Serialization Solution Implementation Guide
Serialization Solution Implementation Guide
An Implementation Guide
By Joe Whyte, Global Serialization Lead, Rockwell Automation
Summary
No corner of the world is safe from counterfeit pharmaceuticals. In the United States,
contaminated blood thinner medication killed dozens of Americans and sickened many
more in 2008. In New Zealand, women who bought do-it-yourself Botox on the Internet
in 2011 were disfigured by impurities – including cooking oil – contained in the bogus
injections. In sub-Saharan Africa today, according to the Centers of Disease Control,
an estimated 30 percent of all drugs are counterfeit, and often contain little or none
of the active ingredients patients need to battle malaria, tuberculosis and other
life-threatening diseases.
While the human suffering caused by counterfeit drugs is incalculable, experts estimate
that global pharmaceutical companies lose an estimated $75 billion annually to rogue
dealers, including those involved in organized crime and even terrorist groups.1
That total doesn’t include less tangible but still substantial losses to pharmaceutical
manufacturers from diminished brand value caused by damaged public trust.
By all accounts, trafficking in illicit pharmaceuticals – including
sham, stolen or otherwise diverted prescription medications –
is far more lucrative than selling illegal drugs. The U.S. Department
Pharmaceutical companies of Commerce estimates that a $1,000 investment in counterfeit
lose an estimated $75 billion prescription drugs can result in a $30,000 return – ten times the
profit margin for heroin.
annually to rogue dealers … a
Alarmed by the proliferation of counterfeit medications – as well
total that does not include losses as fake medical devices and contaminated consumer products,
from damaged public trust and such as baby formula – countries around the world are taking
action. Impending regulations aimed at protecting public health,
diminished brand value. intellectual property rights and national security will require
pharmaceutical, medical device and consumer packaged-goods
manufacturers to track and trace products across the supply chain.
Until now, only production-related information, such as the expiration date and lot codes,
has been printed on products and their final packaging. However, serialization –
the application of a unique alpha or numeric identifier on every pharmaceutical package
down to the unit level of sale – is a common requirement among the otherwise disparate
international initiatives scheduled to take effect in the next several years.
These unique identifiers must be stored in a database along with other information
about the item, including manufacturer and batch details. Using unique serial numbers,
the authenticity of items can be verified against the database at every step in the
distribution chain, from the manufacturer to the consumer.
Brazil is leading the serialization charge. All packaging on prescriptions sold in the country
must carry a two-dimensional (2-D) code to enable monitoring from the factory to the
pharmacy – including identification of the individual who purchased a particular drug.
But that’s just Brazil. GS1, an international organization that develops and maintains
standards for supply and demand chains across multiple sectors, has created many
standards to support serialization – down to what a 2-D barcode looks like. GS1’s EPCIS
does provide details on managing and sharing data between parties who have EPCIS
certified systems. However, there is no global agreement on a central or distributed
database or data ownership model.
1
http://www.stimson.org/images/uploads/research-pdfs/Full_-_Counterfeit_Drugs_and_National_Security.pdf
Pharmaceutical Serialization: An Implementation Guide | 3
Human Harm
Nearly a decade ago, the World Health Organization (WHO) launched the International
Medical Products Anti-Counterfeiting Task Force (IMPACT) to “halt the production,
trading and selling of fake medicines around the globe.”2
IMPACT members included international enforcement agencies, pharmaceutical
manufacturers’ associations, and drug and regulatory authorities. Since 2006,
members have collaborated on international criminal investigations, helped countries
strengthen their detection and enforcement systems, and worked with industry to
develop prescription supply-chain protections, such as secure, high-tech
pharmaceuticals packaging.
Still, the number of people harmed by counterfeit, contaminated, stolen and otherwise
compromised medications has continued to grow, along with the sophistication of the
criminals who peddle them.
