IMPLEMENTATION TIMELINE
2015 HANDBOOK
Pharmaceutical
Serialisation &
Traceability
Brought to you by
TABLE OF CONTENTS
Foreword
3
Timeline Overview
4
Pre-Implementation Phase
5
Execution Phase
9
Multi-Site Implementation Phase 10
Post-Implementation Phase
13
Acknowledgements 14
Foreword
Following the release of the EU Falsified Medicines Directive in 2011, the pharma
market is in the process of becoming fully serialised ahead of 2018s deadline.
Market players currently stand at different stages of the implementation process:
Some yet to implement, some mid process and others at the final stages -
sharpening their strategy.
All firms should aspire to execute a sustainable approach to serialisation,
however the specific implementation strategy remains to be determined on a
company-by-company basis.
Michael Kinsella Industrial Operations Deputy Director at Servier said: Breaking
the project into manageable sections and [having] a modular approach is the
essential way to manage it and to not to forget about the long term costs of each
module.
There are plenty of company decisions, not only industry decisions, about what
kind of organisation will be required in each company. And this question can only
really be answered by each company, because each company has a different type
of supply chain or a different size or a different philosophy. So, theres really a lot
of work to be done on the strategy of the long term maintenance and ownership
of this new profession in the pharmaceutical industry.
In the absence of a one-size-fits all-approach, after consulting with industry
experts, Pharma IQ proposes this framework for key milestones within a
sustainable serialisation strategy - in which firms can choose customize in
relevance to their requirements.
NOTE:
This article and its contents are intended for educational and insight purposes and should not be taken as professional advice.
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Timeline Overview
Pre- Implementation Phase
v Initial Approach: Engage with
stakeholders and initiate a program
v Awareness: Acquire understanding
on key challenges and requirements
v Strategic Engagement
Execution Phase
Pilot Initiation c
Validation c
Multi-Site Implementation
Post - Implementation
SERIALISED
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Pre- Implementation Phase
AWARENESS:
Acquire understanding on key challenges and requirements.
This awareness will help firms foresee the condition of the road ahead, allowing them
Execution Phase
KEY CONSIDERATIONS:
Multi-Site Implementation Phase
Fraud Identification
The driving objective behind serialisation of course is to identify counterfeit items,
on this matter, Michael Kinsella notes that the following considerations should be
answered:
What if we do find false products? What are the processes and how will this project
specifically help in detection or dissuasion of those counterfeit products?
He adds, At the moment, were very much all hands to the pump to get the solution
in place but the end game of this, in the spirit of the law, it is to have authentic
product on the market and to be able to verify that as authentic. So, if you find [an]
inauthentic product, how can you use this system to speed up the response to the
authorities? How can the data be exploited in a way that it can be proven to be
beneficial?
Potential Challenges
Post - Implementation Phase
Michael Kinsella notes that challenges can be expected in the transition and
maintenance of the operational efficiency of factories.
1. The long term day-to-day impact on the new process: It may take longer to
produce a typical work order or to complete a changeover.
2. Operational impact from transition: Not all lines may be equipped at the same time
causing issues with planning in factories where some lines producing for a product
may be out of service for a few weeks because of the aggregation installation.
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Pre- Implementation Phase
DONT FORGET
Harmonisation:
There could be opportunities in the project to reduce or to automate some activities
for operators.
Michael Kinsella notes:
Execution Phase
v For example, if you print on every box and verify the print is correct then we can
eliminate the human check for the print which could reduce the risk of a human
error because 100% of the boxes will be checked automatically.
v Do you need to have a physical check to count the number of boxes in an in-
process quality control? Consider whether harmonisations of quality checks to
check the number of boxes can be scheduled to happen automatically if you
have aggregation.
STRATEGIC ENGAGEMENT:
Multi-Site Implementation Phase
Provide a definitive roadmap and strategy which accounts for the projects long term
financial impacts.
KEY CONSIDERATIONS
Elements to define
v Code grading - Integrating as much data as possible into code.
v Returns- An expensive aspect which some in the industry shy away from
discussing, however its a key aspect to prepare for.
v Security issues - How will you secure the data
v IT Infrastructure
THINGS TO AVOID:
Post - Implementation Phase
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Pre- Implementation Phase
KEY CONSIDERATIONS
the third phase. Consider Developing unique URS documents for business units - Bill
Fletcher reminds that in very large companies with different business entities, it may
be necessary to develop different URS at each of those levels for specific business
units.
