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New Exemptions..DSCSA-October 2024
Hello all… As you may have already heard, the FDA has announced more exemptions for authorized trading partners. For this post I will...
jwgilbreath
Oct 10, 20245 min read
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DSCSA—Small Dispensers
Hello all, On June 12, 2024, the FDA announced DSCSA exemptions for certain types of dispensers (i.e., “small dispensers”) until November...
jwgilbreath
Jun 14, 20244 min read
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DSCSA Mid Point
Hello All! We are coming up to the midpoint of the FDAs stabilization period allowed for the industry to prepare for DSCSA compliance. ...
jwgilbreath
May 17, 20241 min read
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DSCSA—CDER NextGen Portal. Follow up
Hello all! So, as a follow up regarding the CDER NextGen Portal: As I stated in an earlier post, the portal is used as a communication...
jwgilbreath
Feb 29, 20241 min read
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Updates to Regulations Affected By Controlled Substance Act—Opioid Use Disorder (OUD)
Hello all! Shifting gears from DSCSA! So, the final rules have officially been implemented surrounding OUD treatment. For context...it...
jwgilbreath
Feb 11, 20242 min read
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FDA CDER NextGen Portal Update
Hello all! I have been communicating with one of the FDA help lines for made clarity related to the CDER NextGen portal. The...
jwgilbreath
Dec 5, 20231 min read
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FDA CDER Site for DSCSA
Hello all! So, FDA has added to their Centers for Drug Evaluation and Research (CDER) internet site (I.e., their "CDER NextGen" Portal). ...
jwgilbreath
Nov 29, 20232 min read
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DSCSA and Ambulance Replenishment
Hello all! So one thing that has been asked of me is the following: How does DSCSA affect ambulance restocking/replenishment? Many of...
jwgilbreath
Oct 31, 20233 min read
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DSCSA —where are you now?
Hello all!! With the FDA information about stabilization period for DSCSA in mind.... Are you pushing forward with your plans to be fully...
jwgilbreath
Sep 26, 20231 min read
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DSCSA and Reconciliation
Hello all! I know I have been bombarding you with info regarding DSCSA last few days! I attended a Seminar that was solely discussing...
jwgilbreath
Aug 31, 20232 min read
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DSCSA—November 27, 2024
Hello all! I'm attending the HDA traceability Seminar. Very interesting information. A couple FDA representatives are at the Seminar. ...
jwgilbreath
Aug 30, 20231 min read
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DEA Visits
Hello all! I can tell you that the DEA has been active in the last month or so. There have been 4 hospitals and 1 retail site that I...
jwgilbreath
Aug 23, 20233 min read
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DEA form 106 —timeliness changes
Hello all! Big news! It has finally happened! DEA has placed a time frame on when DEA form 106s must be sent in! Also, forms must be...
jwgilbreath
Jun 22, 20231 min read
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Theft and Loss—Controlled Substances
Hello all! It's been a while since I posted. I've been very busy at work plus traveling a lot. Let's focus on something more simple and...
jwgilbreath
Jun 10, 20236 min read
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PPPMag
Exciting news! PPPMag has stated they want to publish an article I wrote about regulatory readiness. Hopefully you will see it sometime...
jwgilbreath
Jun 1, 20231 min read
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DSCSA — Suspect and Illegitimate Products
Welcome back to the blog! Let's discuss one of the core reasons why DSCSA was formulated ...suspect and illegitimate products. FDA has...
jwgilbreath
May 27, 20233 min read
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Destruction of controlled substance documentation—- DEA form 41
Hello all! From time to time I've had questions regarding documentation of drugs that are destroyed by a registrant...ex. If you have a...
jwgilbreath
May 24, 20236 min read
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DSCSA—Path to November 27, 2023
Hello all! Previously, I gave an overview of DSCSA current state. Well changes are coming that will impact dispensers! Most of the...
jwgilbreath
May 20, 20234 min read
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Regulatory Body Visit (#2)
Hello All! Let's continue the discussion of how to be ready for a regulatory body visiting your sites. The regulatory body will expect...
jwgilbreath
May 17, 20233 min read
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Regulatory Body Visit (#1)
As many of you have experienced the slight twinge in your stomach when someone presents to the pharmacy and says..."I'm from the Board of...
jwgilbreath
May 13, 20232 min read
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