The full complement of US requirements phases in between 2015 and 2023, with challenges for all supply chain companies to face at different points along the way.
With the January Drug Supply Chain Security Act (DSCSA) lot-level traceability deadline behind us, pharmaceutical companies are turning their attention to full drug serialization. DSCSA requires that manufacturers mark packages with a product identifier, serial number, lot number, and expiration date by 2017. Given everything that needs to happen by then, from altering highly regulated packaging and distribution processes to addressing enterprise-wide IT, three years is an aggressive implementation timeframe. At the same time, wholesale distributors and other supply chain companies should be gearing up for end-to-end serialization testing with their manufacturing partners well in advance of the deadline to allow time for any necessary adjustments.
Lastly, dispensers – the only supply chain business to have a different lot level deadline – should be planning for July 1 compliance, by which they will need to be able to receive and archive T3 information, and be prepared to produce it in the event of an inquiry.
Product Tracing – By January 1, all supply chain businesses except dispensers needed to achieve lot-based traceability, which involves sharing a Transaction History with every partner to whom you sell product. For many companies, establishing the necessary infrastructure for communication with partners at the level you need for regulatory compliance was the biggest challenge. In addition, the law does not prescribe standard formats for data exchange, so companies need to be equipped to receive transaction data in many configurations.
When serialization come into play, product tracking will still be required but the nature of the requirement changes. Track and trace and serialization requirements will finally converge in 2023.
Verification –In the event of a suspect product inquiry, supply chain companies must be able to produce the relevant transaction documentation within twenty-four hours (dispensers have forty-eight). The challenge is in being able to locate and access the necessary records in this tight turnaround time. Businesses need a storage and retrieval mechanism that supports these queries.
Serialization – During lot level preparation, the industry discovered that completing one transaction between two parties was challenging. When serialization with its end-to-end tracing takes effect, businesses will need to manage many transactions, involving billions of items, with tens to hundreds of partners, including outsourcing ones. So there is the supply chain communication challenge but there is also a data volume challenge as businesses generate, process, and store an unprecedented amount of data and transactions. In the US the smallest saleable unit and the sealed homogenous case need to be serialized. By law, aggregation is not required but there is speculation that it will be required at some future point.
Manufacturers must serialize by November 2017. The rest of the supply chain has more time before they need to make full use of the serial numbers, but there will be circumstances prior to that in which they need to interact with the serial number, like for product returns and suspect product investigations.
TraceLink has worked with more than 100 industry leaders, from all segments of the supply chain, on their DSCSA compliance strategies. That deep, collective experience informs our approach with every new customer.
We have a solution to meet lot level transaction requirements. Less than a month after the January 1 deadline, we had already processed more than one million transaction histories. We also have full serialization in our platform, and have been serializing product for customers for non-US markets for several years now.
All of this is part of the TraceLink Life Sciences Cloud, where we have more than 200,000 supply chain members. The TraceLink network enables you to interoperate with all of those businesses, seamlessly exchanging data and collaborating on key business processes. We accept any data type and translate into a canonical format, neutralizing one of the key challenges of DSCSA. We also have mechanisms in place to manage exception handling, which is quickly proving to be a significant challenge in the compliance landscape. And as your serialization production, events, and archiving needs grow, our Life Sciences Cloud scales with you, eliminating the need to worry about storage and computer processing capacity.
The TraceLink platform meets your US compliance needs. If you operate internationally, it can help you manage your regulatory requirements in all of your markets, allowing you to focus on one global track and trace solution.
|Regulatory scope||Tracing; verification; serialization|
|Product scope||Most pharmaceuticals|
|Participants||Manufacturers, wholesalers, repackagers, dispensers
|Next deadline||5/2015 enforcement discretion ends;
7/2015 for dispensers;
11/2017 for manufacturers
|Serial # format||GS1 standard|
Still Need a DSCSA Lot-Level Solution?
More than 100 pharma companies are already using TraceLink's Transaction History Management System for lot-level requirements under DSCSA. These customers have access to: