Who is Responsible?
There is now a clear understanding of the responsibility of product tracking and tracing in regards to third party logistics providers (3PL’s) and Pharmaceutical companies. President Obama recently signed into law the “Drug Quality and Security Act,” which replaces the “state-by-state approach for monitoring pharmaceutical shipments.” The law makes a clear depiction as to where the 3PL’s “place” is in the supply chain.
The law states that 3PL’s are custodians of the merchandize and not the owners. It is now the owners’ responsibility for product tracking and tracing, not the custodians, or 3PL’s. “It relieves 3PL warehouse owners and operators of the onerous paperwork burdens that come with being considered part of the chain of ownership.” This also means that the owners need to look internally at their compliance programs and ensure they are able to provide “detailed transaction information, history and statements, and keep that information for six years.”
For internal audits or trade compliance guidance, please contact email@example.com