ABSTRACT
Title II of the Drug Quality and Security Act (DQSA) is designed to address the supply chain from manufacturer to customer or patient. This works well most of the time. In a perfect pharmaceutical supply chain world, there is no illegitimate product to quarantine, no damaged product, no recalled product, and no damaged cases in transit. However, this theoretical optimum scenario doesn’t exist. As in the Scottish prayer in the Cornish and West Country Litany (1926), “things that go bump in the night” do in fact happen.1 (The people who do bad things may not be “ goulies and ghosties and long-leggedy beasties,” as in the prayer and adopted by Dr. Seuss, among others, but they are for sure a different form of monster.) When things do occur out of the ordinary, these pharmaceutical drugs must go somewhere, because as we discussed earlier in the book, the physical space within a retail pharmacy store is quite small. Many people think that these drugs are sent back to the manufacturer. Sometimes this happens, but most of the time the drugs are sent to a pharmaceutical drug reverse logistics provider called a reverse distributor.
