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Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved www.excellishealth.com Serialisation From Challenge to Success Ian Haynes [email protected]

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  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved www.excellishealth.com

    SerialisationFrom Challenge to Success Ian Haynes

    [email protected]

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 2

    Ian Haynes is an engineer with a proven record of innovation. Ian has a strong record of

    working collaboratively within complex organisations, offering strategic insight and analysis leading to creative and innovative solutions.

    Ian has an extensive background in the pharmaceutical and fine chemical sectors, including technology road-mapping, new product design & introduction, product security, coding & serialisation and engineering projects.

    Ian Haynes

    Ian was previously Associate Engineering Director in the Global Engineering Technology groupat AstraZeneca Pharmaceuticals where, alongside other activities, from 2006 he played a key role in AZ’s Pack Coding and Security Features programme. As a result of this work, AstraZeneca achieved a leading position with respect to serialisation and continues to play a key role in this field today.

    Since 2012 Ian has been working alongside Christoph Krahenbuhl in 3C Integrity and continues to play a key role in 3C Excellis Europe. 3C’s core business is to support participants in the phama supply chain in shaping up, planning and delivering their serialisation programmes.

    Ian’s area of specialist expertise is a solid, practical understanding of these programmes, particularly from the perspective of manufacturing systems design, development and operation.

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 3

    Manuh Pitasari

    Ms Manuh Pitasari is a pharmacist with more than 10 yrs working experience in Pharmaceutical Industries.

    She is a specialist in Sterile production and has been responsible to introduce new production lines and entire

    highly automated new facilities in Indonesia through to successful PIC/s GMP inspections. She has a deep

    background in all compliance areas and is a highly practical and customer focused GxP practitioner

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 4

    • Brief Background and Introduction

    • Serialisation in Context

    • Global Requirements

    • Supply Chain Participants and Impacts

    • Getting Started – a roadmap to success

    • Q & A

    Agenda

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 5

    • Brief Background and Introduction• Serialisation in Context

    • Global Requirements

    • Supply Chain Participants and Impacts

    • Getting Started – a roadmap to success

    • Q & A

    Agenda

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 8

    • Direct Impact on Patient

    • No therapeutic benefit

    • Over or under dosage

    • Harmful effects including death

    • Impact on Brand Owners

    • Adverse events

    • Loss of revenue

    • Loss of brand

    • Loss of reputation

    • Wider Impact

    • Loss of efficacy (Malaria drugs, Antibiotics)

    Impact of Counterfeit drugs

    Patient Safety

    Brand Protection

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 9

    Verification of Sales Pack is critical

    Counterfeit

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 10

    Pack focused strategies to fight counterfeiting and other threats

    Threats

    AC Technology

    Authentication Features

    • Overt

    • Covert

    • Forensic

    Serialisation

    Assignment of a unique identity to

    each instance of a productTamper Evidence

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 11

    Manufacturer

    Commercial Distribution“Retail”

    Patients

    Legitim

    ate

    Ille

    gitim

    ate

    Finished

    products

    Distribution

    warehouseDistributors Distributors

    Distributors

    Hospitals

    Pharmacies

    Counterfeit

    Products Illegal Distributors

    Retailers with

    no license

    “Unwitting”

    Patient

    Internet Sale

    Illegally diverted

    products

    Stolen products

    The “channel”

    Counterfeit / illegally traded products can infiltrate the

    legitimate supply chain in many potential ways

    Export

    Rural clinics

    Genuine product flow Counterfeit/Illegally traded product flow

    Root cause analysis - the supply chain

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 12

    Manufacturer

    Commercial Distribution“Retail”

    PatientsLe

    gitim

    ate

    Ille

    gitim

    ate

    Finished

    products

    Distribution

    warehouseDistributors Distributors

    Distributors

    Hospitals

    Pharmacies

    Counterfeit

    Products Illegal Distributors

    Retailers with

    no license

    “Unwitting”

    Patient

    Internet Sale

    Illegally diverted

    products

    Stolen products

    The “channel”

    Counterfeit / illegally traded products can infiltrate the

    legitimate supply chain in many potential ways

    Export

    Rural clinics

    Genuine product flow Counterfeit/Illegally traded product flow

    Need to secure the

    supply chain

    Root cause analysis - the supply chain

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 13

    BPSSC Strategy

    Technology Enforcement Leverage to gain wider business

    benefits

    Serialisation Other Features

    Tamper Evidence Authentication

    Collaborate with

    stakeholders

    Securing the

    supply chain

    Tactical Compliance Strategic Impact

    Must Should Could

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 14

    Illustrations © GS1

    Serialisation: The Global Go-To Solution

    2010 2017

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 15

    1. Serialisation is critical....but may not be enough!In the event of an incident involving your products, compliance with serialisation regulations may protect you from

    regulatory scrutiny – but you are also likely to be subject to public and media scrutiny.

    2. Tamper EvidenceTamper evidence of the serialised item is important to give the patient a reasonable degree of assurance that what is

    inside the packaging is what the manufacturer intended seems fundamental – securing the product in the secure

    supply chain.

    Key messages

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 16

    We have just heard about an incident –

    sounds serious!

    Think the problem product got into the

    legitimate supply chain – how?

    What steps were taken when building the

    legitimate supply chain to ensure it was secure?

    16

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 17

    Latest news is that the product was actually manufactured in the

    “so called” legitimate supply chain –

    what are the ways in which that can happen?

    If you find one of your supply chain

    partners has been operating

    illegally – what will you do to

    prevent this happening again?

    17

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 19

    Hot off the press!

    The pack looks really genuine -but was manufactured by a

    counterfeiter

    Where did they get their hands on the product – where did they get their

    hands on those packaging components? Where did they get their hands on the

    machinery to make this stuff?

    What steps did you take to prevent this?

    19

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 20

    • Brief Background and Introduction

    • Serialisation in Context• Global Requirements

    • Supply Chain Participants and Impacts

    • Getting Started – a roadmap to success

    • Q & A

    Agenda

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 21

    Serialisation in healthcare – A brief history

    1997-: Visionary Phase• RFID• The Internet of Things• MIT Auto-ID Center

    2003-: Standards Phase• EPC Global (2003)• EPCIS V1 (2007)• Traceability Standard (‘09)

    2006-: Pilots / Early Adopters• Merck Serono Serostim (2003)• Pfizer Viagra (2005)• Blood Products Ireland (’06)• BRIDGE (‘06-’09)• EFPIA Sweden Pilot (‘09-’10)• AstraZeneca PSDM (‘08)

    2009-: Implementation• Turkey• France CIP-13• California Pedigree• China• Argentina• South Korea• Etc.

    A narrowing focus on compliance

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 23

    The Serialised Pack

    Pack is assigned and carries a set of attributes e.g.

    • Product Code (e.g. GTIN)

    • Randomised Unique Serial Number

    • Expiry Date

    • Batch Number

    Attributes combined together into a “code” and presented on the pack in a human readable form and machine readable data carrier e.g. 2D data matrix

    Example:

    Product #: (01) 0112345678901234

    Batch: (10) A1B2C3D4

    Expiry: (17) 101112

    S/N: (21) 12345AZRQF1234567890

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 24

    The Serialised Pack

    Pack is assigned and carries a set of attributes e.g.

