Verification is an important part of the operation of the Drug Supply Chain Security Act (DSCSA), and from my observation, it isn’t understood very well. People new to the DSCSA always think “verification” means something beyond what the actual definition is in the law. Late last week the FDA published new draft guidance describing their current thinking about the “verification systems” that members of the supply chain are required by the DSCSA to have in place. It’s an important draft because I suspect not many companies have “verification systems” that have the kind of capabilities spelled out by the FDA. Of course, as usual, it’s only a draft, not for implementation but for comment only. You have until December 24, 2018 to submit comments for consideration by the FDA as they someday make this guidance final. Continue reading DSCSA: Verification Systems Draft Guidance
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