FDA Faulted for Late Product Identifier Guidance
Bristol-Myers Squibb is finding fault with FDA for issuing a draft guidance on product identifiers under the Drug Supply Chain Security Act (DSCSA) close to the end of the enforcement discretion period. The company says that “manufacturers have been preparing for a number of years to comply with the DSCSA requirement of affixing a product identifier on each package and homogenous case. With only two months left to the enforcement discretion period, manufacturers cannot make changes to packaging equipment and modify artwork in order to accommodate recommendations put forth in this guidance.”
In its comment, the Healthcare Distribution Association says release of the draft guidance two months before the 11/27 product identifier deadline “has caused considerable consternation for trading partners who believed they had accomplished this element of DSCSA implementation (often months or years ago) and now must weigh the significant risks and costs of changing their labeling and packaging operations, again (and potentially a third time, if the Q&A is finalized with changes). Unfortunately, the assertion that the Q&A is in draft and not binding offers no remedy.”
The Association for Accessible Medicines says that while its members appreciate the additional clarity provided through the draft guidance and its question-and-answer format, they still have technical and clarifying questions.
The Biotechnology Innovation Organization says the draft “helps to answer common questions sponsors may have regarding use of product identifiers….” The association offers suggestions and feedback to help ensure the draft provides clear and effective guidance to all stakeholders and allows for sufficient flexibility to reduce the likelihood of rework and potential product delays and shortages.
The National Association of Chain Drug Stores offers specific comments on elements of the guidance.