FDA Bar Code Rule

1. FDA Bar Code Rule Richard A. Nickel, M.S., R.Ph. Mallinckrodt Inc. St. Louis, MO

2. 14 Mar 2003 Proposed Rule 26 Feb 2004 Final Rule Applied to “certain human drugs and biological products” Required linear bar code containing NDC number on product label FDA Bar Code Rule

3. Revises 21 CFR Parts 201, 606 and 610 Revision intended to improve patient safety Geared toward needs of hospital pharmacies and the growing use of bar-coding equipment “Bar codes can help reduce or detect potential medication errors by enabling health care professionals to check whether they are giving the right drug via the right dose and right route of administration to the right patient at the right time.” (i.e. 5 rights) FDA Bar Code Rule

5. Mfr to Wholesaler NDC codes used ** Wholesaler to Pharmacy NDC codes used ** Pharmacy to patient Rx numbers used ** **used to tie into a record or link multiple tables in a relational database system

6. NDC Number NDC Number Rx Number

7. FDA Bar Code Rule Radiopharmaceuticals are exempt ‘low misadministration rate’ cited FDA correctly indicates there is no threshold level to determine applicability of rule NRC ‘written directive’ requirement cited

8. FDA Bar Code Rule FR Discussion “We believe that NRC regulations pertaining to the use of radiation byproducts provide sufficient safeguards in preventing medication errors involving radiopharmaceuticals,…” Most users purchase their radiopharmaceuticals from central nuclear pharmacies instead of direct from mfr. NDC codes do not exist for many pharmacy-dispensed products.

9. FDA Bar Code Rule FR Discussion In the comments received, there may have been confusion about Whether or not the final rule would apply to a state-licensed pharmacy, and, The perceived value of a bar code in a nuclear pharmacy.

10. Radiopharmaceuticals are exempt Nuclear pharmacies may use bar coding equipment to prevent errors in dose preparation, packaging and delivery Lack of bar codes on radiopharmaceutical vial creates a weakness in the use of bar coding Preserves the situation the Rule was intended to remedy

11. Radiopharmaceuticals are exempt Patient Safety, as applied in nuclear pharmacy, is not optimized as a result. Facilities utilizing bar coding equipment from source to final dose are left with a gap at the beginning of the process

12. Dispense Bill Of Lading Stage Ship Deliver Scan The Vial Select Orders, Generate And Print Documents Driver Delivers Product Select Items To Deliver And Mark Them Shipped BOL Scan The Case ID Packing Slip Scan The Rx Bar Code Sheet Scan The BOL and Package ID Dispense Rx Scan each Pig Scan Customer Luggage Tag To Confirm Pharmacy Processes

13. Net result… …critical opportunity for patient safety improvement is missed. The nuclear pharmacist is left without one more engineering control to reduce/eliminate errors.

14. Recently, another final rule was published in the Federal Register that is related to this issue

15. Prescription Drug Marketing Act of 1987 Address Drug Diversion Called “The Drug Diversion Bill” Two 2-year delays in implementation passed by congress in response to lobby Pedigree requirement delayed to present day Individual states implementing pedigree requirement (e.g. Florida)

16. Prescription Drug Marketing Act of 1987 FDA’s counterfeit drug initiative-today FR of 23 Feb 2004 published a delay of effective date for pedigree requirement Intent is to implement rule using “electronic pedigrees” for all legend drugs Deadline for implementation is 1 Jan 2007

17. Electronic Pedigree Pedigree: A statement, required by the PDMA, that includes the names and addresses of all parties to each prior transaction involving the drug. Electronic Pedigree Use of RFID (radio frequency identification device) Could contain more information than NDC number

18. RFID Ubiquitous (almost) Employee ID badges used for access Computer access (e.g. Xyloc) Mobil Speedpass PA and NJ turnpike EZPass “Pet Chips” used in companion animals

19. Bar Codes Vs. RFID Bar Code Patent issued in 1952 RFID Patent issued in 1973

20. Bar Codes Vs. RFID Bar Code (Patent issued in 1952) 1984, 15,000 suppliers used bar code technology 1987, 75,000 suppliers used bar code technology 1987: Wal-Mart required suppliers to use or lose their business

21. Bar Codes Vs. RFID RFID(Patent issued in 1973) Required for military suppliers 2005: Wal-Mart requiring 100 largest suppliers to use Soon to be used in.. Gillette razors (recently purchased 500 million) VISA Smart Cards Michelin tires (embedded) mfrs 800,000 tires/day Euro notes (embedded)

22. Bar Codes Vs. RFID Deadlines for RFID Wal-Mart: 2005 (screws begin to tighten on suppliers) FDA: 2007 (proposed) Result should be increased acceptance and awareness of RFID technology and adoption by manufacturers

23. Bar Codes Vs. RFID Incentives for electronic pedigree Drug counterfeiting Drug diversion Inventory control “smart” RFID versus “dumb” bar codes Devices can be written to, as well as read Bar codes have limits to info, while RFID may contain large amount of info

24. Wait until 2007 to include radiopharmaceuticals? Continue to hold patient safety as a top priority Approach radiopharmaceutical manufacturers to implement Request FDA to eliminate exemption Nuclear Pharmacy’s Role in the FDA Bar Code Rule