Committed to Safe Online Pharmacy...concerns of counterfeit drugs affecting the US drug supply. FDA...
Transcript of Committed to Safe Online Pharmacy...concerns of counterfeit drugs affecting the US drug supply. FDA...
NABP®
Committed to Safe Online Pharmacy
NABP®
What Is .pharmacy?
• Pharmacy’s
new Internet
namespace
NABP®
What Is NABP?
• The National Association of Boards of
Pharmacy® (NABP®) is the impartial professional
organization that supports its member boards of
pharmacy in protecting the public health.
• Member boards include all 50 United States, the
District of Columbia, Guam, Puerto Rico, the
Virgin Islands, eight Canadian provinces,
Australia, and New Zealand.
NABP®
What Is .pharmacy?
• In 2012, NABP, with the support of a global coalition of
stakeholders, applied to the Internet Corporation for Assigned
Names and Numbers (ICANN) to own and operate a new generic
Top-Level Domain (gTLD) – .pharmacy.
• A gTLD is the text “to the right of the dot” in a domain name.
• Words created from letters found in the Latin and Spanish
alphabets can be used as .pharmacy domain names.
• Potential .pharmacy domain names include:
– Boots.pharmacy
– lamejorfarmacia.pharmacy
– Pfizer.pharmacy
NABP®
What Is .pharmacy?
• Ultimate goal is for
patients worldwide to:
– distinguish a .pharmacy website
as legitimate; and
– know that the medications, information, and
services they obtain from that site are authentic
and safe.
NABP®
Why .pharmacy?
• Addresses global concern
about illegal online drug
sellers distributing products
that endanger patient health
NABP®
Why .pharmacy?
• Supports regulatory efforts of
individual countries, states,
and territories
NABP®
What are the Global Concerns?
• NABP research indicates that
most websites selling medicine
operate illegally and endanger
patient health.
• NABP has reviewed nearly
11,0000 sites and has found
over 10,300 (97%) to be in
conflict with US federal
and state pharmacy laws.
NABP®
What are the Global Concerns?
• Multiple sites offer to sell foreign or non-Food and
Drug Administration (FDA)-approved drugs, many of
which are thought to be counterfeit.
‒ Online sales of unregulated and counterfeit drugs are
estimated at $75 billion per year.
‒ According to World Health Organization, in over 50% of
cases, drugs purchased over the Internet from illegal sites
that conceal their physical address have been found to be
counterfeit.
NABP®
Counterfeiting Cases
• The number of US FDA counterfeiting investigations has increased dramatically over the past several years. In 2000, the number of cases initiated was six, while in 2004, 58 cases were opened. In addition, the United Kingdom saw a 270% increase in counterfeiting incidents between 2004 and 2005.
• In June 2005, counterfeit Norvasc® was found to have been dispensed from a pharmacy in Canada. Eleven deaths were investigated for a possible link to the counterfeit product.
NABP®
Counterfeiting Cases
• Counterfeit Lipitor® was found in the UK in 2005,
resulting in a nationwide recall of 120,000
packages. An analysis revealed that 60% of the
recalled product was counterfeit.
• In an earlier Lipitor counterfeiting incident, 18
million repackaged tablets, a mix of counterfeit
tablets and authentic tablets intended for non-
US markets, were recalled in the largest recall of
a prescription medicine in the US.
NABP®
More Counterfeiting Concerns
• In 2011, more than 50,000 packages shipped from rogue Internet drug sites were seized and found to contain more than 2.4 million illicit and counterfeit dosage units.
• FDA has found – Counterfeit HIV/AIDS drugs that contained nonsterile
tap water instead of an active ingredient,
– Fake schizophrenia medication containing aspirin, and
– Misbranded cough suppressant that caused the death of five consumers.
NABP®
Additional Concerns
• Illegal sale of prescription drugs, including
controlled substances, without a prescription
– One in six Americans has purchased medication
via the Internet without a valid prescription.
NABP®
Why Is This a Global Public Health Issue?
• Illegal prescription drug sales and
counterfeit medicines threaten patient
safety worldwide.