    • Product Code (e.g. GTIN)

    • Randomised Unique Serial Number

    • Expiry Date

    • Batch Number

    Attributes combined together into a “code” and presented on the pack in a human readable form and a machine readable data carrier e.g. 2D data matrix

    Example:

    Product #: (01) 0112345678901234

    Batch: (10) A1B2C3D4

    Expiry: (17) 101112

    S/N: (21) 12345AZRQF1234567890

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 25

    Scanning & Application Identifiers (AIs) in action...

    01108576740020171714112010NYFUL0121192837 ?0110857674002017 17141120 10NYFUL01 21192837

    Sys

    tem

    Inp

    ut GTIN: 09012345670016

    EXPIRATION: 21.May 2012

    BATCH/LOT: 123456

    SERIAL: 123456

    20 Nov 2014 NYFUL01 19283710857674002017

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 26

    Pack Hierarchy – Aggregation & data carriers

    Item

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 27

    Drivers for coding - Aggregation

    Pallet Logistics efficiency Facilitate T&T / ePedigree

    Case /Shipper

    Logistics efficiency Facilitate T&T / ePedigree

    Sales Pack Security, PatientSafety, Anti-fraud

    Authentication / Verification; Product Identification / Dispensing errors; e-Health;

    PrimaryPackage

    Patient Safety, Efficiency

    Product Identification / Dispensing errors; e-Health

    Single Unit Currently none Possibly Clinical Trials use

    Logistics world

    Authentication world

    Patient safety world

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 28

    Pack Hierarchy – Aggregation & data carriers example

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 29

    1) What is T&T?

    Track

    Trace

    2) Key Enablers

    2) Serialised Item Marking

    3) Capture Relationships (Aggregation)

    4) Link to Business Events (e.g. shipment)

    3) Leading to

    Information Sharing / Compliance Reporting

    What is track and Trace?

    1) Standards

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 30

    End to End vs Track and Trace

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 31

    2012

    2013

    2014

    2015

    2016

    Korea 1

    Denmark

    Greece

    China 1

    Japan?

    Argentina

    Colombia

    Canada

    India

    Export

    Brazil 1

    India

    domestic

    Hong

    Kong

    Taiwan

    Russia

    Thailand

    Coding Requirements

    linear or 2D bar

    code with batch-

    variable data only

    (example France

    CIP)

    Static Product Code

    (artwork change

    only)

    [on primary pack]

    2D Datamatrix with

    randomised serial

    number (and

    compliance

    reporting of

    numbers)

    Aggregation

    required

    Explicit or Implicit

    China 2

    Regulatory / legal requirement

    Commercial / Supply Chain

    Roadmap / Standard

    Other

    Korea 2

    Slovenia

    Algeria

    Denmark

    Netherlands

    Switzerland

    Serbia

    Germany

    EU-FMD

    Unclear/unconfirmed

    requirementsSMS

    Kenya

    ParaguayMexicoPanama

    GS1

    GS1

    GS1

    Turkey PTS

    US

    US (batch)

    Korea 3

    Saudi 1

    Saudi 2

    2017 onwards

    India

    Export

    Brazil 2

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 32

    1. Serialisation provides a digital platformWhilst the initial driver may be patient safety – we are building a digital platform that may be exploited by multiple

    stakeholders for a range of internal and external benefits – e.g. supply chain efficiency/visibility

    2. Standards are an essential enabler!In addition to technology capabilities, interoperable standards are essential in order to drive the broadest benefits

    from the programme most quickly.

    Key messages

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 33

    • Brief Background and Introduction

    • Serialisation in Context

    • Global Requirements• Supply Chain Participants and Impacts

    • Getting Started – a roadmap to success

    • Q & A

    Agenda

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 34

    Illustrations © GS1

    Global Requirements – The Challenge

    2010 2017

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 35

    80%

    2020

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 36

    Radar Operator

    Market Watch

    Consolidated

    view of

    Requirements

    Coding Assessment Team

    Remember:

    ➢ Subject to Change

    ➢ Change Management

    ➢ Version Control

    ➢ Documenting the Decision

    Programme of Work

    New and

    changing requirements

    What we are going to do

    Strategy

    Technical Assessment

    Feasibility

    Agreed Principles

    Make decision visible, share with

    stakeholders

    What do these mean?

    Impact assessment

    Coding Assessment Process

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 41

    Global Pharma sales bn $ 900

    US, 350

    EU, 280

    Asia / Africa /

    Australia, 100

    Japan, 100LA, 70

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 42

    GTIN (01) 20354482053011

    SN (21) xxxxxxxxxxx

    Exp (17) YYMMDD

    Lot (10) xxxxxxxx

    MFG Requirement

    *No enforcement when handling product without SNI introduced between Nov 2017 and Nov 2018

    *

    *

    *

    *

    DSCSA Timeline

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 43

    EUFMD “Point of dispense verification”

    Product #: (01) 0112345678901234

    Batch: (10) A1B2C3D4

    Expiry: (17) 101112

    S/N: (21) 12345AZRQF1234567890

    Upload

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 44

    The Road to EU-FMD Compliance: 9th Feb 2019

    2005-2010: Growing awareness of Problem

    2011: EU-FMD

    2012-2015: Stakeholder Alliance

    2016: DR

    2016-2019: Implementation

    2019: Go Live

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 46

    Substantial amount of information available to

    support stakeholders who have obligations under

    these requirements

    https://emvo-medicines.eu/knowledge-database/

    EMVO Knowledge Base

    https://emvo-medicines.eu/knowledge-database/

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 48

    A silver lining on the horizon – Emerging Global Standard

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 49

    • Staying close to the emerging global standard allows you to take advantage of the technology solutions and experience gained already in the early adopter markets

    • Stepping outside of the standard has the potential to increase risk which may impact the costs, time to deploy and manufacturing impact

    • Global standards facilitate international commerce

    • Early adopting manufacturers are playing an advocacy role influencing emerging requirements

    The Benefits of Adhering to the Emerging Global Standard

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 50

    An example of a non collaborative approachFood & Drug Regulatory Authority in Nigeria, NAFDAC

    Industry was not willing to take action,

    HA’s imposed a solution

    Mobile Authentication Service

    Flow Diagram

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 51

    Factors to consider

    • What is the risk in your supply chain?

    • Re-use of packaging – counterfeit manufacture – theft?

    • What are the end points of your “secured” supply chain

    • How far do your regs reach - pharmacy – patient?

    • What is the true nature of your supply chain

    • Who are the participants – what are their capabilities and use cases?

    • How do products travel through your supply chain

    • Original packaging between end points – re-packaging – partial dispensing?

    • National infrastructure?

    Is the Emerging Standard Right for You?

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 52

    • Additional factors that should be considered

    • The selection of the item

    • Tamper Evidence

    • Source of serial numbers – codes

    • ?

    Beyond the Emerging Global Standard...

