The Drug Supply Chain Security Act outlines many new requirements for all trading partners in the prescription drug supply chain. The measures, which have been progressively phased in since 2013, make pharmaceutical products fully traceable to prevent illegitimate, damaged, or harmful drugs from reaching patients.
DSCSA outlines a transformation of how to do business in the pharmaceutical supply chain, requiring serialized packaging, aggregation to associate individual items with shipments, the creation of interoperable connections between trading partners, a data exchange before or during a physical transaction, and other measures.
The final enforcement deadline is November 27, 2023. After that, trading partners who fail to implement the measures for their business type will be unable to receive or sell pharmaceutical products, and will be at risk of audits by the FDA and other bodies, and potentially even penalties from their trading partners.
Here's a quick overview of the DSCSA requirements for dispensers: pharmacies, hospitals, supermarkets, and other businesses that dispense prescription drugs to patients.
DSCSA defines and provides licensure requirements for pharmaceutical trading partners to do business as Authorized Trading Partners. This doesn't include veterinarians or other businesses that only dispense products for animals. To be considered an Authorized Trading Partner, a dispenser must:
As well, they must meet one of the following criteria:
There are also measures for management of trading partners. Dispensers must:
DSCSA requires trading partners to form interoperable point-to-point connections to conduct transactions, using systems that can import and process one another’s data. After this requirement goes into effect, dispensers can only receive shipments with serialized and properly aggregated data. The industry has largely adopted GS1’s EPCIS standard for interoperable data.
Under this requirement, dispensers must exchange serial data in a secure, interoperable, electronic manner. As well, they must implement systems and process that can:
Dispensers can only buy or sell prescription drug products that are encoded with serial numbers in the 2D data matrix barcode and the human-readable text format, with exceptions for certain grandfathered products.
You'll need systems and processes in place to handle suspect or illegitimate products:
You can satisfy DSCSA’s verification requirements by developing a secure electronic database, or using a secure electronic database developed by a third party.
Product tracing relies on electronically delivered 3Ts data: Transaction History, Transaction Information, and Transaction Statement. (Note that Phase II of DSCSA eliminates the requirement for Transaction History.)
Dispensers must respond to any request for information from the FDA, or any other state or federal agencies, relating to a recall or suspect product investigation.
While DSCSA is complex and transformative, a pharmacy can complete its DSCSA compliance journey months in advance of the November deadline. LSPedia offers the industry's leading tools and its most affordable price. Further, it employs serialization data for expiration management and store transfer to cut dead stock costs.
LSPedia's OneScan Pharmacy Solution — available starting at $2 a day — is the most accessible path to audit-proof compliance:
Waiting too long into 2023 will have serious costs and risks; don't put your business in danger of non-compliance when help is easily within reach. Contact us today or write to DSCSA@lspedia.com to get on the path to a stress-free 2024.