After Heparin: - The Pew Charitable Trusts

—Chapter 3—
HDMA)—reported to the FDA that up to 4 percent of the products handled by its members came from
sources other than manufacturers. 460 While it is only a small proportion of total sales, this represents a
substantial absolute volume. According to HDMA, to its knowledge, the practice of a large wholesaler
purchasing from secondary wholesalers no longer occurs. 461
3.2 Drug diversion and counterfeit drugs in
U.S. distribution
3.2.1 Diversion, counterfeiting and theft are ongoing problems in the
United States
The complex distribution system outlined above creates opportunities for stolen or counterfeit drugs to
enter legitimate channels of distribution. One frequently documented drug-diversion scheme is illicit
procurement of government-subsidized medicine for resale into the market. In 2008, there were two
federal convictions involving human growth hormone products that were purchased from Medicaid patients
on the streets of New York and resold into distribution with false documentation. 462 In 2010, three
men were indicted for allegedly illicitly purchasing prescription drugs—some directly from patients—
and selling them to pharmacies through a licensed wholesaler in Texas (see case study 6). 463 In order to
conceal a medicine’s original provenance, drug diverters commonly remove existing labels with various
organic solvents and replace them with counterfeit labels (see figure 15).
Figure 15
Lighter fluid and other solvents are used to remove
pharmacy labels prior to reintroduction of diverted
drugs into the wholesale distribution system. These were
discovered during a warranted search of an unlicensed
warehouse in Miami, Florida.
Source: Cesar Arias, RPh, Stone Cold Healthcare Consultants.
Image used with permission.
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Pew Health Group