Using advanced and readily available technologies, it’s easy for counterfeiting criminals
to produce a pill or a vial that looks like the real thing and create copy-cat packaging that
appears authentic.
That was the case in 2012, when the U.S. Food and Drug Administration (FDA) reported
that a counterfeit version of cancer drug Avastin had invaded the U.S. supply chain.
The fake injectable serum – seized mostly from unsuspecting doctors, clinics and
hospitals – contained cornstarch, acetone and other chemicals, but no active ingredient
to fight cancer. 3
2
http://www.who.int/medicines/services/counterfeit/overview
3
http://www.wsj.com/articles/SB10001424052702303879604577410430607090226
4 | Pharmaceutical Serialization: An Implementation Guide
Overall, industrialized countries are less vulnerable to counterfeit prescription drugs than
less developed nations. An estimated 10 to 30 percent of medicines sold in developing
countries are fake, according to U.S. Centers for Disease Control (CDC), but less than
one percent of prescription drugs sold in America, the European Union, Japan, Canada,
Australian and New Zealand, are counterfeit. 4
In the developed world, most manufacturers are diligent about quality control and
adhering to good manufacturing practices (GMP). However, under-regulated wholesalers
and re-packagers are increasingly involved in the prescription supply chain. The explosion
in Internet pharmacies has given counterfeiters unprecedented access into the already
complex and fragmented prescription supply chain.
Case in point is a 2013 analysis by the National Association of Boards of Pharmacy, which
accredits online pharmacies. It showed that 97 percent of the more than 10,000 online sites
selling prescription medications were operating illegally or not following pharmacy laws
and standards. According to the WHO, more than 50 percent of prescription medicines
purchased over the Internet from illegal sites have been found to be counterfeit.
Rogue Agents
Drugs in almost every therapeutic category have been counterfeited, but certain types of
fake medicines are more prevalent in different parts of the world.
In developed nations, counterfeiters tend to focus on expensive lifestyle medications,
such as erectile dysfunction and anti-allergy drugs. In one of many such cases, three British
men were sentenced to prison in April 2015 for selling fake Viagra. 5 The judge in the case
said the men were part of a “highly organized, large-scale criminal enterprise” that used a
bogus mail-order fishing-tackle business to reap an average of £60,000 a week.
In the developing world, counterfeiters tend to target drugs used to fight infectious
diseases. For instance, a 2012 study published in the journal Lancet showed that up to
36 percent of anti-malarial drugs collected in Southeast Asia were falsified, while in
sub-Saharan Africa, a third failed chemical analysis. 6
Counterfeiters aren’t the only rogues in the
The lack of trace-and-track pharmaceutical business.
transparency in the prescription Gray market companies operating outside the legitimate drug-
supply chain leaves open distribution chain buy and sell prescription drugs. “When critical
medications become scarce and are no longer available through
questions about the quality and a hospital’s usual channels of distribution, unscrupulous gray
efficacy of gray market medicines. market distributors have been quick to jump in with inexplicably
As the FDA notes, “It is unknown obtained supplies of these drugs that they are more than willing
to sell to health care providers at exorbitant costs,” according to
how these drugs are stored and the Institute for Safe Medication Practices. 7
handled, or whether they are The lack of trace-and-track transparency in the prescription
expired, counterfeit or supply chain leaves open questions about the quality and
otherwise substandard.” efficacy of gray market medicines. As the FDA notes,
“It is unknown how these drugs are stored and handled, or
whether they are expired, counterfeit or otherwise substandard.” 8
4
http://www.cdc.gov/features/counterfeitdrugs
5
http://www.theguardian.com/uk-news/2015/apr/13/fake-viagra-gang-members-sentenced-criminal-enterprise
6
http://www.thelancet.com/journals/laninf/article/PIIS1473-3099(12)70064-6/fulltext
7
https://www.ismp.org/newsletters/acutecare/showarticle.aspx?id=3
8
http://www.fda.gov/AboutFDA/ReportsManualsForms/Reports/ucm277747.htm
Pharmaceutical Serialization: An Implementation Guide | 5
as the European Federation of In the United States, new requirements for serialization and
traceability under the Drug Supply Chain Security Act of 2013
Pharmaceutical Industries and will be phased in over a decade. At the beginning of 2015, the
Associations, are drafting and government began requiring that manufacturers incorporate
product-transaction data into a single document that is available,
piloting technological solutions to either electronically or on paper, each time ownership is
transferred. By November 2017, that information must be available
meet the serialization mandates. electronically, and the product identifier must be affixed or
imprinted on the label at the product and case level.
