Stakeholders Want Changes to Supply Chain Guidance
While praising FDA efforts to develop guidances and standards to implement the Drug Supply Chain Security Act, four industry stakeholders are seeking changes to a draft guidance on the interoperable exchange of information for tracing of certain human, finished prescription drugs.
The American Pharmacists Association (APhA) says the information guidance is only one of several guidances addressing the enhanced drug distribution security requirements. “Trading partners cannot adequately prepare systems and processes for the enhanced requirements until the full roadmap is finalized….,” APhA says. “APhA urges FDA to finalize these guidances soon to provide sufficient time for implementation and compliance by 11/27/23.”
Pharmaceutical Research and Manufacturers of America (PhRMA) writes that FDA should provide guidance for non-EPCIS (Electronic Product Code Information Services) standards. It says the agency should include in the final guidance an explicit acknowledgment that Web portals are an acceptable method to exchange information. PhRMA also lists several topics for which it believes additional clarification is needed.
The Healthcare Distribution Alliance lists several comments it would like to see addressed in the final guidance.
Finally, the Association for Accessible Medicines says it and its members commend FDA for its endorsement of EPCIS. The association asks for clarification on whether the revised draft guidance replaces an 11/2014 draft. It says the clarification is needed because the 2014 document specifically endorsed the use of data portals and emails as acceptable interoperable methods to make information available to trading partners and the current draft is silent on their use. “Data portals and emails are ingredients of our members’ 2023 plans to establish interoperable data exchange with some of their trade partners, notably small dispensers,” the association says.