    Product #: (01) 0112345678901234

    Batch: (10) A1B2C3D4

    Expiry: (17) 101112

    S/N: (21) 12345AZRQF1234567890

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 55

    Brand

    Owner

    Serial Numbers – Provisioning

    Line Controller

    Site Manager

    • Line system manager

    • Interface to ERP/MES

    • Recipe Control

    • Download external Serial Number

    • Site-level data concentrator / buffer

    EPCIS

    • Post-line / Post-lot rework

    Enterprise Level

    • Enterprise-wide EPCIS

    • Compliance reporting

    • Serial Number Verification access

    • Link to Master Data Management

    • Link to Sales & Distribution

    A

    D

    CCMO,

    3PL

    B

    E

    Internal Serial Number Sources:

    C. Central Serial Number Generator

    D. Generated at lower ISA-95 levels

    E. “Discovered” on line

    External Serial Number Sources:

    A. Brand Owner

    B. Government/External Authority

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 56

    Serial Numbers – Provisioning Practices

    A – Increasingly common, driven by QA

    typically – a source of complexity

    B – Example China – made practical by

    de-linking from batch related attributes

    C – Almost universal

    D – Rare (but smart?)

    E – Rare (but smart?)

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 57

    Factors to consider

    • Indonesia is a very large and complex market

    • Significant diversity is to be expected

    • Technological diversity from Jakarta to Papua

    • Manufacturing diversity – relatively small number of large manufacturers with extensive capabilities - many small manufacturers with more limited capabilities

    • Supply chain diversity

    • Solution needs to stretch to be effective right across the market

    • Could consider this to be a more demanding requirement than that faced by other markets

    Indonesian Requirements?

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 58

    Proposed system has a strong emphasis on securing the supply chain and protecting the consumer from counterfeits through surveillance

    • Serialisation/product identification

    • Track and Trace

    • Consumer participation

    Broader ambitions are also apparent

    • Optimise recall

    • Enhanced surveillance of manufacture, distribution and healthcare service activities

    • Prevent shortages

    Indonesian Requirements?

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 59

    • Track and Trace

    • Optimising production plan

    • Visibility of distribution

    • Optimising procurement planning

    • Visibility of drug consumption in each region

    • Preventing shortages

    • Optimising recall

    • Minimise counterfeit

    Anticipated Manufacturer, Distributor and Healthcare Facilities benefits

    In other markets (EU for

    example) this level of

    visibility was hoped for by

    the manufacturers but not

    achieved.

    Loss of data visibility was

    the price of participation of

    other supply chain actors

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 60

    • Scope includes domestic and imported products – this catches the attention of global manufacturers and standards bodies – inclusion of OTC!

    • They are looking for compliance with the de-facto emerging global standard...

    • Lobbying to use 2D data matrix and not QR codes

    • Lobbying to comply with GS1 standards

    • If Indonesia can accommodate these requests whilst at the same time meeting the demanding requirements Indonesia face – it would help the rapid and effective implementation of the system.

    The view from outside...

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 61

    • Pack attributes

    • Registration number

    • Batch number / production code

    • Expiration date

    • Serial number

    • Optional GTIN and other product identities

    • Alignment on GTIN as product code is desirable (note GTIN ≠ Registration number...)

    • Inclusion of “other product identities” along with use of QR (vs wide healthcare adoption of GS1 data matrix) gives rise to concerns over the physical size of the code.

    • Identification of the item...

    The view from outside...in a bit more detail

    Product #: (01) 0112345678901234

    Batch: (10) A1B2C3D4

    Expiry: (17) 101112

    S/N: (21) 12345AZRQF1234567890

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 63

    • The proposed system provides the facility for manufacturers to generate their own serial numbers

    • The proposed system also offers to provide 2D codes for manufacturers “without their own serialisation system”

    • The inclusion of batch specific data in the codes along with the 2 week lead time may make this problematic to operate

    • A complete understanding of the obligations on manufacturers and how these are viewed internally from a GMP perspective is required before it can be understood how this provision will aid manufacturers in practice e.g reconciliation of codes, storage of codes etc.

    What is the source of serial numbers?

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 65

    1. There is an emerging de-facto global healthcare coding standard

    Alignment with the standard is beneficial for all supply chain participants.

    2. There may be specific characteristics of the Indonesian supply chain that demand a non standard approach or non standard components

    Protection of Indonesian consumers is more important than compliance with emerging standards

    Key Messages

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 66

    • Brief Background and Introduction

    • Serialisation in Context

    • Global Requirements

    • Supply Chain Participants and Impacts• Getting Started – a roadmap to success

    • Q & A

    Agenda

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 67

    • Regulations clearly state who the supply chain participants are;

    • Manufacturers

    • Distributors

    • Healthcare Facilities

    • Consumers

    • Regulator is also a participant and plays a vital role playing their part in the design, implementation and running of the system

    • Detail assessment of impact not yet possible – subject to publication of final regulation

    Supply Chain Participants

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 68

    • The role of the regulator is fundamental

    • BPOM have been developing the requirement over a number of years

    • 2016 planning

    • 2017 scoping, piloting, benchmarking, legal drafting

    • 2018 stage 1 implementation....

    • Taking feedback from the pilot group and lobbyists and considering/making adjustments to the requirements

    • Next phases are critical to the success of the system

    • Detail definition and guidance for supply chain participants – technical working groups?

    • Support to stakeholders in understanding their obligations under the regulations and GMP

    • Being responsive to feedback from stakeholders, providing and communicating, clarification of requirements and obligations

    The Regulator

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 69

    Implementation/roll out of the proposed system is a key consideration for the regulator – experience from other markets...

    • In addition to publication of the regulation - publication of the “URS Lite” in EU was a fundamental step in facilitating participants understanding of the system and their obligations

    • Further more detailed publications followed – software development kit etc allowing solution providers to build and test solutions

    • The “real” supply chain may be more complex than the regulations anticipate – multi-role players, virtual manufacturers, re-packaging etc.

    • Early engagement with detail flushes out these use cases

    • Engagement needs to be facilitated – recommend engagement with industry associations/trade bodies to run technical user groups

    • Consideration may be given to phasing in requirements – scope phasing, or technical capabilities – but beware of transitional issues...

    The Regulator

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 70

    • The manufacturer is at the heart of this – without the ability to consistently and reliably put readable codes on packs – the system can not run

    • Experience across multiple companies setting out to achieve compliance with various serialisation requirements indicates that this is likely to be the biggest and most complex programme you will deal with.

    • And it may not always be plain sailing...

    The Manufacturer

    There is a lot if information now on manufacturing impact

    Key initiatives have focussed here

    • US stepwise implementation

    • EU End points only

    Other supply chain impacts are only now emerging

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 71

    This is not just a technology project

    Master Data Mgt., GTINs

    etc.Radar & Impact

    Assessment

    External Alignment

    Investigations & Enforcement

    Incident Management

    Supply Chain Integrity

    Artwork Process

    Regulatory Function

    System Security Concerns

    System Validation/GAMP

    etc.

    Distribution

    Enterprise level

    Site Manager

    Line Control

    Device

    Leve

    l 1Le

    vel 2

    Leve

    l 3Le

    vel 4

    Collaboration Layer

    Scanner PrinterScannerCameraPrinter RFID

    HMI Packing Line

    Repository

    Capture I/F

    Query I/FNumber Mgt.

