TRACEABILITY AND THE DRUG QUALITY AND SECURITY ACT CONFERENCE
4TH ANNUAL
EXECUTIVE SUMMARY
CONTENTS
INTRODUCTION 3
PRESENTATIONS 4
FOR MORE INFORMATION 8
3
INTRODUCTION:
If you weren’t able to join us this year, here is what you missed at ExL Pharma’s 4th
Annual Traceability and the Drug Quality and Security Act Conference…
With the latest on how to enhance supply chain processes to protect brands and
comply with global serialization, pedigree, and track and trace regulations, this
annual summit, which was held May 15-16 in Philadelphia, brought together some of
the most experienced industry experts to assess the Drug Quality and Security Act
(DQSA) and its impact on the industry. Presenters offered best practices designed
to optimize and protect supply chains via relevant industry-specific case studies and
examples.
Topics covered at the conference included meeting new requirements requirements
of the Drug Quality and Security Act and how the DQSA affects supply chain
processes, best practices to create and enhance traceability and verification
programs, an introduction to the FDA’s secure supply chain pilot program, an update
on global developments and regulations as well as collaboration with wholesalers
and dispensers and putting long-term strategies into place.
In addition, the conference shared FDA draft guidance for the industry on how to
enhance supply chain security, how to leverage serialization as a corporate asset,
implementing risk mitigation strategies to prevent counterfeiting and diversion, and
more.
Following are session summaries and highlights from the 2014 conference…
4
PRESENTATIONS
Highlighting recent developments in the regulatory landscape, “Understand the
Impact of the Drug Quality and Security Act and How it Affects Supply Chain
Processes” clarified differences between DQSA and CA requirements. Presented
by Gabrielle Cosel, Pew Charitable Trusts, and Bill Fletcher, Pharma Logic Solutions,
the session helped attendees outline processes that need to be in place for 2015
and highlighted the new deadlines for lot traceability, verification, serialization and
requests for information. The duo encouraged trading only with authorized trading
partners and offered clear definitions and dates for upcoming changes in the
industry.
The presentation “Best Practices to Implement a Global Serialization Program
and Handle Multiple Mandates” by Bob
Celeste of GS1 discussed the company’s
data exchange, which easily allows product
information to flow through the supply
chain and reminded that businesses
of all sizes need a common language,
possible through the use of standards. He
encouraged companies to “go fast by going
slow,” which entails getting the basics right
and thinking holistically. Increased visibility
can lead to a wealth of benefits.
“Work Closely with Wholesalers and Dispensers to Meet New Requirements and
Put a Long-Term Strategy in Place” was a panel discussion moderated by Carl
Accettura of PharmoRx Therapeutics with the following panelists: Mike Daly of
Valeant Pharmaceuticals; Dick Rogers of Rx Trace; and Priya Gopal of Novartis.
The panelists highlighted the expectations of wholesalers, discussing some of the
letters manufacturers have received from several wholesalers recently, as well as the
benefits of paper vs electronic and the challenges that the notification requirements
entail for manufacturers. The panel addressed how to capture transaction
information, history and statements as well as the importance of developing
verification and notification procedures for suspect products and the ability to retain
samples of these products upon request. They also covered details on laying the
groundwork for an interoperable, electronic tracing of products at the package level,
and strategies for capturing and exchanging data efficiently.
© GS1 US 2013
ACCRUING BENEFITS EPCIS - GS1’S ANSWER TO INCREASED VISIBILITY
36
The results are:
visibility efficiency security collaboration
convenience value safety satisfaction
for business for patients
5
“Outline the FDA Draft Guidance for the Industry on Methods to Enhance Supply
Chain Security” from Gabrielle Cosel of the Pew Charitable Trusts and Dick Rogers
of RxTrace explained the recent FDA
draft guidance with regards to suspect
and illegitimate products. The duo’s
presentation also outlined processes and
outlined steps to implementation while
detailing a variety of guidance expected
in 2014. According to an industry survey,
improving supply chain visibility is the
biggest benefit of implementation while
a variety of challenges, both internal and
external, exist, in particular, costs and lack
of standard architecture.
Carl Accettura shared a case study from Braeburn Pharmaceuticals “Capturing
Strategic Business Value: Designing a New Product’s Supply Chain to be the ‘Safest
in the Market.’” He outlined how the company leveraged serialized track & trace
data commercially to support the business brand and a secure supply chain while
designing a traceable web-based event repository solution to enhance the new
Rx launch, creating an end-to-end commercial brand solution. With serialization
initiatives in particular, he discussed piloting an intuitive, user-friendly serialization
system to create a secure distribution model to generate a virtual chain of custody
with serialized ePedigree while enhancing physician practices and enrollment.
SESSION SUMMARIES
InvesIgaIon, verificaIon, and noIficaIon
‘‘ SUSPECT PRODUCT.—The term ‘suspect product’ means a product for which there is reason to believe that such product— ‘‘(A) is poten)ally counterfeit, diverted, or stolen; ‘‘(B) is poten)ally inten)onally adulterated such that the product would result in serious adverse health consequences or death to humans; ‘‘(C) is poten)ally the subject of a fraudulent transac)on; or ‘‘(D) appears otherwise unfit for distribu)on such that the product would result in serious adverse health consequences or death to humans.
