THE NATIONAL COALITION OF PHARMACEUTICAL DISTRIBUTORS (NCPD)
POSITION ON SB 1307

The National Coalition of Pharmaceutical Distributors (NCPD) is a national association representing the interests of independent/specialty pharmaceutical distributors.  These particular distributors are small businesses that typically supply the hard-to-serve, or urgent-need retail end users (e.g., the small rural pharmacies, health clinics and doctor offices) that often cannot afford to purchase pharmaceutical products in bulk volume from the larger distributors.

Regarding current efforts to amend California’s existing pharmaceutical pedigree/serialization law, NCPD has adopted the following position[s]:

• NCPD has consistently supported California’s existing pedigree law, as it exemplifies the most comprehensive and responsible method for ensuring pharmaceutical supply chain integrity in the nation – i.e., serialization of ALL dangerous pharmaceutical products from inception to end-use. NCPD recognizes that California’s pedigree law represents the best possible scenario for ensuring consumer and patient safety. 
• At the same time, NCPD also understood that the January 01, 2009 implementation deadline for this law was going to be difficult at best to impose. Technology availability, burdensome costs and compatibility uncertainties were all issues that made this daunting challenge almost impossible for the Board of Pharmacy to enforce.
• To provide the Board of Pharmacy with the statutory flexibility it needed to implement California’s pedigree law in a manner consistent with the industry’s ability to comply, SB 1307, was introduced with comprehensive input from the stakeholders across the pharmaceutical industry.  NCPD supports SB 1307, as amended, as it maintains the fundamental tenets of California’s pedigree law, while also providing the stakeholders within this industry the ability to comply with its mandates in a feasible manner.

Recognizing that counterfeiting, adulteration and diversion of pharmaceutical products has occurred at virtually every link of the pharmaceutical supply chain, the industry has a moral obligation and responsibility to adopt standards and practices that will ensure the greatest degree of certainty associated with the safety of prescription products being delivered to our citizens. 

As identified by the U.S. Food and Drug Administration (FDA), serialization and the tracking of all dangerous pharmaceutical products is the most optimal way of ensuring this degree of certainty and safety. Each of the stakeholder groups within the supply chain – manufacturers, distributors and dispensers alike – have reaped the rewards associated with the sale of these products.  As such, we all share an individual as well as collective obligation to ensure these same products are provided in the safest manner possible. Consumer protection and patient safety must be the guiding principle when contemplating any revision to California’s “Gold Standard” pedigree law.

The National Coalition of Pharmaceutical Distributors (NCPD) Position on SB1307
in PDF Format