    Master data

    Authentication

    Compliance module

    WMS

    Packaging

    http://www.google.co.uk/url?sa=i&rct=j&q=bar+code+scanner&source=images&cd=&cad=rja&docid=fU8l7fDKWKDxyM&tbnid=ZUn2eCCgN46FHM:&ved=0CAUQjRw&url=http://www.ebay.com/itm/New-USB-Barcode-Scanner-Laser-Bar-Code-Reader-POS-Cash-Register-2-M-Cable-/271078296611&ei=Mm43UYmcC8q20QW_pIDICw&bvm=bv.43287494,d.ZWU&psig=AFQjCNEFM9T-8TOGEghRacIaHGJYg0dk1w&ust=1362673578470256http://www.google.co.uk/url?sa=i&rct=j&q=bar+code+scanner&source=images&cd=&cad=rja&docid=fU8l7fDKWKDxyM&tbnid=ZUn2eCCgN46FHM:&ved=0CAUQjRw&url=http://www.ebay.com/itm/New-USB-Barcode-Scanner-Laser-Bar-Code-Reader-POS-Cash-Register-2-M-Cable-/271078296611&ei=Mm43UYmcC8q20QW_pIDICw&bvm=bv.43287494,d.ZWU&psig=AFQjCNEFM9T-8TOGEghRacIaHGJYg0dk1w&ust=1362673578470256http://www.google.co.uk/url?sa=i&rct=j&q=lable+printer&source=images&cd=&docid=3OaEJBDRsFr5SM&tbnid=10a9XMFIpL8O7M:&ved=0CAUQjRw&url=http://www.accuratesystemslabelling.co.uk/information/buyers-guide/detail/id=9&ei=hG43UfW8AcbB0QX_9oGQCQ&bvm=bv.43287494,d.ZWU&psig=AFQjCNFU7QKnKwT18uwr0YQou7LVSVhhUg&ust=1362673650452914http://www.google.co.uk/url?sa=i&rct=j&q=thermal+ink+jet&source=images&cd=&cad=rja&docid=IdcO_XfYu6riWM&tbnid=vtyZK4xnXtn0SM:&ved=0CAUQjRw&url=http://www.packagingdigest.com/article/455659-Thermal_ink_jet_printer.php&ei=BG83UcP6N6e_0QW2v4DgCA&psig=AFQjCNGpgbsx-qxnIUyUDt3hQf8Iml0pEA&ust=1362673772833033http://www.google.co.uk/url?sa=i&rct=j&q=machine+vision+system&source=images&cd=&cad=rja&docid=TG-W3Y2UeOcuwM&tbnid=s8dbLn60xf1SoM:&ved=0CAUQjRw&url=http://www.directindustry.com/prod/turck/cameras-for-machine-vision-systems-4959-565263.html&ei=dG83UZqLLoy20QW-s4GwCA&psig=AFQjCNHsacjT8QmYUabtgJnQUNCfwXN8Dg&ust=1362673867147348http://www.google.co.uk/url?sa=i&rct=j&q=rfid+reader&source=images&cd=&cad=rja&docid=DrcPH2mKJApNKM&tbnid=G4c2a4JQVHT6yM:&ved=0CAUQjRw&url=http://friendcom.en.alibaba.com/product/260184899-200093002/FC_406_Active_RFID_Reader.html&ei=bXA3Uc6nC7SU0QW59IDwBw&psig=AFQjCNEXb8anK5lUgi4AILcrtzW9gKG56Q&ust=1362674145772787http://www.google.co.uk/url?sa=i&rct=j&q=hmi&source=images&cd=&cad=rja&docid=QyDdcpn7uQ6_pM&tbnid=riojxCoTHYe7eM:&ved=0CAUQjRw&url=http://www.transdrive.co.uk/hmi/delta/&ei=2XA3UfKECeWd0QXEtYH4Bw&psig=AFQjCNGUHM6GeyZ4zoO4-LGSh_XKA8AlBA&ust=1362674243062950http://www.google.co.uk/url?sa=i&rct=j&q=computer&source=images&cd=&cad=rja&docid=BliXwZtvhrONRM&tbnid=4LD4vNRi1acYyM:&ved=0CAUQjRw&url=http://www.cantleycomputers.co.uk/Repairs.html&ei=_3E3UbiKLcit0QWT5oGICQ&psig=AFQjCNG2fTuwxjRI4POZObyfot1Qj-1HhA&ust=1362674552598850http://www.google.co.uk/url?sa=i&rct=j&q=pallet&source=images&cd=&cad=rja&docid=-iFPJRKvAwSlrM&tbnid=sQDIFsqdb_TdfM:&ved=0CAUQjRw&url=http://www.storageconcepts.co.uk/blog/2012/06/08/pallet-racking-recent-project-leicester/&ei=SXI3UZj1J4a90QXG_4DgBw&psig=AFQjCNHPdF-zIGdHUWA3GvmacBlMSdF64Q&ust=1362674623798087http://www.google.co.uk/url?sa=i&rct=j&q=pallet&source=images&cd=&docid=PQ0P5OOsLCX8YM&tbnid=yse15GHI3LnDUM:&ved=0CAUQjRw&url=http://dunhilltimberpallets.com/&ei=pnI3UevhDsOn0AWUroCgCQ&psig=AFQjCNHPdF-zIGdHUWA3GvmacBlMSdF64Q&ust=1362674623798087

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    Page 73

    The Serialisation Solution Stack

    DistributionPackaging

    Enterprise level

    Site Manager

    Line Manager

    Station Manager

    Level 1Production Control (manipulating)

    Level 2Production Control

    (supervisory)

