THE CORONAVIRUS PANDEMIC AND THE COUNTERFEIT CHLOROQUINE SPECTER

Anti-malarials are some of the most frequently counterfeited drugs on the planet. Yesterday, chloroquine was a relatively-obscure anti-malarial, at least within our own borders. Today, it’s front and center in the fight against coronavirus (COVID-19).  This overnight...

ROGUE MEDICAL SPAS CONTINUE TO THREATEN VULNERABLE PATIENTS

Allegations involving foreign-sourced Botox and unapproved Juvederm have a Tulsa, OK spa owner in serious hot water.  According to a recent U.S. Department of Justice (DOJ) press release, Elisa Kaye Sanders was indicted on multiple mail fraud and wire fraud charges...

A DSCSA ENFORCEMENT STRATEGY PEP TALK FOR FDA

According to the Drug Supply Chain Security Act (DSCSA), prescription drug wholesale distributors are not Authorized unless they comply with federal licensing and reporting requirements. Failure to comply with each of these requirements is prohibited by FDA and can...

FDA LEADERSHIP IS THE KEY TO STOPPING SHORTAGE DRUG DIVERSION SCHEMES

Independent pharmacies engage in diversion when shortage drugs purchased under false pretenses are re-distributed back into the supply chain instead of dispensed to patients as intended. This type of activity is often accompanied by fraud, misrepresentation, and...

FEDS BUST ANOTHER MASSIVE PRESCRIPTION DRUG DIVERSION SCHEME

Once again, the feds have unfurled a massive prescription drug diversion case highlighting the indispensable role of bogus transaction histories (or pedigrees prior to 2013) in perpetrating these all-too-frequent criminal schemes.  A similar case was announced just...

PERSPECTIVES ON FDA’S MOST RECENT DSCSA GUIDANCE

FDA just issued another DSCSA compliance extension. This time it was offered to wholesale distributors who were facing a November 27th deadline for verifying saleable returns.  They now have an extra year to establish compliance with this provision of the law.  I find...

FBI DRUG DIVERSION CASE HIGHLIGHTS FATAL DSCSA FLAW

Those who claim our nation’s drug distribution system is safer under the Drug Supply Chain Security Act (DSCSA) may have to change their tune.  A recent FBI prescription drug diversion case suggests it’s just as vulnerable today as it was for 25 years...

FDA’S OCTOBER 2018 DRAFT GUIDANCE ON DSCSA VERIFICATION SYSTEMS IS MIA

Where have you gone, draft DSCSA guidance? FDA’s position on DSCSA verification systems was announced last October but went MIA from the agency’s dedicated web page a few months ago.  A web site overhaul in April is the likely culprit, but the powerful influence of...

FDA AND CBP TO INCREASE JOINT INTERNATIONAL MAIL FACILITY EFFORTS

FDA and CBP are teaming up to increase inspection and detention efforts at our nation’s International Mail Facilities (IMFs) and Ports of Entry.  In its press release announcing the collaboration, FDA stated that “Thousands of illicit and dangerous products come from...

FDA’S LONG OVERDUE NATIONAL WHOLESALE DISTRIBUTOR LICENSING STANDARDS

FDA’s proposed national wholesale distributor licensing standards are almost three-and-a-half-years overdue and it’s becoming apparent the agency has no intention of issuing them any time soon.  According to CDER’s 2019 guidance agenda, these standards are not on the...

THE OPIOID ABUSE EPIDEMIC AND FDA’S LAW ENFORCEMENT MISSION CREEP

FDA’s wide-ranging public health and safety responsibilities make it an unlikely candidate for mission creep.  Nonetheless, that specter may very well apply to the agency’s ongoing International Mail Facility (IMF) surge involving its small but invaluable cadre of...

FDA LEADERSHIP IS THE ANTIDOTE TO SHORTAGE DRUG DIVERSION SCHEMES

It’s been more than six years since Congress first exposed the despicable gray market shortage drug distribution practices of certain pharmacies and distributors.  In its July 2012 report, Congress concluded, “gray market companies that operate outside of authorized...

A POTENTIAL SHIFT IN FDA’S APPROACH TO TAINTED DIETARY SUPPLEMENTS

FDA’s latest tainted dietary supplement alert seems to signal a shift in the agency’s approach to this problem. FDA alerts on these products have not typically referenced OCI investigations in this fashion. Perhaps the agency is beginning to grasp the need...

FDA ALERTS THE PUBLIC TO WESTMINSTER PHARMACEUTICALS, LLC DRUG RECALL

FDA recently alerted the public that Westminster Pharmaceuticals, LLC was recalling Levothyroxine and Liothyronine products in various strengths that were manufactured using active pharmaceutical ingredients from a deficient Chinese manufacturer.  According to the...

SENTENCING ANNOUNCED IN ILLEGAL FOREIGN-SOURCED DRUG CAPER

Three Canadians and their company, Quantum Solutions, SRL, have been sentenced in a pharma supply chain caper involving the sale of illegal foreign-sourced prescription drugs to three retail pharmacies in western Pennsylvania.  The individuals in this case were...

STOLEN OCTAGAM COULD SIGNAL A NEW TREND FOR PHARMA CARGO THIEVES

Pharmaceutical cargo thefts have become a relatively infrequent occurrence, but 10 years ago it was a much different story. The problem seemed to be spiraling out of control.  Thankfully, the number of such incidents has slowed to a trickle over recent years. The...