Epic DSCSA / FMD Fail: the apology memo to your boss
In the spirit of public service to the pharmaceutical industry as it gears up for the implementation of various traceability requirements, we are offering a free template email for late adopters. Pull this out and use it if you ever have to own up to getting serialisation really, really wrong. (NB we use the European spelling on this site but please mentally replace the middle s with a z if that bothers you). We hope you never need this email, but if you’re going to wait until next year before doing anything or talking to vendors, you might want to file this post in Favourites for re-use later.
Date: sometime in 2017
To: CEO, Pharmacorp Inc.
From: COO / Chief Compliance Officer / Head of Regulatory / SVP Manufacturing / Head of Supply Chain / Head of Technical Operations / whatever
Thanks for the copy of the Drug Supply Chain Security Act / Falsified Medicines Directive and your refreshingly to-the-point enquiry about our current readiness status for “the [expletive deleted] pack coding deadlines which are only months away”.
As of today, I have to admit that I don’t know if our production people will be able to get everything ready in time.
We thought it was a bluff
To your point, we have certainly been aware since 2013 (and in fact years before) of the requirement to mark packs and I agree that three years of preparation seems like an adequate amount of time to get things done. However, we were hoping that either Congress / the EU was kidding or that delays and enforcement holidays would kick this can a long way down the road. I suppose with the benefit of hindsight this may indeed look somewhat “incompetent”.
We need more cash
We have now contacted all the suitable technology vendors and serialisation consultants but it seems that their lead times may be longer than we had hoped. Apparently there is a finite availability of expert resources and the first choice partners are all maxed out with existing customers who are further down the track in preparing for the deadline. Our calculation that we could save money by waiting as long as possible and letting other people make all the mistakes now looks like it may have been wrong. We may have to revisit our budget request to ask for emergency funds to get this done.
We may not be able to sell product
You asked whether missing the deadline would have an impact on our commercial operations. After enquiring with the sales division (thanks for the introduction, by the way) it turns out that the USA and EU are our largest markets – who knew? As I understand it, we can’t sell product there if we don’t meet the legal criteria, so I guess this will have an impact on the financials at some stage. I would recommend holding a slot on the agenda at the next earnings call. If it helps at all, the delay in initiating our program means that some of the capex for equipment spend might be pushed into the next financial year.
We hope to be fully compliant again as soon as we get all the process mapping done, user requirement specifications written, vendors selected and contracts finalised, necessary pilots completed, equipment installed on all lines, errors minimised and OEE brought back into line, supply chain partners up to speed, serialised and aggregated inventory flushed through distribution channels etc.
FYI, I am also hearing that the DSCSA and FMD may have parallels in other geographies. This may have some other impacts on our Rest of World operations. Our contract manufacturers are in various states of readiness and we may need to revisit key supply arrangements. As soon as I get to grips with what the requirement for serialisation and tamper-evidence means for our global manufacturing strategy I will report back.
I’ll get my coat…
Apologies once again for being caught out by this deadline creeping up on us so suddenly – after all this time. Thanks for your understanding and good luck with explaining the situation at the Board meeting.
Don’t be that person. Make sure you plan for serialisation, aggregation and tamper-evidence. If you are planning pack changes, bear in mind that all unit-of-sale packs will need to be tamper-evident in the EU by February 2019. Make allowance for strategic advice and implementation consultancy. Don’t try to wing it. This really is the last chance to get things done right and in time. Whether you are just starting, well advanced but need some help along the way, or almost done but just need a little extra resource for fine tuning, we can help. Contact us: [email protected]
Tags: European Union, pedigree, serialization, strategy, USA