    Level 3Manufacturing Operations Management

    Level 4Business Logistics

    Collaboration Layer

    Scanner PrinterScannerCameraPrinter RFID reader

    HMI Packing Line

    RepositoryCapture I/F

    Query I/FNumber management

    Master data

    Authentication services

    Compliance module

    WMS

    Level 5

    http://www.google.co.uk/url?sa=i&rct=j&q=bar+code+scanner&source=images&cd=&cad=rja&docid=fU8l7fDKWKDxyM&tbnid=ZUn2eCCgN46FHM:&ved=0CAUQjRw&url=http://www.ebay.com/itm/New-USB-Barcode-Scanner-Laser-Bar-Code-Reader-POS-Cash-Register-2-M-Cable-/271078296611&ei=Mm43UYmcC8q20QW_pIDICw&bvm=bv.43287494,d.ZWU&psig=AFQjCNEFM9T-8TOGEghRacIaHGJYg0dk1w&ust=1362673578470256http://www.google.co.uk/url?sa=i&rct=j&q=bar+code+scanner&source=images&cd=&cad=rja&docid=fU8l7fDKWKDxyM&tbnid=ZUn2eCCgN46FHM:&ved=0CAUQjRw&url=http://www.ebay.com/itm/New-USB-Barcode-Scanner-Laser-Bar-Code-Reader-POS-Cash-Register-2-M-Cable-/271078296611&ei=Mm43UYmcC8q20QW_pIDICw&bvm=bv.43287494,d.ZWU&psig=AFQjCNEFM9T-8TOGEghRacIaHGJYg0dk1w&ust=1362673578470256http://www.google.co.uk/url?sa=i&rct=j&q=lable+printer&source=images&cd=&docid=3OaEJBDRsFr5SM&tbnid=10a9XMFIpL8O7M:&ved=0CAUQjRw&url=http://www.accuratesystemslabelling.co.uk/information/buyers-guide/detail/id=9&ei=hG43UfW8AcbB0QX_9oGQCQ&bvm=bv.43287494,d.ZWU&psig=AFQjCNFU7QKnKwT18uwr0YQou7LVSVhhUg&ust=1362673650452914http://www.google.co.uk/url?sa=i&rct=j&q=thermal+ink+jet&source=images&cd=&cad=rja&docid=IdcO_XfYu6riWM&tbnid=vtyZK4xnXtn0SM:&ved=0CAUQjRw&url=http://www.packagingdigest.com/article/455659-Thermal_ink_jet_printer.php&ei=BG83UcP6N6e_0QW2v4DgCA&psig=AFQjCNGpgbsx-qxnIUyUDt3hQf8Iml0pEA&ust=1362673772833033http://www.google.co.uk/url?sa=i&rct=j&q=machine+vision+system&source=images&cd=&cad=rja&docid=TG-W3Y2UeOcuwM&tbnid=s8dbLn60xf1SoM:&ved=0CAUQjRw&url=http://www.directindustry.com/prod/turck/cameras-for-machine-vision-systems-4959-565263.html&ei=dG83UZqLLoy20QW-s4GwCA&psig=AFQjCNHsacjT8QmYUabtgJnQUNCfwXN8Dg&ust=1362673867147348http://www.google.co.uk/url?sa=i&rct=j&q=rfid+reader&source=images&cd=&cad=rja&docid=DrcPH2mKJApNKM&tbnid=G4c2a4JQVHT6yM:&ved=0CAUQjRw&url=http://friendcom.en.alibaba.com/product/260184899-200093002/FC_406_Active_RFID_Reader.html&ei=bXA3Uc6nC7SU0QW59IDwBw&psig=AFQjCNEXb8anK5lUgi4AILcrtzW9gKG56Q&ust=1362674145772787http://www.google.co.uk/url?sa=i&rct=j&q=hmi&source=images&cd=&cad=rja&docid=QyDdcpn7uQ6_pM&tbnid=riojxCoTHYe7eM:&ved=0CAUQjRw&url=http://www.transdrive.co.uk/hmi/delta/&ei=2XA3UfKECeWd0QXEtYH4Bw&psig=AFQjCNGUHM6GeyZ4zoO4-LGSh_XKA8AlBA&ust=1362674243062950http://www.google.co.uk/url?sa=i&rct=j&q=computer&source=images&cd=&cad=rja&docid=BliXwZtvhrONRM&tbnid=4LD4vNRi1acYyM:&ved=0CAUQjRw&url=http://www.cantleycomputers.co.uk/Repairs.html&ei=_3E3UbiKLcit0QWT5oGICQ&psig=AFQjCNG2fTuwxjRI4POZObyfot1Qj-1HhA&ust=1362674552598850http://www.google.co.uk/url?sa=i&rct=j&q=pallet&source=images&cd=&cad=rja&docid=-iFPJRKvAwSlrM&tbnid=sQDIFsqdb_TdfM:&ved=0CAUQjRw&url=http://www.storageconcepts.co.uk/blog/2012/06/08/pallet-racking-recent-project-leicester/&ei=SXI3UZj1J4a90QXG_4DgBw&psig=AFQjCNHPdF-zIGdHUWA3GvmacBlMSdF64Q&ust=1362674623798087http://www.google.co.uk/url?sa=i&rct=j&q=pallet&source=images&cd=&docid=PQ0P5OOsLCX8YM&tbnid=yse15GHI3LnDUM:&ved=0CAUQjRw&url=http://dunhilltimberpallets.com/&ei=pnI3UevhDsOn0AWUroCgCQ&psig=AFQjCNHPdF-zIGdHUWA3GvmacBlMSdF64Q&ust=1362674623798087

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 74

    The Serialisation Solution Stack Components

    DistributionPackaging

    Enterprise level

    Site Manager

    Line Manager

    Station Manager

    Level 1Production Control (manipulating)

    Level 2Production Control

    (supervisory)

    Level 3Manufacturing Operations Management

    Level 4Business Logistics

    Collaboration Layer

    Scanner PrinterScannerCameraPrinter RFID reader

    HMI Packing Line

    RepositoryCapture I/F

    Query I/FNumber management

    Master data

    Authentication services

    Compliance module

    WMS

    http://www.google.co.uk/url?sa=i&rct=j&q=bar+code+scanner&source=images&cd=&cad=rja&docid=fU8l7fDKWKDxyM&tbnid=ZUn2eCCgN46FHM:&ved=0CAUQjRw&url=http://www.ebay.com/itm/New-USB-Barcode-Scanner-Laser-Bar-Code-Reader-POS-Cash-Register-2-M-Cable-/271078296611&ei=Mm43UYmcC8q20QW_pIDICw&bvm=bv.43287494,d.ZWU&psig=AFQjCNEFM9T-8TOGEghRacIaHGJYg0dk1w&ust=1362673578470256http://www.google.co.uk/url?sa=i&rct=j&q=bar+code+scanner&source=images&cd=&cad=rja&docid=fU8l7fDKWKDxyM&tbnid=ZUn2eCCgN46FHM:&ved=0CAUQjRw&url=http://www.ebay.com/itm/New-USB-Barcode-Scanner-Laser-Bar-Code-Reader-POS-Cash-Register-2-M-Cable-/271078296611&ei=Mm43UYmcC8q20QW_pIDICw&bvm=bv.43287494,d.ZWU&psig=AFQjCNEFM9T-8TOGEghRacIaHGJYg0dk1w&ust=1362673578470256http://www.google.co.uk/url?sa=i&rct=j&q=lable+printer&source=images&cd=&docid=3OaEJBDRsFr5SM&tbnid=10a9XMFIpL8O7M:&ved=0CAUQjRw&url=http://www.accuratesystemslabelling.co.uk/information/buyers-guide/detail/id=9&ei=hG43UfW8AcbB0QX_9oGQCQ&bvm=bv.43287494,d.ZWU&psig=AFQjCNFU7QKnKwT18uwr0YQou7LVSVhhUg&ust=1362673650452914http://www.google.co.uk/url?sa=i&rct=j&q=thermal+ink+jet&source=images&cd=&cad=rja&docid=IdcO_XfYu6riWM&tbnid=vtyZK4xnXtn0SM:&ved=0CAUQjRw&url=http://www.packagingdigest.com/article/455659-Thermal_ink_jet_printer.php&ei=BG83UcP6N6e_0QW2v4DgCA&psig=AFQjCNGpgbsx-qxnIUyUDt3hQf8Iml0pEA&ust=1362673772833033http://www.google.co.uk/url?sa=i&rct=j&q=machine+vision+system&source=images&cd=&cad=rja&docid=TG-W3Y2UeOcuwM&tbnid=s8dbLn60xf1SoM:&ved=0CAUQjRw&url=http://www.directindustry.com/prod/turck/cameras-for-machine-vision-systems-4959-565263.html&ei=dG83UZqLLoy20QW-s4GwCA&psig=AFQjCNHsacjT8QmYUabtgJnQUNCfwXN8Dg&ust=1362673867147348http://www.google.co.uk/url?sa=i&rct=j&q=rfid+reader&source=images&cd=&cad=rja&docid=DrcPH2mKJApNKM&tbnid=G4c2a4JQVHT6yM:&ved=0CAUQjRw&url=http://friendcom.en.alibaba.com/product/260184899-200093002/FC_406_Active_RFID_Reader.html&ei=bXA3Uc6nC7SU0QW59IDwBw&psig=AFQjCNEXb8anK5lUgi4AILcrtzW9gKG56Q&ust=1362674145772787http://www.google.co.uk/url?sa=i&rct=j&q=hmi&source=images&cd=&cad=rja&docid=QyDdcpn7uQ6_pM&tbnid=riojxCoTHYe7eM:&ved=0CAUQjRw&url=http://www.transdrive.co.uk/hmi/delta/&ei=2XA3UfKECeWd0QXEtYH4Bw&psig=AFQjCNGUHM6GeyZ4zoO4-LGSh_XKA8AlBA&ust=1362674243062950http://www.google.co.uk/url?sa=i&rct=j&q=computer&source=images&cd=&cad=rja&docid=BliXwZtvhrONRM&tbnid=4LD4vNRi1acYyM:&ved=0CAUQjRw&url=http://www.cantleycomputers.co.uk/Repairs.html&ei=_3E3UbiKLcit0QWT5oGICQ&psig=AFQjCNG2fTuwxjRI4POZObyfot1Qj-1HhA&ust=1362674552598850http://www.google.co.uk/url?sa=i&rct=j&q=pallet&source=images&cd=&cad=rja&docid=-iFPJRKvAwSlrM&tbnid=sQDIFsqdb_TdfM:&ved=0CAUQjRw&url=http://www.storageconcepts.co.uk/blog/2012/06/08/pallet-racking-recent-project-leicester/&ei=SXI3UZj1J4a90QXG_4DgBw&psig=AFQjCNHPdF-zIGdHUWA3GvmacBlMSdF64Q&ust=1362674623798087http://www.google.co.uk/url?sa=i&rct=j&q=pallet&source=images&cd=&docid=PQ0P5OOsLCX8YM&tbnid=yse15GHI3LnDUM:&ved=0CAUQjRw&url=http://dunhilltimberpallets.com/&ei=pnI3UevhDsOn0AWUroCgCQ&psig=AFQjCNHPdF-zIGdHUWA3GvmacBlMSdF64Q&ust=1362674623798087