– Diseases needlessly left untreated
– Illness and death due to toxic substances
– Prescription drug abuse on the rise
NABP®
Additional Concerns
• Pharmacy spam constituted 31% of all spam
during 4Q11.
– Responsible for computer viruses and malware
– Ties to international organized crime
NABP®
Earlier Initiatives by NABP
• Verified Internet Pharmacy Practice Sites® (VIPPS®) program
– Includes policy and procedure evaluation, website review, license verification, and on-site visit
– Advantages
• Very thorough evaluation – high confidence for consumers
– Disadvantages
• VIPPS seal has been “hijacked” and posted on rogue websites.
• Applicable only to pharmacy applicants
• Price may be out of reach for smaller practices.
• Process may be lengthy.
• US and Canadian applicants only
NABP®
Earlier Initiatives by NABP
• NABP e-Advertiser ApprovalCM Program
– Includes website review and license verification
– Advantages
• Shorter processing time and lower cost than VIPPS
• Applicable to pharmacies with a limited online presence and
non-pharmacy applicants
– Disadvantages
• E-Advertiser seal may be “hijacked”
• US and Canadian applicants only
NABP®
Goals of the .Pharmacy gLTD Program
• Restrict use of .pharmacy domain names to legitimate website
operators that meet universal Internet pharmacy practice
standards.
– Registrants must demonstrate adherence to all applicable laws
where they are located and where their patients reside.
– Available to pharmaceutical manufacturers, pharmacy benefit
management companies, schools and colleges of pharmacy,
wholesale drug distributors, drug information sites, and more
– All current approved VIPPS and e-Advertisers will be offered
.pharmacy without having to undergo additional evaluation.
• Keep .pharmacy out of the hands of a third party that may
allow illegal and/or counterfeit activity within the gTLD
NABP®
How Will .Pharmacy Attain These Goals?
• Evaluate domestic AND international
applicants
– International partnerships worldwide to assist
with screening and monitoring of all .pharmacy
domain name registrants for adherence with
standards
• Raise consumer awareness and build trust in
the .pharmacy gTLD
NABP®
Screening and Monitoring of Applicants
• All applicants vetted prior to registration
– Evaluation for compliance with program
standards and with regulatory standards in home
jurisdiction and jurisdiction of patients
• Necessary jurisdictional pharmacy and practitioner
licensure
• Only valid prescriptions filled
• Patient information protected
– Disciplinary history evaluated
NABP®
Ongoing Compliance Monitoring
• Approved registrants of .pharmacy domain
names will be monitored for continued
compliance with standards.
• Domain names within .pharmacy will be
subject to suspension or revocation upon the
violation of the terms and conditions set forth in
the registration agreements.
NABP®
Support for .pharmacy Is Global
• Leaders – Contributed $100,000 or more – Pfizer, Inc
– Eli Lilly and Company
– Merck & Co, Inc
• Advocates – Contributed $25,000 or more – Gilead Sciences
– Janssen Therapeutics
NABP®
Support for .pharmacy Is Global
Endorsers – Submitted a letter of support to ICANN or
otherwise publicly expressed support – Amgen, Inc, Alliance for Safe Online Pharmacies (ASOP),
Boehringer Ingelheim, British Brands Group,
Drugsdepot.com, DrugSource, Inc, EnforceTheAct.org,
European Alliance for Access to Safe Medicines (EAASM),
Indiana Board of Pharmacy, International Pharmaceutical
Federation (FIP), Ipsen Pharma, LegitScript, National
Association of Pharmacy Regulatory Authorities (NAPRA),
North Dakota State Board of Pharmacy, Novo Nordisk, Inc,
Rx Direct, Inc, Sanofi
NABP®
Support for .pharmacy Is Global
• The Supporter Advisory Committee provides expertise and strategic input to the Executive Board for establishing core standards of operation that are universal to legitimate pharmacy practice and that will be required of all .pharmacy domain name registrants.
