New FDA Drug Supply Chain Guidances
FDA has finalized two guidances and published two draft guidances to help ensure that prescription drugs are identified and traced properly as they move through the supply chain. An agency online notice says the documents provide agency recommendations for how to comply with applicable Drug Supply Chain Security Act (DSCSA) requirements, including those for enhanced drug distribution security at the package level that take effect 11/2023.
Industry questions about the use of product identifiers on drug packages are answered in the finalized guidance Product Identifiers Under the Drug Supply Chain Security Act: Questions and Answers.
The final guidance Drug Supply Chain Security Act Implementation: Identification of Suspect Product and Notification is to aid certain trading partners in identifying a suspect product and specific scenarios that could significantly increase the risk of a suspect product entering the pharmaceutical distribution supply chain. It also describes how trading partners should notify FDA of illegitimate product and sets forth a process for terminating notifications of illegitimate product in consultation with the agency.
A revised draft guidance, Definitions of Suspect Products and Illegitimate Product for Verification Obligation Under DSCSA, gives FDA’s current understanding of terms used to define “suspect” and “illegitimate” products. In response to stakeholder comments, it revised a 3/2018 draft guidance.
Finally, a new draft guidance, Enhanced Drug Distribution Security at the Package Level Under DSCSA, is to assist supply chain stakeholders, particularly trading partners, with requirements for enhanced drug distribution security at the package level that take effect 11/27/23. The guidance provides recommendations on the system attributes necessary for enabling the secure tracing of product at the package level.