Tag Archives: Pharma Supply Chain

China

The Intrigue Contained In The New China Drug Code

The CFDA “Bit Code”

Over the last few weeks, the pharma serialization and tracing landscape has begun to shift in China.  The China Food and Drug Administration (CFDA) announced a new use for an existing “National Drug Code” in Public Notice 2017-1 that, according to Google Translate (a helpful but very imperfect translator), will be referred to as the “Bit Code”.  In addition, a new notice has appeared on the AliHealth-hosted web portal that drug companies have been using for the last seven years or so to obtain serial numbers for their drug packages.  Automated translation tools leave too much to speculation so companies should not use them for compliance purposes.  However, here are my thoughts/speculation on what is happening.  Continue reading The Intrigue Contained In The New China Drug Code →

SSCC

Serializing Product Groupings Under Global Regulations

A “product grouping” is any collection of saleable units of products that are bound together in some way.  They can be “bundles”, homogeneous or non-homogeneous cases, totes, pallets or something like these.  The pharma serialization regulations in some markets call out some of these groupings for special treatment, and some do not.  I’ll try to catalog what we know about product groupings in each of the current, known regulations. Continue reading Serializing Product Groupings Under Global Regulations →

HDA

First Meeting of the HDA Verification Router Service Task Force

Happy Martin Luther King Jr. Day!

As someone who often attempts to explain truth and reality through writing, I can really appreciate the writing skill of Rev. Dr. Martin Luther King Jr. (see “Celebrating Martin Luther King Jr.”).  I’ve learned that the best writing has to come from your heart just as much as it does from your head, but I still make mistakes that I don’t expect to see in Dr. King’s writing.  Last week is an example.  By attending the Healthcare Distribution Alliance’s (HDA’s) Verification Router Services (VRS) Task Force meeting in Crystal City, Virginia, I learned more about HDA’s intentions for the design of the VRS. Continue reading First Meeting of the HDA Verification Router Service Task Force →

FDA Guidance

FDA Finalizes Guidance On Suspect Product

suspect-product-final-guidanceHere we are, waiting for the FDA to publish new draft guidance related to the Drug Supply Chain Security Act (DSCSA) after a deadline that passed more than a year ago, and what do we get?  A final version of a guidance document that was originally published in draft form two and a half years ago:  “Identification of Suspect Product and Notification”.  Well, OK, thanks. 

I have to say, this is important guidance.  In fact, it is probably the most important DSCSA guidance that the FDA has published yet, whether in draft or final forms.  And, unfortunately, Continue reading FDA Finalizes Guidance On Suspect Product →

Anti-counterfeiting

Sponsored: Will Global Serialization Mandates Result In Less Counterfeiting?

iqpc-acf-sidebar-banner-1One of the focuses of RxTrace is to explore global pharma serialization and tracing regulations in an attempt to discover some of their implications.  Some implications turn out to be obvious, but some turn out to be surprising.  Identifying the implications early provides us with a better understanding of what to expect from our investments in time to fine-tune those investments.  If company leaders have a realistic understanding of what to expect from different investments, they will make better decisions for their stakeholders.  Can they expect to be fully compliant?  Only partly compliant, thus needing to spend more down the road?  Will they be fully compliant with the law, but disappoint their primary customers and thus find that their business takes a hit?  If they have a good idea of what to expect before they Continue reading Sponsored: Will Global Serialization Mandates Result In Less Counterfeiting? →

Center For Supply Chain Studies, DSCSA

Could Blockchain Technology Be Used For DSCSA Compliance?

c4scs-logoIf your email inbox is anything like mine it has recently been swamped with articles and webinar notices about the possible use of blockchain technology to solve multiple challenges in healthcare.  I recently attended a very interesting day-long workshop on that very topic. 

So is blockchain a real solution, or is it just the latest over-hyped buzzword that is being promoted by people who don’t understand the real needs of healthcare companies?  I’ll tell you what I think.  But first, a little background.

Blockchain technology is a way of encapsulating information within a layer of structured data that multiple parties can use as the basis for trust in the accuracy of the source of that information.  It’s all about adding trust to information that is shared between parties.  Trust is just one of the many Continue reading Could Blockchain Technology Be Used For DSCSA Compliance? →

Samples

Drug Samples Under Global Serialization and Tracing Regulations

1 Comment

istock-526070305-smallerSome pharma manufacturers make special packages of certain drugs that they give away to certain medical practitioners as a way of promoting the product and introducing the practitioner and their patients to it.  The method of distribution is usually through field sales people employed directly by the drug manufacturer, and the drug samples are delivered by them directly to the practitioner.

What could go wrong with that?  Probably diversion of the product contained within the “free sample” packaging back into the supply chain, but without the “free sample” indicator on the package.  Should these special packages be tracked?  Should they be serialized?  Continue reading Drug Samples Under Global Serialization and Tracing Regulations →

EPCIS, GS1 U.S.

The New GS1 US DSCSA Implementation Guidance Suite

1 Comment

A few weeks ago, GS1 US published version 1.2 of the DSCSA implementation guidance that documents how to apply GS1 standards when meeting the U.S. Drug Supply Chain Security Act (DSCSA).  GS1 US is the GS1 Member Organization (MO) in the United States, of GS1, the global supply chain standards organization.  Companies who market drugs in the U.S. pharma supply chain and their solution providers will find this new version to be an indispensable resource that will Continue reading The New GS1 US DSCSA Implementation Guidance Suite →