DONT FORGET
Detail is Vital:
Bill Fletcher provides insight on how vital this stage isin avoiding possible failures
down the line.
He states: What I often see as a failure in some of the projects that Ive come into
after theyre partway through the project, is that the user requirements were simply
too vague or too or too focused on a specific solution brand. The URS failed in
their ability to precisely measure and contrast the various solution offerings, and
so unknowns crept into the project and were discovered later on in the project,
Post - Implementation Phase
requiring additional systems to be acquired. They might have prevented that and the
delay if the requirements were more measurable earlier on.
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Pre- Implementation Phase
KEY CONSIDERATIONS
Execution Phase
fulfill your requirements, Bill Fletcher states that firms should contemplate developing a
cap analysis and locate solutions to cover that business need.
THINGS TO AVOID
IT solutions that impose restrictions
Michael Kinsella explains: A key aspect in our project is that were looking for
solutions that are connectable. IT solutions that are connectable, but they dont
impose certain connections to other pre-defined systems. The idea of connectivity
is very important and gives you the ability to have a modular approach - you could
have a system which is scalable.
FUNCTIONAL SPECIFICATION
Once the vendors have been selected and contracts executed, then its a common
practice to develop a functional specification- a document that takes the user
Post - Implementation Phase
requirements that work for the business, and compares them to the capabilities of the
commercial solution. Following this, the commercial solution is then examined for ways
it can be configured to meet specific business requirements. This document allows you
to identify any areas where the solution doesnt fully align with all of the needs, and then
look for alternative separate solutions to accommodate those gaps.
Bill Fletcher points out: Its a good practice because you can identify problems before
youre committed to actually acquiring and installing and configuring the system.
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Pre- Implementation Phase
Execution Phase
PILOT INITIATION
Initiate a pilot program using one line, with a view to iron out all issues prior to full
implementation.
The functional specification is applied to install, configure and test the chosen
solutions.
Integration tests can be conducted between all of the various systems: The
enterprise, the packaging and warehouse systems.
Execution Phase
DONT FORGET
To go forwards, you may have to look back In the opinion of Bill Fletcher: During
the cycle, at any time from selecting the vendor on, you may find that theres a need
to go back and acquire other systems, or you may find that the solution that was
selected did not meet the requirements as promised or as expected, and so theres
Multi-Site Implementation Phase
VALIDATION
Validation is a common practice in life sciences. It looks to confirm the solution
meets the desired needs consistently and in a low risk fashion. After this stage, the
solution will typically go live.
Validation refers to the functional requirements and the user requirements, it simply
asks questions on whether this solution accomplishes the particular business
requirement.
Post - Implementation Phase
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Pre- Implementation Phase
CASE SNAPSHOT
Michael Kinsella mentioned about how Servier started the process of placing the
printing and verification machines in France back in 2010 which was a key first step
in the global serialisation programme for Servier.
Execution Phase
We started to print static Datametrics codes on all of the French products and
to do this we had to equip all of the production lines that are in France, about 22
production lines, and also some production lines which are producing outside of
France but for the French market. We decided to pick one type of printing and
verification machine which was developed and tested specifically for France
Looking ahead, Michael Kinsella forecasts: Before 2018, we will have responded
to the Korean, Chinese, Brazilian, Saudi Arabian [markets] and maybe some other
Multi-Site Implementation Phase
small markets like India. When Europe comes, at the end of 2018, we should be fully
operational to be able to generate reports in all of those markets.
KEY CONSIDERATIONS
Harmonisation is Key
Experts note that the key is to have as much harmonization in the factory as possible.
He adds: Also, there will be harmonisation of certain processes; certain process like
labelling is a very important aspect, [to] have harmonised: A way to generate labels
and to generate aggregation labels in particular. That can be done [according to the
respective] international standards, but you should have a central governance of
some kind to ensure that the labels are managed in a harmonised way.
Post - Implementation Phase
Copy and Paste Formula to production- Michael Kinsella mentions how all Servier
factories have the same software, same printing machine and theoretically the same
philosophy for aggregation. Almost a kit that will be put on top of all the case
packers that exist in the factories. All case packers are not identical but the function,
the process and the number of devices that we used will be copy and pasted.