By 2023, U.S. mandates will require manufacturers to be able to
exchange transaction information and transaction statements in
an interoperable electronic manner. A full transaction e-pedigree will be defined by the
FDA prior to the required implementation in November 2023.
In the European Union, with the publication of the Delegated Act on safety features in
February 2016, manufacturers have to comply until 2019 with new Serialization regulations
outlined in the Falsified Medicines Directive (FMD).
These changes comprise just the first wave of new track-and-trace legislation.
Pharmaceutical serialization requirements are in various stages of development in more
than a dozen counties from China to Mexico to Saudi Arabia.
9
http://www.cdc.gov/drugoverdose/data/index.html
http://www.gs1.org/docs/healthcare/Joint_Industry_Position_Paper_on_Serialization_and_Product_
10
Verification_Final_November_2013.pdf
11
http://www.healthcarepackaging.com/playbooks/pharmaceutical-serialization-playbook
6 | Pharmaceutical Serialization: An Implementation Guide
Interoperability Challenges
For pharmaceutical companies, these deadlines have created a huge quandary. The
major challenge: While the regulations spell out serialization as the solution to protect the
pharmaceutical supply chain, they don’t specify how to implement a serialization solution.
Aggregation is the relationship between the primary package and every subsequent container or
package used to ship the saleable unit of a prescription drug. In serialization, aggregation is both a
physical relationship and a data relationship. For example, each carton, case and pallet that contains
the unit of sale requires a unique serial number. Those associated serial numbers are collected
in a database, and used to track prescriptions throughout the supply chain, from the point of
manufacture to the consumer.
E-pedigree is a chain-of-custody document that identifies each prior sale, purchase or trade of a
drug, including the date of those transactions, and the names and addresses of all parties involved.
Electronic data interchange (EDI) is the transfer of data from one computer system to another by
standardized message formatting, without the need for human intervention. EDI permits multiple
companies – possibly in different countries – to exchange documents electronically. It is the most
common method used by drug makers today to share serialization information and serialized
content-to-container relationships with trading partners.
Electronic Product Code Information Services (EPCIS) is a GS1 standard that enables supply-
chain partners to store and share physical event data, including the what, when, where and
why about physical observations (events), independent of the technology used to capture that
information. This allows companies to associate and share additional information, or events, relating
to an object’s identity. For example, companies can associate information, such as the time and date
that a bar code was scanned or an RFID tag was read, the location of that scan/read, and whether
the object was being shipped or received. 12
There also is not an agreed-upon data format for capturing aggregated track-and-trace
information and sharing it among multiple trading partners in the global supply chain.
Within the four walls of the factory, implementing the new regulations requires tracking
at every stage in the end-of-line packaging process down to machines, printers, labelers,
bar-code scanners and vision systems.
Pharmaceutical Serialization: An Implementation Guide | 7
At each stage in the finished goods packaging process, a unique serial number –
represented by a 2-D barcode or RFID tag – must be applied to the product’s package.
Depending on the industry or customer need, there can be up to five levels of parent/child
aggregation, with serial numbers applied to the item level or unit dose, up to the pallet.
