In response to a May 28 hearing focused on revisions to Division 62 of the Oregon Board of Pharmacy’s policy on pharmaceuticals, IWLA submitted comments to clarify the unique role of a third-party warehouse logistics provider in the supply chain. The letter also addressed the inconsistencies between the proposed state policy and the Drug Supply Chain Security Act.
The letter makes the following recommendations:
Eliminate the requirement that a 3PL establish and maintain records of pedigrees, defined as “Transaction History,” “Transaction Information,” and “Transaction Statement,” on the grounds that this is preempted by federal legislation that recognizes the warehouse logistics organizations do not take ownership of products and therefore cannot be responsible for this information.
Suspend consideration of registration requirements for 3PLs to avoid needless confusion with federal licensing and to standardize requirements across all states.
Please read the letter. IWLA will continue to fight states that act against the system established by the federal government with no added benefit to the safety or security of the pharmaceutical supply chain. Stay tuned for more updates on this issue.