FMD error and alert messages guidance notes and scanning and error messages flowchart
Falsified Medicines Directive
FMD error and alert messages guidance notes
To accompany “FMD – scanning and alert messages” chart
These guidance notes accompany the “FMD – error and alert messages (for pharmacy and wholesale)” chart (v5a) and are based on a workshop held at Walgreens Boots Alliance, Weybridge, on 5th September and subsequent discussions with relevant experts. The chart looks specifically at handling of alert messages and is intended to inform wider discussions on implementing FMD, including amending Standard Operating Procedures. It will link with other industry guidance on the assessment of suspect packs once an alert has been raised and professional guidance on ethical decision making related to FMD.
NOTE: This is a working document and will be updated in light of feedback and experience. It represents current thinking on these issues at this point. Comments and feedback are encouraged.
NOTE: Anti-tampering devices All packs bearing safety features will also require their anti-tampering devices (ATDs) to be visually examined before decommissioning. The normal (positive) response assumes that each pack has passed. If operators suspect that packs have been tampered with then they are required to report this to the National Competent Authority in the same way as for a pack that fails a verification or decommissioning scan. See section on “Handling packs that generate alerts”.
TERMINOLOGY: An alert is a message generated by a response from the NMVS following a scan of a unique identifier. A warning is a message generated by a local system. There are a large number of potential alerts that can be generated by NMVS/EMVS, not all of which are passed to end users. Some are condition-specific (eg, unable to reverse decommissioning after 10 days). The chart and this guidance captures the main categories of alert (grouped together) and the actions required by end users.
Positive scan (Green)
It is assumed that the vast majority of all stock being verified and/or decommissioned will produce a positive response from the NMVS. The aim of the process should be to minimise the response or action to be taken by end user operators. There should be a positive confirmation that a scan has taken place (single “beep”) in line with other automated processes (eg, supermarket self-checkouts).
Local systems should display a list of all products that have been scanned along with the product details (name, strength, form, etc) derived from the full data product master data, as well as batch, expiry and serial numbers. This should be enabled as the default setting by the NMVO. The most recently scanned product should be at the top of the list displayed by the local system to the end user to enable checking in case an operator is distracted or has to break off from scanning. Preferably there should be at least one screen or display per operator.
The status of the product (and the confirmation of any change of status at decommissioning) should be indicated in the list (using symbols [P] and colours that are unambiguous) as and when the response is received from the NMVS. This information should be stored in local data audit trails.
When scanning or verifying large numbers of packs, especially in wholesale settings, local systems may also be pre-configured to request or prompt the number of packs to be scanned and indicate when this has been reached.
Not FMD or fails to scan (Amber)
A wide range of products will not require verification or authentication under FMD at any time. This includes non-prescription products, medical devices, non-medicines, specials and other out-of-scope items, as well as POM stock produced and released before 9th February 2019. Local processes should make it clear that these products can still be dispensed and do not have to be returned to wholesalers or suppliers (unless there is another kind of problem).
Ideally, local systems should be able to distinguish between “right” (FMD) and “wrong” (not FMD) stock by drawing on NMVS master data loaded on to local systems. This would allow a process of “scan everything, system sorts it out”. Whenever possible there should be a positive audible confirmation that a scan has taken place.
Where this is not technical possible then end user operators should have access to visual training guides that distinguish between “right” and “wrong” products in order to minimise scanning errors.
Excessive “amber warning” pop-up boxes saying that certain packs do not need to be verified should be avoided in case they cause operator “alert fatigue”.
Some products may fail to scan because of damage to the 2D data matrix. SOPs should indicate that a lack of audible confirmation should prompt the process for manual data entry. In general, damaged packs should be a rare occurrence. Where a product has multiple packs that fail to scan, this should be reported to the wholesaler, supplier or NCA as a defective medicine using existing procedures.
NOTE: See “data error” red alert for packs that do scan but contain incorrect data.
Warnings generated by local systems (Red)
These warnings can be generated in response to data held within a unique identifier 2D data matrix (eg, expiry data) or in response to end user operator actions (eg, double scans of same pack). They do not require a live connection to the NMVS at the time of scanning to generate a warning, however the NMVS will also generate an alert message, when or if connected.
Out of date As a minimum, local systems should warn operators about products that have passed their expiry date by cross-referencing with calendar date. It would be preferable and a major benefit for systems to also warn about products that are close to their expiry date (eg, less than three or six months or another user-defined period).
Double scan A double scan occurs when the same pack is scanned more than once at the same location in quick succession. Agreement should be reached with system suppliers and the NMVO on how many repeated scans, and how frequently, is an acceptable limit.
Local systems should capture and warn operators about this, requiring an acknowledgement. Local limits should be agreed after which operators’ local management is alerted (to prompt training or process improvement).
If a national limit is to be set on the number of double scans permitted before an alert is raised with the NMVO (and/or NCA) then this should be set at a very high level for the initial phase following the start of FMD authentication. This will avoid swamping the system with unnecessary alerts. The permitted level could be reduced in due course once experience is gained across the supply chain.
