Brazil Suspends Pharma Serialization And Tracing Requirements | RxTrace

"Last week, Brazil’s pharma industry regulatory agency, the National Agency of Sanitary Surveillance (ANVISA), announced that they were “suspending” at least part of RDC-54/2013, the declaration that mandated drug serialization and tracing, until further notice.  Thank you to all who forwarded the link to the official announcement.  I was able to translate and read it on Thursday, and I submitted a comment on my own last essay, “Pharma Serialization Deadlines In Flux“, to include the link.  Apparently shortly after that essay was published, ANVISA  publicly announced the suspension." Dirk Rodgers - Read the full article from Dirk here.

Why Does ANVISA Embrace GS1 Standards, Except The Serial Number? - By Dirk Rodgers

Dirk Rodgers of RxTrace.com has written another great article on ANVISA... Read below for an excerpt  or read the full article here. Serialization is a challenge and with this interpretation from the Brazilian authorities it certainly complicates matters for manufacturers if their goods land up in Brazil...

"In Brazil, the National Agency of Sanitary Surveillance (ANVISA) has built their pharma serialization regulation around GS1 standards. They embrace the GS1 Datamatrix and GS1-128, both encoded with GS1 Application Identifiers (AI) and using GS1 Human Readable Interpretation (HRI) (see my previous essay, “The ANVISA Unique Medicine Identifier (IUM) on Drug Packages”, for my thoughts on HRI), the GS1 Global Trade Item Number (GTIN) and the GS1 Serial Shipping Container Code (SSCC) to be specific. But there is one GS1 standard they steer clear of: the GS1 serial number. Why is that?

The ANVISA Unique Medicine Identifier (IUM) on Drug Packages - Dirk Rodgers

Last week Dirk wrote about the DSCSA Product Identifier on Drug Packages in the United States.  Last month he wrote about shipping container/transport package identification under the Brazil National Medicine Control System (SNCM) (see “ANVISA And The SSCC Controversy”).  In this article Dirk takes a look at drug package identifiers under the SNCM as regulated by the National Agency of Sanitary Surveillance (ANVISA).  Dirk is a member of the GS1 Healthcare group - Contact GS1 Healthcare for more information.

An excerpt from Dirk's article:

"Under the SNCM, manufacturers must apply a Unique Medicine Identifier (IUM) to all drug packages imported or sold into the Brazilian supply chain and trace them through the supply chain by December 11, 2016.  By December 11 of 2015, manufacturers must apply the IUM to the packages of at least three lots of drugs and trace them to the dispensing points.  And you thought compliance with the DSCSA was going to be hard to achieve!

Identification Of Pharma Cases In The U.S. - Dirk Rodgers

Article from Dirk Rodgers - "Last week I discussed controversy over the use of GS1’s Serial Shipping Container Code (SSCC) in the Brazil pharma supply chain to meet regulatory requirements imposed by ANVISA. But there are different controversies, or at least potential confusion, in the U.S. pharma supply chain surrounding case labels, and some of those are relate to the SSCC and its use. 

A case product identification label is the label a manufacturer usually places on each homogeneous case at case-packing time to identify what is inside the corrugated box. A “homogenous case” is a case that contains units from a single NDC and all units are from a single packaging lot. The product identification label should not be confused with a shipping/logistics label, which, if it exists, is applied at the time of shipment and contains information about the destination.

Typically, cases that are shipped from a higher-volume manufacturer to a larger wholesale distributor will be placed onto a pallet. The pallet often has cases of multiple products, and even different homogeneous cases of the same product can contain different lot numbers. You can sometimes even find a Non-homogeneous case mixed in with the homogeneous cases. Further, cases on the same pallet can actually be fulfilling different purchase orders submitted by the buyer. All of these variations complicate the job of the receiving clerk." - Read full article at RxTrace.com

ANVISA And The SSCC Controversy - By Dirk Rodgers

GS1’s Serial Shipping Container Code, or SSCC, has been around a long time, but the logistics identifier has recently taken center-stage in a number of controversies related to meeting several country-specific pharma traceability regulations. I’ll cover these controversies in multiple essays—in this one, Brazil. 
This controversy started when ANVISA, the pharma regulator in Brazil, indicated in their regulations that they expected companies to mark every “transport package” entering their supply chain with a unique identification code so that each serialized unit inside can be associated with it (the aggregation requirement).
The problem is, a homogeneous case of product can be both a “standard grouping” of the product and a transport package. GS1 recommends that “standard groupings” of product be marked with its own GS1 Global Trade Item Number, or GTIN. Read the full article at RxTrace.com - Author Dirk Rodgers