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 75

    The Hardware

    Starting from the base line of a conventional manufacturing line with no tamper evidence and embossed variable data …….what would the item level coding station look like?

    • A platform (maybe a tamper evident labeller)

    • Addressable printer with associated vision system

    • Integrated reject station

    • Level 2 serialisation software component – connected to level 3

    Aggregation – additional hardware integrated into existing equipment or semi-automatic coding and printing equipment.

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    Page 77

    Manufacturing Impact

    Top Tier

    Average

    Poor

    Performer

    Top tier line – a small but permanent drop in OEE – 5%

    Average line – significant early drop in OEE followed by recovery and the

    prospect of improved performance in the long term

    Poor performer – rapid decline in performance – little chance of recovery

    Early adopters report

    significant impact - 2 to 4

    years required to recover

    OEE!

    Manufacturing NEWS

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 78

    • Enemy of serialisation is disturbance from the steady state

    • Take time under normal circumstances but serialisation increases the complexity of recovery – reconciliation of the physical and data assets

    • Work on the performance of your assets now;

    • Drive ERT (Effective Run Time) up

    • Consider reinvestment where assets are poor performers

    • Create capacity now

    What Can You Do Now?

    Primary Packing Secondary Packing

    ERT >

    60%

    35% < ERT < 60%

    ERT <

    35%

    ERT >

    60%

    ERT <

    60%

    Retain

    Sustain

    Drive

    Arrive

    Retire

    Aspire

    Retire

    Aspire

    Retain

    Bolt on

    70%

    30%

    Capex

    Pick your Pilot Line...• Not your best

    • Not your worst

    • Not your most occupied

    • Not your most important

    product

    • Pick your pilot team

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 79

    • Like other supply chain participants there is a need to map your current business processes and to overlay on those your obligations under the new regulations – note 2025 deadline...

    • “Happy Path” requirements appear to be relatively straightforward

    • Scan product in and report to BPOM – note scan down through the aggregated levels until scan is valid – tertiary, secondary, item

    • Scan the product out and report to BPOM

    • Full process mapping however is required to identify all your business processes and understand how they are impacted e.g.

    • Sampling, loss or damage, no reads

    • Partial shipments

    • Export (sales to anyone outside of the system)

    • Repackaging

    • Integration with existing business systems e.g. WMS

    The Distributor

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 80

    Factors to consider

    • Manufacturers use of 3PL – handle product on their behalf

    • Wholesaler – receive product from manufacturer but also from other wholesalers

    • Wholesalers may reconfigure product for onward shipment

    • Aggregations established by the manufacturer may not survive very long in the supply chain

    • Wholesalers will be de-aggregating and re-aggregating product

    • Mixed (non homogeneous) cases and mixed pallets will move around the supply chain

    • Reverse logistics

    The Distributor

    3PL

    NB. Current coding

    scheme may not

    support

    reconfiguration of

    goods in the supply

    chain – default

    option is item level

    scanning

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 81

    • May see variety in codes on incoming goods

    • QR Codes

    • 2D DM codes

    • Codes on secondary and tertiary packaging?

    • Status of product now becomes important and this may need to be reflected in physical disposition of the goods in facility

    • Ready to scan (incoming goods)

    • Scanned and failed (synchronous or asynchronous process?) – quarantined for return

    • Scanned and available

    • Scanned and ready to ship

    • In addition to (mobile) scanning equipment, likely to need some technology, possibly integrated with current WMS and ERP systems recording and aligning product status

    The Distributor

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    Page 82

    • Healthcare facilities are very similar to distribution facilities in the regulation – the final transaction however is an item level “sell” rather than “ready to be distributed”

    • Similar considerations apply for healthcare facility

    • May see variety in codes on incoming goods

    • QR Codes

    • 2D DM codes

    • Codes on secondary and tertiary packaging?

    • Status of product wrt to the system now becomes important and this may need to be reflected in physical disposition of the goods in facility

    • Ready to scan (incoming goods)

    • Scanned and failed (synchronous or asynchronous process?) – quarantined for return

    • Scanned and available

    • Scanned and ready to sell/dispense

    • In addition to scanning equipment, likely to need some technology, possibly integrated with current PMR or POS systems recording and aligning product status

    Healthcare Facilities (Hospital pharmacy, drugstore, dispensary)

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    Page 83

    • Although provided with an app to allow consumers to validate their own product, they are not system participants as such but simply gain access to the status of the product (serial number)

    • Expectation is that consumers will

    • Verify their product

    • Report suspected counterfeits

    • Example Europe – scanning at the point of dispensing

    • In some clinical settings this may not be possible – parenteral products for example

    • May not always be a pharmacist present at point of dispensing – institutional use, dispensing doctors etc

    • Take up of such systems of often low – trust in supply chain – privacy issues are increasingly a factor

    Consumers

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 84

    • This is a critical moment in the project where the all supply chain participants need to work together to put the meat on the bones of the regulation

    • Publication of detail requirements – URS Lite etc

    • Business process mapping to understand obligations (happy path and deviations)

    • Working together to drive out the detail – industry associations and trade bodies working together with the regulator

    Key Messages

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 85

    • Brief Background and Introduction

    • Serialisation in Context

    • Global Requirements

    • Supply Chain Participants and Impacts

    • Getting Started – a roadmap to success• Q & A

    Agenda

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 86

    Some good news and some bad news

    • The Bad News:

    • Serialisation projects are big projects

    • The impact of failure is potentially huge

    • Often complex, involving many areas and requiring collaboration across boundaries

    • They can suffer from high degrees of uncertainty and change

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 87

    • The Bad News:

    • Serialisation projects are big projects

    • The impact of failure is potentially huge

    • Often complex, involving many areas and requiring collaboration across boundaries

    • They can suffer from high degrees of uncertainty and change

    • But there is Good News:

    • The core capabilities that need to be established are not too complex and increasingly well understood

    • These can actually be pretty straightforward projects in terms of planning

    • But need to seize the opportunities to simplify: Decouple, use generic approaches that are flexible and adaptable

    • With sound programme/project management practice success is assured

    Some good news and some bad news

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 88

    Inherent Conflicts

    • Serialisation Projects are prone to more conflicts than other projects because of:

    • Size and Scale of the undertaking

    • Diverse parts of the organisation with diverse standards, guidelines, processes and “traditions” collide

    • Operating to different (conflicting?) targets and objectives

    • In terms of project management: You are dealing with an IT project but also an engineering project, an artwork project, a supply chain project, business change project etc….

