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Falsified medicines directive: the clock is ticking

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Whilst proposals for a hub-and-spoke prescription fulfillment model appear to have been pushed onto the back burner, the implementation of the falsified medicines directive (FMD) is really starting to cook on gas.

This affects everyone within the pharmaceutical supply chain and is a transformational change to current systems and processes.

You may be tempted to believe FMD will disappear following the EU referendum, but no one should bury their head in the sand; FMD is already incorporated into UK legislation and is certain to happen.

With the legislation becoming effective from February 9, 2019, the countdown is on for the pharmaceutical industry to comply with the enhanced security requirements. With increasing fears, concerns and instances of counterfeit medicines entering the pharmaceutical supply chain, these changes should be welcomed even if they don’t come cheaply.

Collective Responsibility

Previously, I’ve encouraged all parties to take a holistic view of the industry. FMD is a prime example of an issue affecting all stakeholders and needs to be considered by manufacturers, wholesalers and dispensers with an aligned approach.

The legislation requires prescription medicines for sale to carry a unique and randomised serial number encoded in a 2D-barcode and a visible anti-tampering device.

Manufacturers will be responsible for uploading the serial numbers to a system of national databases linked by a European hub, and country-based national data repositories will allow verification at different times and final decommissioning when each pack is dispensed to a patient.

At each stage of the supply chain, the product will be inspected to ensure it hasn’t been tampered with, has not previously been dispensed and that the packaging is intact. Additionally, goods distribution practice (GDP) guidelines will require the individual product to be scanned to record the batch number and expiry date. This check will indicate whether the product is authentic and bring up information such as whether the product has been subject to a recall.

These actions, to be carried out across the pharmaceutical supply chain, are vital to its integrity and minimise the opportunity for the original product to be replaced with a counterfeit.

FMD to increase patient safety

I wholeheartedly support the objective of FMD to implement end-to-end verification of the medicines supply chain for all prescription medicines, to not only enhance patient safety, but also provide greater confidence in the integrity and quality of medicines prescribed. 

To ensure its successful implementation, FMD will require significant investment both in financial terms and a commitment of time and resource.

As one of the UK’s leading pharmaceutical wholesalers, we’ll continue to work with regulators, stakeholder bodies, our manufacturer partners and pharmacy customers to ensure all participants in the medicines supply chain are ready to safely implement the processes for medicines authentication in time.

Transformational change

February 2019 may seem a long way off, but don’t underestimate the scale of change required and, in reality, we have less than two years to be ready and to develop, test and input new systems and working practices. I’d encourage everyone to familiarise themselves with the requirements and start collective discussions with stakeholders now!

I have no doubt the change will be difficult and will come at a price, but I believe the long-term benefits far outweigh the short-term challenges. Given that all of us either take some form of medicine or have family or friends who are dependent on medication, it may be in our best interests to deliver this solution for the benefit of all.

6 Comments
Question: 
What do you make of FMD?

max falconer, Superintendent Pharmacist

Shameful C&D! Allowing space for the peddling of propaganda by a person representing organisations that have lobbied and dumped this ridiculous directive on community pharmacy. This is a wildly onerous requirement to what is an apparently non-existent problem. No one I have asked has been able to give a single example of counterfeit medicines entering the UK bricks and mortar pharmacy chain.

 

 

 

Z ZZzzzz, Information Technology

Actually there were a few instances that I remember around 2005-2006 and it involved Lipitor at the time.  Use a search engine to get details of this kind of thing at the time.  Pfizer cited stopping counterfeit medicines as one of the excuses for their solus deal.  Some commentators at the time cited Pfizer's demands for stopping parallel imports as they were losing out on selling Lipitor in their own US market at a huge cost price as the real excuse. Golden triangle of UK to Canada to US allegedly.  Pfizer would never admit that allegation.  If you look at Pfizer's comments on how to stop counterfeits 8 or 9 years ago, a lot of their points are there in the FMD.  So even the EU are not immune to the power and influence of Pfizer. 

max falconer, Superintendent Pharmacist

I thinkAA you mean the EU are complicit with the power and influence of Pfizer. As they tend to be with all wealthy lobby groups that's why for instance so many of the old remedies we used to sell from smaller manufacturers have disappeared in recent years.

Z ZZzzzz, Information Technology

Agreed.

Z ZZzzzz, Information Technology

As it will be Big and small Pharma companies that lose financially if any falsified medicines get through the system surely they should bear the total cost of introducing this.  I wish people like Mr Main would stop trying to spin this any other way by infering that as we all use medicines or know someone else that uses medicines as an excuse to share the cost.  Complete and utter red herring!  Any such sustem will need original pack dispensing if it has to made easy to implement.  If that is not forthcoming then what's the point.

James Laurence, Community pharmacist

its obviously been a long time since jeremy worked in a busy pharmacy if ever at all

this idea has been created by the worst sort of bean counter who thinks we have nothing better to do than take on more pointless tasks we are over worked under resourced by all means have tamper evident packaging but bar code scanning get real idiots in your ivory towers. this idea needs shoving where the sun doesnt shine

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