The unique serial number at each stage in the packaging process must be married to all
the unique serial numbers contained in the package. Therefore, each pallet serial number
(parent) is paired to all the unique case serial numbers (children) on the pallet, creating
the aggregated parent/child relationship. Likewise, each case
serial number (parent) is paired to all of the unique carton serial
The unique serial number at each numbers (children) that are in the case, and so on.
stage in the packaging process Accurately applying and associating these new and complicated
sets of individual identifiers poses interoperational challenges for
must be married to all the unique many drug makers. That’s because historically, pharmaceutical
serial numbers contained in companies have invested in “black box” solutions at the
the package. packaging-line level. Those can include unique hardware – such
as their own versions of printing and vision systems – as well
as custom software drivers, custom application software and
proprietary networks.
For data generation and acquisition, serialization is complicated by the massive need for
unique applied numbers (preferably randomized), the high volume and speed of the
data-handling process, and the wide range of products, formats and country requirements.
Serialization also adds extra layers of information that must be integrated into existing
production processes and information systems. Information must flow between control
systems, manufacturing execution systems (MES), enterprise resource planning (ERP)
systems, inventory management and supply-chain systems.
Beyond the pharmaceutical plant, products can change ownership as many as 10 times
within the supply chain before reaching patients. 12 These transition points in the supply
chain are essentially the vectors of attack for anyone sophisticated enough to steal or
otherwise divert prescription drugs from the legitimate supply chain. 13
Effectively meeting the new government mandates will require a holistic serialization
solution to track and trace prescription drugs through the entire supply chain.
Today, electronic data interchange (EDI) is the most common method used by drug
makers to share serialization information and serialized content-to-container relationships
with trading partners. However, EDI file-sharing wasn’t designed for tracing supply-chain
event data. It has no query mechanism, no exceptions processes, no global format, and
most important of all, it is not extensible without Standards action, which would require a
multi-year process. Extensibility is a software design principle defined as a system’s ability
to have new functionality extended, in which the system’s internal structure and data
flow are not affected, an essential element if a platform is to adapt to new and emerging
regulatory requirements. EDI doesn’t amount to much more than a text file combined with
an advance shipping notice, much like how consumers track their FedEx packages today.
GS1 has developed EPCIS to overcome shortcomings with EDI and accommodate the
growing volume and complexity of data required by emerging serialization legislation.
EPCIS enables supply-chain partners to store and share physical event data, including the
what, when, where and why of events, independent of the technology used to capture
that information. 14
12
http://www.pharmacompliancemonitor.com/global-pharmaceutical-product-serialization-taking-steps-against-
counterfeiting/8831/
13
http://www.healthcarepackaging.com/playbooks/pharmaceutical-serialization-playbook
8 | Pharmaceutical Serialization: An Implementation Guide
This allows companies to associate and share additional information, or events, relating to
an object’s identity. For example, companies can associate information, such as the time
and date that a barcode was scanned or an RFID tag was read, the location of that scan/
read, and whether the object was being shipped or received.
Ultimately, as a product is scanned through the supply chain, if a serialization identifier
shows up somewhere else in the system, it’s a red flag that there’s a counterfeit in the
market. This enables manufacturers to take action before it gets into the hands of
the consumer.
The system integrates with EPCIS certified supply chain repositories to specifically meet
serialization regulatory requirements.
14
http://www.gs1.org/docs/GS1_Anti-Counterfeiting_White_Paper.pdf
Pharmaceutical Serialization: An Implementation Guide | 9
Here’s how the holistic Rockwell Automation solution works at each level of its ISA-95
aligned data model:
Level 0, according to the traditional ISA-95 standard, is the device level that includes
pieces in the packaging machine, such as vision systems, printers and radio-frequency
identification (RFID) systems.