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 89

    • There is a need to map your current business processes and to overlay on those your obligations under the new regulations

    • “Happy Path” requirements – make product, apply codes, upload codes to activate the product.

    • Non happy path processes need also to be understood e.g.

    • Codes requested and not used on finished goods

    • Insufficient codes available during manufacturing order

    • Post lot re-work - Loss, damage or sampling of product

    • Partial case upload

    • A consideration of how the serialisation process integrates with your existing business systems will also be required – ERP, MWS etc

    • You will need to take a GMP view of your activities under the new regulations – e.g. reconciliation of codes, vision inspection of codes, linking to product release processes, data retention etc.

    Business process mapping

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 90

    • Work can start now on a business impact assessment of serialisation

    • Aspects like artwork modification to accommodate the new codes are complex and time consuming –may be the biggest artwork project you have undertaken

    • Regulatory impact of pack re-design is likely to be a factor – early planning is essential

    • Identification of the wider supply chain impact is important as your ability to comply may be critically dependent on the activities of third parties

    • Understanding the scope will allow you to resource the project – manpower and finance - avoiding surprises later

    • Roll out strategy is important along with any stock build to create capacity

    • The initial obligation to get one line operating is critical

    • This pilot line forms a technology platform that you can use to establish the capability and the necessary supplier relationships. A solid launch platform to rapid and trouble free compliance.

    Impact Assessment

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    You need the right team

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    Research lists the following suspects:

    • Supply chain management

    • Product Security Function

    • Production/Manufacturing Ops.

    • IT

    • Packaging

    • Regulatory

    So who should lead the team?

    Questions:

    • Where does the program emerge from?

    • Where is the program best placed for

    now?

    • Who will own this long-term in BAU?

    • Who will suffer most if it goes wrong?

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    • Regulatory• IT• Package Design/Labelling• Package engineering• Warehouse• Distribution• QA• Validation and CSV• Operations• Planning and scheduling• Supply chain and logistics• Customer services/commercial• Sourcing/Procurement

    • Legal• Any others?

    Who should be in the team?

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    • What are the characteristics of your supply chain up to the point of “change in title”?

    • Your supply chain reaches beyond your packing line, factory and organisation!

    • Are you a 3PL or a wholesaler or both?

    • Where is the centre of gravity of your project?

    Where are you in the supply chain?

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    What Goes Wrong?

    Your ProgrammeThe Regulatory

    Requirements

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    What Goes Wrong - Engaging your Senior Stakeholders

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    What Goes Wrong - Engaging your Senior Stakeholders

    What does it Cost (money, resources, attention)? What else does it prevent me from

    doing?

    How does it impact my OEE? During

    implementation and beyond?

    What can I do to minimise the impact?

    Are there ways of turning this into a benefit?

    Do I really need to do anything? Where do I find out more?

    What is this all about? What are

    these requirements?

    "Can we get back to talking about the real

    pharmaceutical business now?"

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    Patient Journey = Program Journey

    New opportunities

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    • Conflicting priorities

    • Misunderstanding the scale and scope of the programme

    • Underestimating resource requirement – people, capital, capacity, time

    • Master data management problems

    • Lack of strategic clarity

    • Failing to address the external supply chain in time

    • Poor/limited regulatory understanding

    • Unknown unknowns...

    1

    0

    1

    What Else Goes Wrong…

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

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    • Poor/limited understanding of the real supply chain

    • Timescales for implementation

    • Big bang

    • Phased roll out - roadmap

    • Long vs short lead times

    • Too many stakeholders under one umbrella

    • Changing direction

    • China, India export, Brazil,

    • Over ambition – selection of novel solutions

    • Failure to pilot to shake issues out

    1

    0

    2

    What Else Goes Wrong…Regulatory Issues

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    Page 103

    • Brief Background and Introduction

    • Serialisation in Context

    • Global Requirements

    • Supply Chain Participants and Impacts

    • Getting Started – a roadmap to success

    • Q & A

    Agenda

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

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    Ian Haynes

    [email protected]

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    1

    0

    5

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    • Background and Introduction

    • Serialisation in Context

    • Global Requirements

    • Impact on Manufacturers

    • Getting Started – a roadmap to success

    • Want you want from your regulator – panel discussion

    Agenda

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    Page 107

    • Dialogue – a partnership approach to delivering patient safety through securing the supply chain leading to...

    • Regulations• Effective - designed to tackle the identified risks

    • Comprehensive – address the activities of all supply chain participants

    • Achievable – clearly defined with realistic time phasing

    • To as great an extent as possible aligning with the emerging global standard

    • Allows available and proven technology solutions to be exploited

    • Reduces risk – rapid deployment and predictable cost

    • Builds on the experience of others

    • Facilitates the creation of capability that is useful in the wider context supporting industry ambition

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

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    Illustrations © GS1

    Serialisation: From Success to Challenge

    2010 2017

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    Regulatory LabellingManufacturi

    ngCMOs IT ERP

    Supply chain

    sales

    • Serialization is a regulatory imperative • Serialization is still evolving . ( Today : Turkey, Korea, US-DSCSA-EUFMD , many new

    regulations to come Russia, Middle-East, some regulations changes : Brazil, China, India,….)

    • Your company is evolving• Serialisation is an enterprise program

    A Holistic approach to serialization

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

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    • Limited internal bandwidth…: implementing a major project like serialisation that

    touches many parts of the organisation

    • Limited internal knowledge….: limited internal knowledge and experience of the

    particular challenges of serialisation

    • How to understand the details and impact of the requirements in the many

    markets where the company operates

    • Understanding what needs to be done to be Serialisation-ready: Best Practices

    Serialisation Project Challenges

    Unknown UnknownsPharma Business vs. One-off

    ProjectsScope Reaches Far Beyond

    Company Border

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

    Page 111

    Methodology : Strategy to Sustainability

    STRATEGY PILOT STANDARDIZATION INTEGRATION ROLLOUT SUSTAINABILITY

    • Process design • Data standards development• Compliance assessment• Technology selection• Pilot implementation

    • Integration framework development

    • Up-stream & Downstream process integration• Data integration

    • Process re-evaluation & standardization• Data standardization• Governance model development• Implementation Template development• Quality framework development• KPI Establishment

    • Global solution deployment

    • Template localization• Site implementations• Site KPI establishment

    • Serialization COE• Internal support model• Best-in-class solution• KPI measurement and

    enhancement• Quality management

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    Page 112

    Counterfeit medicines are deliberately and fraudulently mislabelled with respect

    to identity or source:

    • One of the biggest risks of counterfeit medicines is that patients may not get the therapeutic benefit expected from the product.

