This post is Part 2 of the Series: Understanding The Drug Supply Chain Security Act and What it Means for Pharmaceutical Distribution Companies. For a full list of all the topics in this series, please see the bullet points at the end of this post.
2024 Update: Blue Link has reviewed various FDA communications and resources regarding the requirement to continue to receive and send Transaction Reports “T3s”. We believe, based on FDA Guidance, Enhanced Drug Distribution Security Requirements Under Section 582(g)(1) of the Federal Food, Drug, and Cosmetic Act--Compliance Policies, specifically section IV, that distributors/trading partners should continue to use current methods regarding Transaction Reports. This recommendation is Blue Link’s interpretation, and is in no way intended to be a definitive opinion or legal advice. Understanding of, and compliance with, FDA regulations remains your own responsibility.
The requirement to track products is not new to the pharmaceutical industry. For years there have been various requirements around tracking lot numbers (batches) of products and their expiry dates and Pedigree management (tracking of supply chain members involved with the purchase and sale of product). For the most part, it has always been the responsibility of the manufacturer, repackager and primary distributor to keep track of specific information. This, combined with information in the previous legislation, made it difficult or near impossible to track back through other trading partners that took ownership of the product throughout the supply chain in order to easily manage a recall. Furthermore, there was little ability to determine if a product was legitimate or illegally injected into the pharmaceutical supply chain. With the advent of the Drug Supply Chain Security Act and more specific regulations, traceability has improved. In this second installment of this Series around the DSCSA, we will provide information on the specific traceability requirements small-medium size pharmaceutical distribution businesses must comply with in order to run their business.
As of July 1st, 2015 the “Drug Supply Chain Security Act (DSCSA)”, Section 582 requires that all “Trading Partners” including manufacturers, repackagers, wholesale distributors, and dispensers not accept pharmaceutical products unless the trading partner they receive the product from can provide specific information about the product. This specific requirement dictates that every shipment moving through the supply chain include a Transaction Report or "T3". Essentially, where Pedigree tracks historical information about a specific lot and the trading partners involved, a T3 or Transaction Report includes the same information in addition to more details about the product and a statement of legitimacy. Pedigree details are part of the Transaction Report which passes from the existing owner to trading partners downstream. Every time product changes ownership, the new owner gets added to the Transaction Report. There is only one Transaction Report per product/lot number. This allows each trading partner to verify that the movement of product is legitimate and legal.
Transaction Report
The Transaction Report breaks into 3 distinct pieces:
Transaction Information
The T3 Report requires the following transaction information:
- Name of the product
- Strength and dosage
- Specific NDC#
- Number of containers
- Lot number of the specific product
- Date of transaction and shipment
- Business name and address of the trading partner sending/receiving the product
Transaction History
The T3 Report requires the recording of the product’s entire transaction history (Pedigree) starting with the manufacturer. Details in the DSCSA and associated FDA generated documents, provide guidance on when a product's ownership is transferred and when the Transaction History of the product needs to be updated to include the transaction.
Transaction Statement
The transaction statement records the following information and requires that the trading partner transferring ownership of the specific product adhere to the following information.
- Is authorized under the DSCSA
- Received the product from a trading partner that is also authorized under the DSCSA
- Received the transaction information and statement from the trading partner
- Did not knowingly ship a suspect or illegitimate product
- Has systems in place to comply with verification requirements
- Did not provide false transaction information or knowingly alter the transaction history
For the most part, the industry has combined the above information into one document. When a product has a change of ownership, the trading partner must provide all applicable information for each lot of the product to the new owner of the product. The DSCSA requires that a product shall not be received into the receiving trading partner's inventory until a complete and accurate Transaction Report is provided by the trading partner shipping the product.
There no requirements around a trading partner managing this information electronically, however, the time it takes to manually enter and record the data and keep accurate records makes this task very time-consuming and error-prone. The best way to manage this information is to find a full inventory and accounting system that also has specific pharmaceutical industry functionality.
Learn more about the Drug Supply Chain Security Act (DSCSA) and Pharmaceutical Distribution Software.
- Blog: Part 1 – Drug Supply Chain Security Act (DSCSA) and Pharmaceutical Distribution
- Blog: Part 2 – Drug Supply Chain Security Act (DSCSA) Transaction Report (T3)
- Blog: Part 3 – DSCSA: Suspect and Illegitimate Product Handling and Notification
- Blog: Part 4 – Serialized Numerical Identifier (SNI) and the Drug Supply Chain Security Act
- Blog: Part 5 – Drug Supply Chain Security Act (DSCSA) – Annual Reporting
- Blog: Part 6 – How to Manage DSCSA Requirements with Pharmaceutical Software
Information in this post was taken from DSCSA Implementation: Product Tracing Requirements — Compliance Policy and other various presentations provided by the FDA. The information contained herein is provided as a summary and guidance only. For specific requirements go to “Drug Supply Chain Security Act (DSCSA)” and associated FDA Guidance Documents.
Want to learn more about how software can help your pharmaceutical business meet DSCSA Regulations? Contact Us Today!