“ ILLEGITIMATE PRODUCT.—The term ‘illegi)mate product’ means a product for which credible evidence shows that the product— ‘‘(A) is counterfeit, diverted, or stolen; ‘‘(B) is inten)onally adulterated such that the product would result in serious adverse health consequences or death to humans; ‘‘(C) is the subject of a fraudulent transac)on; or ‘‘(D) appears otherwise unfit for distribu)on such that the product would be reasonably likely to result in serious adverse health consequences or death to humans.
DefiniIons: Suspect and IllegiImate Product
6
Bill Fletcher of Pharma Logic Solutions presented a regulatory and strategy
supply chain master class on “Making the Right Business Decisions in Light of
the Drug Quality and Security Act (DQSA)” to help prepare organizations for
item-level serialization and traceability and provide the latest information on
requirements. He noted that global trade will drive counterfeiting to areas of the
world that lack traceability regulations and that packaging alone does not thwart
counterfeiting. Variations in product identification/uniqueness in other countries
necessitates some agility in data systems. Key elements of the new law are that it
defines supply chain participants and their requirements for managing and passion
transaction information; it establishes rules for providing transaction information
for investigations and suspect product notifications as well as rules for trading
with “authorized” supply chain participants. DQSA also adds a new requirement
to uniquely identify prescription drug products and their shipping cases using
serialization and defines steps that will be taken to move the industry to certified
chain of custody pedigree within 10 years. The right strategy, vendor selection and
functional design are key to successful implementation.
“Beyond The Drug Quality And Security Act - why this Legislation Falls Short of
a Safe and Secure Supply Chain” by Walter Berghahn of the Healthcare Packaging
Council shared his organization’s mission to advance the use of compliance-
prompting packaging to improve medication adherence and patient health outcomes.
In general, packaging is designed to protect
patients and help them take medication,
protect the product from the environment,
protect the product and patient from
unscrupulous players in the supply chain,
and protect our healthcare system from
unwanted costs and unnecessary patient
harm. Supply chain security is all about the
right patient, right drug, right dose, right
time and safe drug. Even a 1 percent error
rate among 4 billion prescriptions means
40,000,000 potential impacts. Functional
packaging is critical to getting it right.
SESSION SUMMARIES
The 99% good � Manufacturers � Distributors � Physicians � Pharmacists
� But 1% bad in a system of 4 billion prescriptions means 40,000,000 potential impacts
7
“Implementing the FDA’s Secure Supply Chain Pilot Program” was the focus of
a session offered by Brad Elrod of Pfizer. In a typical pharmaceutical supply chain,
many transport assets and people are involved in getting pharmaceuticals from cradle
to table, which is why the FDA launched its Secure Supply Chain Pilot program to
implement aspects of the FDA Safety and
Innovation Act. The program is designed
to create regulatory/entry simplification
and process improvements that eliminate
“may proceed” time and increase supply
chain predictability. It was also intended to
provide a measurable reduction in inventory
through decreased lead time in supply
chain agreements and decrease double
handling at logistics centers as well as faster
resolution of issues around short supply
compounds.
SESSION SUMMARIES
1
Pharmaceu)cal Supply Chain
Many Transport Assets and People Are Involved in Getting Pharmaceuticals From Cradle to Table???
Finished Product Manufacturing/Packaging
Road
Customs
Port of Departure
Warehouse/ Logis<cs Center
Interna<onal Ocean/ Air/Road Port of
Arrival
Customs
Road
Warehouse
Warehouse / Customer
API Manufacturing
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UPCOMING EVENTS:
5TH TRACEABILITY AND THE DRUG QUALITY AND SECURITY ACT CONFERENCE May 5-6, 2015 in Philadelphia
www.exlevents.com/traceability
Join us in Philadelphia at our annual conference to make sure you have everything in place
to be able to respond to FDA inquiries within 48hrs to avoid high fines and work effectively
together with your wholesalers and dispensers. Our expert speaker faculty of leading supply
chain experts provides valuable insights what processes to put in place now to comply with
the requirements in 2017 and leverage serialization benefits to secure an advantage in the
market place. Hear how they have managed to provide business value through serialization
and pedigree beyond regulatory compliance.
This interactive forum discusses best practices for track and trace and lessons learned
from implementing an integrated global supply chain security program, which improves
transparency, secures your supply chain and protects your brand, while leveraging business
benefits.
Do you want to spread the word about your organization’s solutions and services to
potential clients who attend this event? Take advantage of the opportunity to exhibit,
present an educational session, host a networking event, or distribute promotional items
to attendees. ExL works closely with you to customize a package that suits all of your
needs. To learn more about these opportunities, contact, Matthew Halvorsen, Business
Development Manager at 917-258-5163 or [email protected]