    • The market in counterfeit and substandard drugs thrives in areas with weak regulation and enforcement of drug laws

    • Their victims are the weakest in society: People who are suffering from sickness and illness

    • They target areas such as lifestyle applications, nutritional supplements

    • Counterfeit medicines are manufactured in clandestine laboratories with no standards, no regard for quality, no control.

    • Their quality is unpredictable as they may contain the wrong amount of active ingredients, wrong ingredients or no active ingredients.

    Focus on Counterfeit Medicines?

  • Proprietary & Confidential | Copyright © 2018 Excellis Health Solutions LLC | All Rights Reserved

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    Counterfeit Medication – a closer look

    Authentic Counterfeit

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    oftware?

    Fake Credit Cards?

    Narcotics?

    ecisions, decision

    s...

    Counterfeit Pharmaceutical

    s?

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    Page 115

    For every $1000 invested, counterfeitpharmaceuticals generates $ ½ Million return*

    Pharmaceutical Counterfeiting is seen as High

    Profit with Low Risk

    So who may be involved ?

    ➢ Organised crime gangs

    ➢ Unlicensed businesses

    ➢ Licensed businesses: Brokers, Distributors,

    WholesalersReturn on $1K Investment

    $7K

    $100K

    $500K

    Fake c

    redit

    card

    s

    Counte

    rfeit s

    oftw

    are

    Counte

    rfeit d

    rugs

    * S

    ou

    rce

    : V

    isa

    /Ma

    ste

    r C

    ard

    , M

    icro

    so

    ft,

    AZ

    ow

    n d

    ata

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    • Impacting lifestyle drugs

    • Branded medicines

    • Generics

    • High value

    • Low value

    • High volume

    • Low volume

    • Internet pharmacy a particular problem

    A Global Problem

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    Page 117

    How do you turn all these requirements and uncertainties into something practical that we can deliver?

    1

    1

    7

    Impact on Manufacturing

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    Program Organisation

    The real skill is to build the right sub-

    teams and to manage them when they

    are in and also when they are out

    Responsible

    Accountable

    Consulted

    Informed

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    Page 120

    Program Organisation

    Core Team

    Sub team 1 Sub team 2 Sub team 3

    Reference or stakeholder

    group

    Design Authority

    Steering Group

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    Implementation ProgrammeACTIVE PROJECTS

    Tactics & Strategy

    Technical/IS

    Delivery SupportProduct Driven

    MarketDriven

    Security

    Features

    ProjectOffice

    Feasibility/Position

    development

    Active Implementation Project PDCA

    Risk Register CommunicationsCapital & ResourcePlanning

    Components

    RadarStrategyStrategic

    suppliers and identify

    feasibilities

    List of agreed feasibility and

    position statements

    A full list of active projects and initiatives will be developed

    Pack Coding and Security Features Programme

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    Implementation Programme

    ACTIVE PROJECTS

    Tactics & Strategy

    Development

    Technical/IS

    Delivery Support

    IS System Process

    Establishment

    Equipment Processes

    and Systems

    Product

    Driven

    Market

    Driven

    Data & Intelligence/Market

    Requirements/Technology

    Security

    Features

    Printing on labels &

    shrink sleeving Product A

    Product C

    IV’s Strategy

    France

    Turkey Aggregation

    Feasibility/

    Position

    development

    Tactics & Strategy

    Priority Products I

    Brazil

    SF Database

    Components

    XX Supply Chain

    Established

    Product D

    Product E

    Contractor Pilot

    Global GTIN Proceses

    HUD Position

    Statement

    Semiotics Research/

    Overt Feature of Choice/PF2

    Sweden

    PSDM Strategy

    RFID gap

    analysis/feasibility

    High Speed Line

    Resp & polyamp

    feasibility.

    EU Gap Analysis/US

    Strategy

    China

    Denmark

    South Korea

    Argentina

    Hong Kong

    EU, Switzerland,

    Netherlands and

    Spain

    Product F

    SF Review

    Serialisation and Coding

    Principles

    Includes Market Access

    Support Tools Exploitation

    Product B - India

    Embed Supplier

    Partnership Principles Tertiary Pack TE

    VialsProduct G

    Develop Processes

    Team members

    Pack Coding and Security Features Programme

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    Who FrequencyWhat

    Security Council Quarterly meetingStrategy sign-off

    Product Security Strategy Team Monthly MeetingStrategy

    development/enh

    ancements

    Tactics Team

    Global Implementation Team

    Monthly Meeting

    Monthly Meeting

    Tactics/Global

    Implementation &

    Support

    Security Regional Contact Meeting 6 weekly meeting

    Global Site

    /Regional Tactics

    &

    Communications

    Regional/Site Leadershiptba by Global

    site/Regional lead

    Communications

    /Implementation

    Site Implementation Team(s)tba by Site Team

    LeadersImplementation

    Leader

    VP Supply Chain

    Head of Product

    Security

    Programme Lead

    Regional Product

    Security Lead and

    Regional

    Champions

    Global

    Site/Regional

    Champions

    Nominated by

    Global

    Site/Regional

    Champions

    Governance and Reporting

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    Page 124

    Excellis Methodology : Strategy to Sustainability

    STRATEGY PILOT STANDARDIZATION INTEGRATION ROLLOUT SUSTAINABILITY

    • Process design • Data standards development• Compliance assessment• Technology selection• Pilot implementation

    • Integration framework development

    • Up-stream & Downstream process integration• Data integration

    • Process re-evaluation & standardization• Data standardization• Governance model development• Implementation Template development• Quality framework development• KPI Establishment

    • Global solution deployment

    • Template localization• Site implementations• Site KPI establishment

    • Serialization COE• Internal support model• Best-in-class solution• KPI measurement and

    enhancement• Quality management

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    Page 125

    ▪ Understand the clients’ business model, technologies and capabilities to develop a Strategy for

    compliance with serialization regulations in a timely fashion

    ▪ Deliver a Pilot phase to minimize project risk and ensure the solutions and processes being

    implemented are based on best practices

    ▪ Standardization of the solutions and processes based on Pilot success to be rolled out to the other sites,

    lines and business units. 


    ▪ Integration with both internal and external supply chain partners based on a standardized integration

    framework to minimize risk

    ▪ The solution is then rolled-out to additional lines and sites requiring the capability to meet serialization

    requirements

    ▪ Development of a Serialization Center of Excellence to ensure long term Sustainability

    Excellis Project Delivery Methodology

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    Serialisation As-Is Review1. Strategy• strategic initiatives • current shape of the programme

    • critical elements and company topology

    2. Solution Implementation• existing systems architecture • capability• process design • organization governance

    3. Internal Logistics• internal logistics • warehouse• distribution systems

    4. Partner Integration• CMOs • External Logistics / 3PLs

    5. Coding and Master Data• pack range • labelling• coding • master data• artwork • other security features

    6. Technology Stack• serial number management • edge systems• line engineering • repository / EPCIS• site level • systems integration

    7. Validation / Quality

    8. Programme Management

    • project management • change management

    • risk management

    |---------- As-Is---------- |

    Strategy

    Partner Integrati

    on

    Solution Implementation

    Internal Logistics

    Coding &

    Master Data

    Technology

    Stack

    Validation &

    Quality

    Programme

    Management

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