Earlier today, FDA published guidance, for immediate implementation, effectively delaying the effective date of the product tracing requirements for manufacturers, wholesale distributors or repackagers until May 1, 2015. This guidance appears to be a continuation of FDA’s efforts to address industry’s concerns about the implementation of the DSCSA product tracing requirements that are effective
Drug Product Tracing
FDA’s Second Guidance on the Drug Supply Chain Security Act Misses the Mark
By Daniel Gottlieb on
Posted in FDA, Pharmaceuticals
Although FDA appropriately identified the need for guidance on the Effect of Section 585 of the FD&C Act on Drug Product Tracing, Wholesale Drug Distributor and Third-Party Logistics Provider Licensing Standards and Requirements; the Draft Guidance issued by FDA this month does not ask the right questions.
In November 2013, Congress enacted the Drug…