The Rockwell Automation solution expands Level 0 to include
the packaging machine itself, which was separate at Level 1 in
the traditional ISA-95 model. This modification keeps all the
Free of proprietary equipment equipment responsible for packaging the product on the same
level. To ensure all the machines and their components operate
and networks, pharmaceutical seamlessly – and allow the solution to be scalable and
producers can choose from repeatable – all the physical assets are commercial off-the-shelf
(COTS) technology.
a wider selection of OEMs for
Separating the machine functions from the data functions not
troubleshooting or repairs. only creates a consistent information solution – it also empowers
OEMs to deliver serialization-ready machines without the
complexities entailed in adding IT data capabilities. With the
Rockwell Automation solution, the machine-controller level
isn’t responsible for managing data or generating serialization identifiers as they do on
many existing packaging lines. The Rockwell Automation solution keeps those critical and
increasingly sophisticated data functions above Level 0.
A side benefit for packaging-machine end users: Free of proprietary equipment and
networks, they can choose from a wider selection of OEMs, Systems Integrators and
Solution Providers to provide and integrate Level 0 devices and packaging machinery
or to provide deployed system repairs or troubleshooting support services.
10 | Pharmaceutical Serialization: An Implementation Guide
Reverse-Logistics Benefits
A holistic and interoperable serialization solution can deliver reverse-logistics benefits from
more accurate and efficient recalls to improved forecasting and more customer-specific
marketing programs.
For example, imagine a pharmaceutical company discovers a supply-chain partner did not
store a specific ingredient for a drug at specified temperature or humidity levels. Today, the
producer would need to review data to understand which batches were impacted. They
would likely add the previous and trailing batches to the recall to be safe, determine which
pallets those were shipped out on, and guesstimate what happened to those pallets after
they were received by a third party. They would need to rigorously publicize the recall and
impacted batch numbers to ensure product was not consumed as they couldn’t directly
contact the point-of-sale outlets.
With a holistic serialization solution, the producer could use the data thread to track
backward along their distribution chain. They could quickly and easily utilize their cloud-
based data repository to determine which cases or packages were on pallets that shipped,
as well as where they were shipped from there onto the final point of sale. Those retail
outlets could be contacted directly to remove the damaged product and only the
damaged product from the shelves. If the point of sale had information on the consumers
who purchased the damaged product, they could potentially reach out to the consumer
directly to prevent any complications from the defective medicine.
But the solution offers more than this. Pharmaceutical innovators are following initiatives
like the Smart Manufacturing Leadership Coalition, Industrie 4.0 and China’s Manufacturing
Intelligence 2025. Admittedly, though, many don’t yet have a clear strategy in place to
operationalize these initiatives.
Pharmaceutical Serialization: An Implementation Guide | 13
Success today requires greater process knowledge – the kind locked deep inside
production systems. Accessing that data and converting it into useful information can yield
tremendous benefits, but information alone isn’t enough.
Cross-departmental activity between plant-floor and front-office systems has become
particularly necessary in the life sciences industry, as tracking and reporting has evolved
from a nice-to-have to a must-have. Rockwell Automation refers to this as The Connected
Enterprise. It’s the creation of a unified control and information system architecture to
harness production intelligence and improve operations across the product life cycle –
from formulation to factory.
Because the new Rockwell Automation holistic serialization solution is fully integrated
across the supply chain, all enterprise and control system levels, and potentially directly
to the customer, its common serialization data thread provides real-time visibility to
a company’s products and customers. What pharmaceutical producers can do when
empowered with this information is only limited by their imagination.
Resources
Rockwell Automation
Joe Whyte
Global Serialization Lead
700 Lanidex Plaza
Suite 7102
Parsippany, NJ 07054
Mobile: 973.768.3617
E-mail: jwhyte@ra.rockwell.com
http://www.rockwellautomation.com/sites/rockwellsoftware/applications/product_serialization.page
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Publication LIFESC-WP001C-EN-P – October 2017 Copyright © 2017 Rockwell Automation, Inc. All Rights Reserved. Printed in U.S.A.
Supersedes Publication LIFESC-WP001B-EN-P – April 2017