Regulatory Open Forum

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  • 1.  SNIs for Primary and Secondary Drug Packaging

    Posted 27-May-2016 12:26

    Dear all,

    I am reading the Guidance: Standards for Securing Drug Supply Chain - Standardized Numerical Identification for Prescription Drug Packages.

    It says, "For the purpose of this guidance, FDA considers the prescription drug package to be the smallest unit placed into interstate commerce by the manufacturer or the repackager that is intended by that manufacturer or repackager, as applicable, for individual sale to the pharmacy or other dispenser of the drug product".

    Can anyone shed some light on what FDA's practice is with regards to the SNI? Does it need to appear on both primary and secondary package labels, for example, a vial and its carton?  I've been looking at trade packages, and the SNI only seems to appear on the primary package label.

    Thanks,

    Heather

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    Heather Hammond
    Ridgewood NY
    United States
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  • 2.  RE: SNIs for Primary and Secondary Drug Packaging

    Posted 27-May-2016 12:32

    And I just came across a GTIN on a carton while perusing DailyMed.

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    Heather Hammond
    Ridgewood NY
    United States



  • 3.  RE: SNIs for Primary and Secondary Drug Packaging

    Posted 27-May-2016 12:55
    Heather, 

    sNDC for package-level SNI is used as a means of identifying prescription drug packages at the individual level. facilitating unique identification of individual product packages.  

    For your description, a single SNI should be on the primary package (carton) because you are not selling the vial only without the carton. 

    D