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Executive Summary

NACDS OPPOSES UNIT-OF-USE PACKAGING in a revised position statement approved by the Natl. Assn. of Chain Drug Stores (NACDS) Board of Directors at its recent annual meeting in Hawaii. "Government mandated or industry wide adoption of unit-of-use packaging for pharmaceutical products" would produce increased drug costs not "commensurate [with] health benefits to the consumer, including increased safety and integrity of the drug product," maintains the new policy. NACDS also pointed prescribing inconvenience as a second reason for opposing unit-of-use packaging: "Furthermore, unit-of-use packaging would unnecessarily restrict the physician's flexibility in tailoring and prescribing the optimal course of therapy for the patient." The revised statement was drafted in response to NACDS' view of PMA's willingness to reconsider unit-of-use packaging. "In view of favorable recommendations made last December to the House Subcommittee on Oversight and Investigations by the Pharmaceutical Manufacturers Association (PMA) that the Congress should institute unit-of-use packaging as a solution for minimizing drug diversion problems, our Board of Directors felt a need to clarify for interested parties the Association's position on this issue," NACDS President Robert Bolger asserted, according to a May 20 release. PMA suggested during the December hearings before Rep. Dingell's (D-Mich) subcmte. that unit-of-use packaging could be "a potential solution to a serious problem" ("The Pink Sheet" Dec. 9, p. 6). PMA announced at that time that the board planned to assess the desirability of "manufacturer-dispensed packaging" as a measure against drug diversion. The PMA board has studied the issue but has not reached a decision regarding a concerted association action to promote unit-of-use packaging. It its April drug diversion report, the House Oversight and Investigations Subcmte. recommended that manufacturers switch to unit-of-use packaging. "If manufacturers do not voluntarily move to a unit-of-use system, the Congress should consider imposing such a system," stated the report. Packaging changes would increase control over the wholesale market and curb sample abuse, maintained the subcommittee. NACDS' new statement departs from its previously declared position on unit-of-use packaging by rejecting outright an imposed system. The former policy "encourage[d] the industry development (rather than government mandated) of unit-of-use packaging for pharmaceutical products when such packaging is appropriate for proper drug therapy." At the December diversion hearings, NACDS voiced objections, such as costliness of converting to the system, but took "no position." Other pharmacy groups continue to hold positions they expressed to the subcommittee during the December hearings. The Natl. Assn. of Retail Druggists' (NARD) policy is similar to NACDS' new statement maintaining that unit-of-use packaging would increase Rx drug costs, interfere with physician prescribing practices and do little to prevent diversion. In a March-adopted policy statement, the Natl. Whsle. Druggists Assn. (NWDA) reiterated its December testimony that "inadequate information is available concerning additional storage space requirements, increased packaging costs and handling costs for unit-of-use packaging." NWDA believes that "at this stage of development, federally-mandated specifications are premature." The American Society of Hospital Pharmacists (ASHP) Exec VP Joseph Oddis testified at the December hearing that "the utility of treatment-size packages should be reassessed, and probably voluntarily established as a standard packaging mechanism." ASHP practice standards guidelines support unit-of-use packaging as a safer and more economical method for distributing medication in a hospital setting. Among advantages listed by ASHP are "improved overall drug control and drug use monitoring," "reduction in the size of drug inventory in patient care areas," and "greater adaptability to computerized and automated procedures."

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