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Pre- Implementation Phase
KEY CONSIDERATIONS
Managing localization:
A small level of slight variations may occur from site-to-site that has to be managed.
This localisation factor may arise due to language, IT architecture, geography or the
physical structure of the factory.
Michael Kinsella reminds, however, that once this system goes into place it should
all lean towards a central management or a central expert group that can help and
support all sites and maintain as much harmonisation as possible in factories to
simplify the maintenance required and to allow for experience sharing.
Post - Implementation Phase
DATA COMMUNICATION
In regards to the central data management functions outside of factories, Michael
Kinsella notes that this entails the consolidation of all of the reports and the links
between distribution chain, wholesalers, logistical partners or production partners
and, of course, with the markets or the government agencies, via a corporate
repository system.
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Pre- Implementation Phase
KEY CONSIDERATIONS
Data Pooling:
As the amount of countries increases that you are fully serialised within, a
centralised service for data reporting to markets should be able to function in
alternate directions. In Michael Kinsella experience the explains that this assists with
receiving numbers when his firm acts as a CMO for other companies and also for
sending numbers from factories when numbers are generated internally and then
sent outside.
Multi-Site Implementation Phase
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Pre- Implementation Phase
KEY CONSIDERATIONS
Fluid Communication:
Execution Phase
On this matter Michael Kinsella notes: I would say that theres a lot of communication
to be done internally. No matter who leads the project, it is easily a half or a full-time job
for one person to communicate constantly within the company to explain the impact
and to be ready for the questions that will come. He notes that queries are likely to be in
connection to:
v A report not being sent,
v A report being corrupt,
Multi-Site Implementation Phase
DONT FORGET
Be Open to Flexibility:
Alex Ulbrich spoke of a similar situation in regards to a cloud based solution
implemented at his firm, due to issues with process compatibilities with the internal
validation department, they had to switch back to internal communications and decide
on a new route.
NEW OPPORTUNITIES:
This step is focused on utilising the advantages of the serialisation process beyond the
objective of compliance.
Post - Implementation Phase
Data Optimisation:
A lot of present discussion in the industry is around exploring the ways in which
serialisation data could be useful. Specifically:
v In assistance with enabling targeted product recall.
v Helping with stock management in the future. Informing operators of what numbers
are where.
v Understanding the authenticity and movement of the product to create a more
refined manufacturing process
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Pre- Implementation Phase
SERIALISED
Execution Phase
ACKNOWLEDGEMENTS
Thanks to all specialists that assisted with the research for this project. Including more
specifically Bill Fletcher of Pharma Logic Solutions, LLC, Alexander Ulbrich of Vetter
Pharma and Micheal Kinsella of Servier.
Multi-Site Implementation Phase
RESEARCH SOURCES
http://www.gxpsystems.com/services-serialization.html
http://www.domino-printing.com/Global/en/DocumentLibrary/The-Hidden-challenges-
of-Pharmaceutical-Serialisation.pdf
http://pharmaceuticalcommerce.com/special_report?articleid=26841
http://ec.europa.eu/health/files/falsified_medicines/2012-06_safety-features/efpia-eaepc-
girp-pgeu_en.pdf
http://www.pharma-iq.com/regulatory-legal/articles/pasi-kemppainen-on-implementing-
serialisation/
http://www.pharma-iq.com/regulatory-legal/articles/how-to-successfully-use-anti-
counterfeiting-techno/
Post - Implementation Phase
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Whether the final
delegated acts are
announced next week or
next year, the fact remains
that planning a sustainable
strategy will determine
your commercial success
as an organisation.
t Standardise your serialisation process across multiple sites to save costs and
create flexibility with insight from Teva.
t Digitalise your serialisation data: Utilise data commercially with Mercks cutting
edge case study
t Hear directly from EMVO, GS1, Ministry of Health & Welfare, Republic of Korea;
regulators and associations will give critical regulatory updates to ensure you
are up to speed with the imminent deadlines
t Spark key conversation around group integration and strategy with Vetter
Pharmas strategic panel discussion: Exclusive project team panel discussion
with IT, project strategy and commercial teams.