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006_DirectorsChair.qxd 3/6/07 11:27 AM Page 6<br />

Director’s Chair<br />

How to Define Drug Safety<br />

Peter Mayberry<br />

Executive Director<br />

Healthcare Compliance<br />

<strong>Packaging</strong> Council<br />

The biggest bang for<br />

the buck in terms of<br />

improving drug safety<br />

would be to look<br />

at the way U.S.<br />

pharmaceutical<br />

manufacturers are<br />

allowed to package<br />

and distribute<br />

their products.<br />

As the new Democraticmajority<br />

Congress settles<br />

in and begins implementing<br />

its agenda for the next two<br />

years, one issue that has been<br />

getting tremendous attention on<br />

Capitol Hill is drug safety.<br />

Later this year, in fact, the<br />

Prescription Drug User Fee Act<br />

(PDUFA) is slated to expire. If not<br />

reauthorized, FDA will have little<br />

choice but to stop its participation<br />

in the development of new<br />

drug products — a highly unlikely<br />

scenario. And, as commonly<br />

happens when Congress handles<br />

“must-pass” legislation, it is very<br />

likely that PDUFA reauthorization<br />

will become a vehicle for a<br />

number of issues related to pharmaceuticals.<br />

Indeed, there is<br />

already talk on Capitol Hill of<br />

using the bill as a means of better<br />

monitoring drugs once they are<br />

on the market, and allowing drug<br />

reimportation so that seniors can<br />

have access to cheaper medicine.<br />

To date, however, the primary<br />

focus of drug safety discussion<br />

in the 110th Congress<br />

has centered on FDA, with virtually<br />

no apparent interest being<br />

paid to distribution issues. This<br />

is unfortunate, because, arguably,<br />

the biggest bang for the buck in<br />

terms of improving drug safety<br />

would be to look at the way<br />

pharmaceutical manufacturers<br />

are allowed to package and distribute<br />

their products in the<br />

<strong>Unit</strong>ed States.<br />

Simply stated, if manufacturers<br />

shipped more product in<br />

unit-dose formats with uniform<br />

consumer information, some of<br />

the benefits that would accrue<br />

include:<br />

• Fewer dispensing errors in the<br />

pharmacy.<br />

• Highly improved drug efficacy<br />

(i.e., better assurances that<br />

the drugs will actually work<br />

as intended).<br />

• Less opportunity to introduce<br />

counterfeit product and/or<br />

mix expired product with<br />

product that is still good.<br />

• Far greater opportunity for<br />

pharmacists to counsel<br />

consumers.<br />

• Guarantees that accurate and<br />

reliable consumer information<br />

is dispensed with Rx drugs.<br />

• Improved compliance with<br />

pharmaceutical regimens.<br />

The <strong>Unit</strong>ed States is somewhat<br />

unique in that pharmaceutical<br />

manufacturers are allowed<br />

to ship product in bulk containers<br />

with a single leaflet intended for<br />

physicians and pharmacists.<br />

Switching from the U.S. model to<br />

one that is used throughout much<br />

of the rest of the world — whereby<br />

the same drugs are shipped by<br />

the same manufacturers in unitdose<br />

formats with approved consumer<br />

information — is a timely<br />

initiative. It should be a much<br />

greater part of any Congressional<br />

consideration of a PDUFA<br />

reauthorization bill or any other<br />

initiative geared toward increasing<br />

drug safety for that matter.<br />

6 <strong>Unit</strong> <strong>Dose</strong> Alert • www.unitdose.org • March 2007

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