2 Draft DSCSA Guidances Out

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FDA has published two draft guidances covering portions of the Drug Supply Chain Security Act (DSCSA). The first guidance, DSCSA Standard for the Interoperable Exchange of Information for Tracing of Certain Human, Finished, Prescription Drugs, identifies the standards necessary to facilitate the adoption of secure, interoperable, electronic data exchange among the pharmaceutical distribution supply chain. The document also clarifies the trading partners, products, and transactions subject to such standards.

The guidance revises an 11/2014 draft to update the policy articulated in that draft to reflect enhanced drug distribution security requirements that take effect 11/27/23.

The second guidance, Identifying Trading Partners Under the Drug Supply Chain Security Act, is to assist industry and state and local governments in understanding how to categorize the entities in the drug supply chain under the act. The document revises an 8/2017 guidance to address the status of some entities as trading partners, provide clarification on certain drug distribution scenarios, and address the interpretation of a section of the law that discusses third-party logistics providers’ licensure status before the effective date of forthcoming regulations establishing licensure standards.

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