NBC News reported last Friday that the FAA approved the first delivery of drugs via a drone. The drone drop was made to a health clinic in rural southwest Virginia. A NASA plane delivered the medicine to a Wise County regional airport and then the drone took 24 packages the rest of the way.
The article did not go into whether NASA or the drone company, Flirtey, was acting as a wholesaler or a 3PL. Nor did it go into the relationship between the supplying pharmacy and the health clinic, but, this underlines how quickly the drug supply chain can change based on technology development and patient need.
The entire transaction may not fall under DSCSA law based on the relationship between the supplying pharmacy and the health clinic (was there a change of ownership?). The scenario here is additionally interesting in that it includes a hand off between two 3PLs in the supply chain. As we know, the DSCSA law only requires 3PLs to collect DSCSA data (Transaction Statement, Transaction Information and Transaction History, or TS, TI, TH, respectively). If in this case, the pharmacy to clinic transfer was a transfer of ownership, then the pharmacy would be responsible for passing DSCSA data to the clinic and making it available to the first 3PL (NASA?), but, who would be responsible for making the DSCSA data available to Flirtey?
Also, it would seem that both NASA and Flirtey may need to register with the FDA as 3PLs and acquire the appropriate licensing.
Now, this is all a bit of fun and games on my part, but it does underline the need for flexible solutions as the convergence of physical and information technologies continue to impact our understanding of supply chains.
Which brings me to a few last thoughts, as the drone dropped the supplies in the middle of a field, who's Global Location Number (GLN) was used to identify that location? And, was there another 3PL involved to move the product from the field to the clinic?