News and Events

Following discussions at a national level between the Department of Health, the Health Products Regulatory Authority (HPRA), the Pharmaceutical Society of Ireland (PSI), the HSE and Private Hospitals Association (PHA) stakeholder representatives and IMVO, it has been decided to adopt a pragmatic approach to the implementation of the Delegated Regulation (and the associated statutory instrument) after the go live date, to ensure the continuity of safe supply of medicines to patients while all parties gain a better understanding of the new system. This means that:

• All medicinal products released by MAHs for the Irish Market after Feb 9^th should bear the safety features as required i.e. a tamper proof seal and 2D barcode.
• During the initial period of operation, the system will be considered to be in ‘use and learn’ phase. Therefore wholesalers, pharmacies and hospitals should scan medicines bearing the safety features and if an alert or any other unexpected message is flagged, should continue to supply packs to patients in accordance with their existing procedures, unless they have overriding concerns that a falsified medicine is involved.
• All alerts generated by FMD system in pharmacies, wholesalers and hospitals, upon scanning a pack during this ‘use and learn’ phase will be forwarded by the system to the IMVO, the HPRA and the pharmaceutical companies so that they can be investigated and monitored.
• Notwithstanding the above, if a pharmacist or wholesaler has reason to believe that packaging has been interfered with, based on their examination of the anti-tampering device on the pack, they must report their concern to the HPRA (as a suspected quality defect via the usual reporting mechanisms) and not supply the pack.

National legislation including the provisions of Article 23 of the Delegated Regulation will be introduced, however, the offences provided for in the Regulations will not be commenced for a period of time to let the new system bed in.

During this period, the alerts generated will be analysed by the Department of Health, IMVO, HPRA, PSI, HSE and the private hospital pharmacies to determine why they are occurring and develop appropriate protocols for their resolution. Manufacturers (and marketing authorisation holders (MAHs) will also be involved in the investigation of alerts generated against their products.  The system will be reviewed again in three months’ time. This approach will ensure that medicines continue to be provided to patients without delay and also ensure that all stakeholders, manufacturers, wholesalers, pharmacists and other healthcare professionals work to build confidence in operating the new safety system.

Formal notification of this agreed national approach has been issued today to pharmacists, wholesalers, MAHs and manufacturers by the PSI and the HPRA. IMVO is very appreciative of the careful consideration given to the matter by the authorities in Ireland and we will continue to work closely with them over the coming months to maximise the learnings about the system during this ‘use and learn’ period.