Alerts generated by NMVS (Red)
These alerts are generated when UI data from packs is compared with the data and status information held on NMVS. They require a live connection to the NMVS.
Recalled pack The status of the pack in the NMVS is set to “recalled” or “withdrawn”. This may be at a pack or batch level. In these circumstances end users should follow existing procedures for the return or disposal of affected packs, including processes for reordering and reimbursement.
Status error The status of the pack in the NMVS is set in such a way that the product cannot be decommissioned and supplied. This includes packs marked as “stolen”, “sample (not for commercial sale)”, “free sample”, “exported from EU”, “for destruction” or “checked-out” (part of the parallel import process). These indicate packs that should not be in circulation in the supply chain. See below for guidance on handling these packs.
Data error The data on the pack does not match corresponding data held in the NMVS or the data on the pack has gaps or missing fields (ie, missing one or more of serial, product, batch, expiry or national reimbursement number, where relevant). This also includes packs where data is encoded using formats or characters that are not permitted by EMVO or other relevant authorities (eg, GS1). Manufacturers are expected to scan all 2D data matrix codes as they are produced to avoid such errors. Improper coding may indicate falsified packs. See below for guidance on handling these packs.
Data errors may also occur if packs are released to market before data uploads to EMVS are successfully completed. This should be avoided and, where this is confirmed as an issue, such packs should be reported as defective medicines
Already used The UI data is correct but the status indicates that it has already been decommissioned at another location, either in the same country or in another country. This could indicate duplication of UIs and potential falsification. This is different to the “double scan” error which only occurs when packs are re-scanned at the same location. See below for guidance on handling these packs.
Locked packs Packs can have their status set to “locked” on a temporary basis. Only manufacturers and wholesalers can do (and undo) this. There is no 10-day rule on reversing locked status. However, since dispensing entities cannot undo locked packs they would be unable to dispense them. For this reason, packs should only be locked electronically after they have been physically locked up (quarantined). Those doing the locking should have “pack in hand” at the time. It should never be used for packs that are in transit or which have been widely distributed. If packs are not in the possession of the person wishing to lock them then the recall route should be used instead.
Handling of packs that generate alerts (Red)
Packs marked “recalled” or “withdrawn” should be handled in the normal way for return or disposal, including reimbursement.
Packs with “status error”, “data error” or “already used” alerts need to be quarantined, investigated, reported and, if required, handed over to manufacturers or NCA inspectors for examination.
Quarantine Suspect packs should be physically quarantined away from normal stocks. Where possible and practicable, suspect packs should be placed in separate plastic bags and labelled with relevant details, including the alert ID number raised by the NMVS.
Investigation An internal investigation should be conducted by a suitable person within the organisation, such as a Qualified Person, Responsible Person (wholesale) or Responsible Pharmacist or Pharmacy Manager (community pharmacy) to rule out any technical or procedural issues, including double scanning. Senior managers, such as Chief Pharmacists, Superintendent Pharmacists, Operations Directors, or GP practice partners, should be informed of the outcome as appropriate.
External reporting Although the NMVS will generate a report that can be accessed by the NCA, wholesalers and dispensing entities have a duty placed on them by the Delegated Regulation (2016/161, Articles 18 & 30) to report suspected falsification incidents. This should be done through a suitable portal provided by the NCA. In the UK, this should be a specific “Report FMD alert” page as part of the existing Yellow Card scheme. The NCA should make available and publicise a hotline line for urgent incident reporting.
Analysing packs When requested by Marketing Authorisation Holders (MAHs) and/or NCA inspectors, suspect packs should be supplied to them for further analysis. It is up to MAHs to make suitable arrangements with the person holding the pack for its return. Persons returning packs should receive appropriate reimbursement for the cost of the pack and any relevant out-of-pocket expenses incurred from the MAH (or NCA, if they have taken possession of the pack). The NCA should indicate to the person supplying the suspect pack when or if they might receive any feedback on the investigation, whether directly or through a more general update.
NOTE: Work on a pathway for MAHs for handling alerts and analysing suspected falsification incidents is being undertaken by the European Federation of Pharmaceutical Industry Associations (EFPIA) and Medicines for Europe (MfE).
Guidance notes prepared by:
Jonathan Buisson MRPharmS MFRPSII
International Pharmacy & Policy Manager
Walgreens Boots Alliance
23rd October 2018
Naughton B, Roberts L, Dopson S, Chapman S, Brindley D. Effectiveness of medicines authentication technology to detect counterfeit, recalled and expired medicines: a two-stage quantitative secondary care study. BMJ Open. 2016 Dec 1;6(12):e013837.
Naughton B, Roberts L, Dopson S, Brindley D, Chapman S. Medicine authentication technology as a counterfeit medicine-detection tool: a Delphi method study to establish expert opinion on manual medicine authentication technology in secondary care. BMJ Open. 2017 May 6;7(5):e013838.
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