Tag Archives: FDA

Data Ownership In The Track And Trace Cloud, Reprised And Updated

Back in January of 2013 I wrote an important essay called “Data Ownership In The Track And Trace Cloud” which analyzed a potential future where members of the pharma supply chain would need to deposit and maintain track and trace data in a centralized or semi-centralized data repository in the “cloud”.  As the title implies, my main focus was on who would own that data, which was, and continues to be, a hot topic.

But now, five years on, things are getting less “potential” and more real. Continue reading Data Ownership In The Track And Trace Cloud, Reprised And Updated

I Receive My First Serialized Drug From My Pharmacy: Is It Right?

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Normally drugs dispensed by American pharmacies are repackaged into the “standard” amber vial.  The pharmacy places their own label on that bottle so the patient normally doesn’t receive the manufacturer’s package that would have the new 2D barcode mandated by the Drug Supply Chain Security Act (DSCSA).  There are a few drugs that are not repackaged by US pharmacies, like most things in an inhaler and drugs in “compliance packaging” like birth control pills.  But even then, the pharmacy puts their label on the package

 

somewhere.

One of the few drugs I take daily is a statin, which has always been put into an amber bottle by my pharmacy.  A few months ago I received a three months supply, and to my surprise, the pharmacy dispensed the prescription in the manufacturer’s original 90-count bottle, and there was the DSCSA 2D barcode on the label.  The pharmacy label was positioned so that it formed a “flag” and did not cover the 2D barcode, and the pharmacy label was easily removed to expose the entire manufacturer’s label.  This drug was made by Lupin Pharmaceuticals, a generic drug manufacturer base in India.  How did they do? Continue reading I Receive My First Serialized Drug From My Pharmacy: Is It Right?

DSCSA: OIG Report Exposes Likely Enforcement Approach

Last week the US Department of Health and Human Services (HHS) Office of Inspector General (OIG) published their second report on the experience of selected members of the pharma supply chain with the exchange of drug product tracing information as required by the DSCSA.  This one was aimed at dispensers.  The one published last fall was aimed at wholesale distributors.  As you know, starting in January 1, 2015 (delayed until May 1, 2015), pharmaceutical wholesale distributors have been required to pass to their customers for non-exempt prescription drug shipments, and retain for six years, transaction documents (TI, TH and TS).  Since July 1, 2015 (delayed until March 1, 2016), dispensers have been required to receive and store these Continue reading DSCSA: OIG Report Exposes Likely Enforcement Approach

The 2 Most Helpful Requirements In The DSCSA

There are lots of impactful requirements in the Drug Supply Chain Security Act (DSCSA), but there are two whose impact will likely increase the safety of patients far more than all of the others.  That is, they are the most helpful requirements.  Do they include serialization?  Verification?  Transaction documentation?  Wholesaler and 3PL licensing?  Not even close.

The two requirements that I believe will have the biggest impact on the safety of drugs in the US supply chain are the requirement to only engage in transactions with authorized trading partners, and the lot number being included in the 2D barcode.  Let me explain. Continue reading The 2 Most Helpful Requirements In The DSCSA

DSCSA Guidance: Standardization of Data & Documentation Practices for Product Tracing

The second—and longer—draft guidance document the FDA published on the day of the third DSCSA public meeting is a “catch-all” (see also “DSCSA Guidance: Definitions of Suspect and Illegitimate Product for Verification Obligations” and “FDA DSCSA Public Meeting #3: A Difference?”).  It contains lots of diverse recommendations, all related to the standardization of data contained in the DSCSA transaction information (TI), transaction history (TH), and transaction statement (TS).  This draft guidance applies to every member of the supply chain, including drug manufacturers, CMOs, 3PLs, wholesale distributors, repackagers and dispensers of all kinds.  Everyone should read it and submit comments to the FDA when something isn’t clear enough.  Continue reading DSCSA Guidance: Standardization of Data & Documentation Practices for Product Tracing

DSCSA Guidance: Definitions of Suspect and Illegitimate Product for Verification Obligations

As I mentioned last week, the FDA published two new draft DSCSA guidance documents on the day of the recent FDA DSCSA Public Meeting (see “FDA DSCSA Public Meeting #3: A Difference?”).  Let’s take a closer look at what’s in them and their significance to companies facing the Drug Supply Chain Security Act (DSCSA).  I’ll cover one of the two in this essay and cover the other document in the next essay. Continue reading DSCSA Guidance: Definitions of Suspect and Illegitimate Product for Verification Obligations

FDA DSCSA Public Meeting #3: A Difference?

Last Wednesday the FDA held the third in a series of three Drug Supply Chain Security Act (DSCSA) public meetings (see “FDA Announces New DSCSA Pilot Program and Public Meeting Series”).  I noticed a few important differences at this meeting compared with the two previous meetings (see “FDA DSCSA Public Meeting #1 Exposes Gulf In Goals”, and “FDA DSCSA Public Meeting #2, Still A Gulf”).

Overall, these differences indicate that the FDA may be beginning to recognize how much ground they and the industry must cover between now and November of 2023, and it appears that has led them to get a little more rational.  One meeting is not enough to establish a change in pattern, but if it eventually proves true, then this meeting would be the beginning of that change.  A big injection of rationality is what happened in Brazil back in late 2016 (see “Brazil Gets Rational With Their New Pharma Traceability Law”) and that seems to have put them on a course for success.  Could something similar be happening here? Continue reading FDA DSCSA Public Meeting #3: A Difference?

Human Readable Text Controversy

This example shows a compromise alternative to print both the NDC and the GS1 GTIN in the DSCSA Product Code human readable, following the GS1 General Specifications healthcare human readable guidelines in section 4.14.1

I was a little surprised at how heated the discussion was at the breakfast table back during last year’s Healthcare Distribution Alliance (HDA) Traceability Seminar.  I chose an open seat at a table with people from multiple drug manufacturers and someone from GS1 US.  Our conversation at the table started out typically—the weather, the previous day’s speakers—the usual.  I had recently been thinking about the human readable portion of the Product Identifier mandated by the Drug Supply Chain Security Act (DSCSA) (see “The DSCSA Product Identifier On Drug Packages”), so I asked everyone what their company was planning to do? Continue reading Human Readable Text Controversy