• The Supporter Advisory Committee includes: – ASOP, California State Board of Pharmacy, Eli Lilly and
Company, EAASM, FairWinds Partners, FIP, Indiana Board of Pharmacy, INTERPOL, LegitScript, Merck & Co, Inc, NAPRA, Neustar, North Dakota State Board of Pharmacy, Pfizer
NABP®
.pharmacy Product Model
• Online and brick-and-mortar pharmacies will likely route the .pharmacy domain name to their current sites in the .com or .net TLD.
• Geographic names – we hope to use geographic names to identify legitimate pharmacies operating legitimately in the geographic location. – May be limited – permission required from country
authorities
– Germany.pharmacy, france.pharmacy, spain.pharmacy, us.pharmacy
NABP®
Consumer Education
• Fundamental goal is to educate consumers to recognize
.pharmacy as the valid designation for a legitimate
pharmacy or pharmacy-related entity.
• “Look to the right of the dot”
• Increase awareness of rogue online drug sellers
masquerading as pharmacies
– Dangers of counterfeit drugs and buying prescription drugs
without a prescription
• As consumer recognition increases, more businesses
will be willing to undertake the application process.
NABP®
What Has Been Accomplished So Far?
• February 2013 – .Pharmacy gTLD Advisory
Committee convened
• May 2013 – .pharmacy application passed
ICANN’s initial evaluation
• July 2013 – .pharmacy gTLD governance
document finalized
• June 2014 – contract with ICANN finalized
• Late 2014 – anticipated launch
NABP®
Recent Challenges
• Name collision “issues” will delay launch of some domain names. – Name collision refers to the confusion that could
occur when a new gTLD string exactly matches an existing string used on an internal network. As new gTLDs go live, they can potentially “collide” with existing names.
• Two-letter country codes cannot be used without permission of each country’s ICANN Government Advisory Committee representative.
NABP®
Recent Challenges
• Rogue drug sellers disguised as legitimate
pharmacies have been vocal in their opposition
to .pharmacy.
– Spreading misinformation and lies about the
program and NABP
• Accusations of payoffs to NABP by pharmaceutical
manufacturers
– PharmacyChecker
– Canadian International Pharmacy Association
NABP®
Next Steps
• Develop international partnerships!
• Finalize and execute all necessary contracts
• Finalize domain registration polices and
technical operations
• Launch consumer education campaign
NABP®
Conclusion
• Success will not be measured by the number
of domain names registered.
• Success will be measured by the level of
recognition and trust placed in the .pharmacy
domain.
NABP®
VAWD
• Verified-Accredited Wholesale Distributors® (VAWD®)
• VAWD was launched in 2005 and was developed due to
concerns of counterfeit drugs affecting the US drug
supply. FDA supported the development of the program.
• Wholesale distributors of prescription drugs and devices
that are located in the US are eligible to apply for VAWD.
NABP®
VAWD
• In 2013, NABP revised the VAWD criteria.
– Virtual manufacturers and virtual wholesale
distributors could qualify for VAWD accreditation.
– Responsible distribution practices are mandated.
– Diverted drugs are prevented from entering into the
supply chain.
NABP®
VAWD
• Complex global supply chain for prescription
drugs
– 80% of Active Ingredients (powder) for prescription
drugs from overseas
– 40% of Finished Dosage Forms (capsules, tablets,
liquids) from overseas
• Accreditation programs track drugs from start
(manufacturer) to finish (patient or destruction of
non-dispensed expired drugs).
NABP®
VAWD
• Determine lawful sources to ensure drugs are
safe and effective
• Examine security, storage, shipping of drugs
– Narrow temperature ranges for most drugs (68o to 77o
F)
– Backup power for systems
– Shipping packaging maintains temperature
Monitor and Record Temperature
Backup Power for
Security and AC Systems
Shipping
NABP®
VAWD
• 21 states recognize VAWD in some manner.
• There are currently over 540 VAWD-accredited
wholesalers.
NABP®
Questions?
Carmen A. Catizone
Executive Director/Secretary
National Association of Boards of Pharmacy
1600 Feehanville Drive
Mount Prospect, IL 60056