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Serialization - Challenges and Good Practice in Packaging Operations Eptember 2021
Serialization - Challenges and Good Practice in Packaging Operations Eptember 2021
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2.0 Glossary................................................................................................................................................................................................ 9
3.1 Considerations for reducing the impact of serialization and aggregation on OEE and system performance... 11
3.1.7 Using serialization OEE data management for continuous improvement ...........................................................19
References.......................................................................................................................................................................................................30
Table 2: High-level print technology comparison and the impact on OEE ................................................................................................................................................................................................ 12
List of figures
Figure 1: Serialization and aggregation packaging steps...................................................................................................................................................................................................................................... 7
Figure 4: Recommended typical automated case packing aggregation flow sales unit to shipper case ....................................................................................................................................... 15
Figure 5: Recommended typical semi-automated aggregation flow sales unit to shipper case........................................................................................................................................................ 16
Figure 6: Recommended typical automated bundling aggregation flow sales units to bundle.......................................................................................................................................................... 17
Figure 9: Example from a major pharmaceutical company’s internal SOP describing how local and global roles and responsibilities correspond to the
L1–L5 system and required training........................................................................................................................................................................................................................................................................... 27
T&T of pharmaceutical products through the supply chain industry still faces a number of technical challenges and
has become a common health authority requirement, dating limitations relating to regulatory expectations, with
back to Turkey in 2010 (see Table 1), even if not yet globally many pharmaceutical companies around the world still
standardized. Regulations around this topic are needed to transforming their packaging operations to meet them.
ensure that systems are in place to determine the authenticity
In response to these challenges, the BioPhorum Secondary
of medicines and to improve distribution compliance.
Packaging Team completed an industry benchmark on
An important benefit of T&T systems is to make counterfeiting
the serialization of sellable units. The purpose of this
harder. According to WHO estimates, counterfeiting of
benchmark was to identify common industry challenges with
medicines is responsible for one million deaths annually and
serialization and to broaden the knowledge of good practice,
10% of all drugs sold globally are fake. Global events such
industry capabilities and to identify the quickest route to
as the COVID-19 pandemic further increase these risks by
implementation and compliance with global serialization
disrupting the supply chain and increasing internet purchases2.
requirements (see Table 1). The benchmark was completed
The introduction of T&T regulations has driven specific in 2020 by 11 pharmaceutical companies and covered the
changes to industry packaging practices. Digital information following topics: governance, training, grading of print, overall
related to the drug has become a major quality-relevant part equipment effectiveness (OEE), decommissioning of serial
of the drug packaging process. UPIs must be applied, verified numbers, technology limitations, primary unit serialization
and transported together with the medicines. Any data and non-standard requirements.
discrepancies between the manufacturing and dispensing
The results of the benchmark survey were reviewed by the
of the drug will result in the product being suspected a
11 participating companies together with the additional
counterfeit and will lead to detailed investigation.
pharmaceutical companies in the BioPhorum Secondary
This paradigm shift has triggered considerable modifications
Packaging Team. This paper provides an overview of
to drug packaging processes and technologies. While
points to consider and good practices relating to the most
the purpose of most T&T regulations is primarily to fight
challenging areas identified during two workshops, in May
counterfeiting, additional uses, such as the fight against
2020 and in December 2020. The four most challenging
tax fraud or use for custom controls, introduce additional
areas discussed within the scope of this paper are: OEE and
non-related requirements that often do not follow
system performance; technical limitations; decommissioning
international standards. These non-standard requirements
of serial numbers; and training. This paper seeks to encourage
influence the technical requirements and established
dialogue between industry, regulatory agencies and T&T
processes in pharmaceutical operations, adding additional
system providers, by adding the unique perspective of the
complexity and challenges to the implementation and use
secondary packaging customer, summarized after several
of serialization on packaging lines. More than 10 years after
years of using such serialization systems.
the first introduction of serialization, the pharmaceutical
Brazil Full track and trace 2022 GS1 standards endorsed (with ANVISA registry number to be encoded in the
DataMatrix in addition to GTIN)
China Full track and trace 2019 Revised regulation now endorses ISO-compliant standards (including GS1)
beside existing China e-code system
Ecuador Full track and trace 2021 (phased GS1 standards endorsed
approach)
EU – Falsified Point of dispense verification 2019 GS1 standards endorsed (with few countries requiring National Health
Medicines Directive Reimbursement Number to be encoded in the DataMatrix in addition to GTIN)
India – DGFT Full track and trace 2016 GS1 standards endorsed
requirements (export)
Indonesia Full track and trace 2021 (phased GS1 standards endorsed for prescription medicines (authentication)
approach)
Russia Full track and trace 2019–20 Unique crypto key and crypto code issued by Russian agency must be encoded
in the DataMatrix
Saudi Arabia Full track and trace 2020 GS1 standards endorsed
South Korea Full track and trace 2015 GS1 standards endorsed (with Korea Drug Code embedded in the GTIN)
(with optional aggregation)
US – Drug Supply Chain Full track and trace 2018–23 GS1 standards endorsed (with US National Drug Code embedded in the GTIN)
Security Act (DSCSA) (phased
approach)
Key takeaways
• he introduction of T&T regulations has driven specific changes to industry packaging practices. Digital
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information related to drugs has become a major quality-relevant part of the drug packaging process. This
paradigm shift has triggered considerable modifications to drug packaging processes and technologies.
• ore than ten years after the introduction of serialization, the pharmaceutical industry still faces a number
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of technical challenges and limitations relating to regulatory expectations, with many pharmaceutical
companies around the world still transforming their packaging operations to meet them.
• he top four challenging topics/processes related to serialization discussed in this paper are: OEE and
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system performance; technical limitations; decommissioning of serial numbers; and training.
Theoretical
Quality loss Speed loss
run time
Produced quantity
(1) Theoretical run time =
Theoretical speed
Expenditures, print quality, light resistance, No impact No impact No major/significant impact on OEE.
print quality human readable
Dust - + Laser causes dust, due to ablation of the paint or varnish from
the material, which could cause the line to stop more often for
cleaning. Alternatively, it requires installation of a dust-extraction
system, which impacts the need for available space.
Cardboard requirements - + Laser requires more sensitive and constant cardboard quality (high
kaolin content) to ensure good print quality and low reject rate.
Line speed - + Inkjet allows higher speed of the conveyor belt (> 40m/min).
Maintenance needs + - Laser is generally more stable in terms of performance while inkjet
requires more maintenance (i.e. replacing the ink cartridges).
2: The manual handling of rejected products requires Whenever possible, and if the business case makes sense,
operators’ training and solid procedures. A typical the replacement of any manual aggregation process (e.g.
manual scanning) with aggregation per automated case
example is a product rejected by the print and
packer should be considered. There are several advantages
check equipment but considered good after
to, and positive impacts on, OEE of doing so. For example,
human inspection. If this could be considered
by implementing aggregation per automated case packer,
acceptable in a non-serialized environment, it the bundling process step could be eliminated, as bundling
becomes critical in a serialized one. is usually in place when case packing is a manual operation.
Table 3 lists some aggregation equipment changes and the
potential impact on OEE. Figures 4 and 5 provide a typical
automated case-packing aggregation flow sales unit to
shipper case and a typical ‘semi’-automated aggregation
flow sales unit to shipper case as recommended by the
authors of this paper.
• I mplementation of automated case packer (side loader) Increase of output and labor reduction
and elimination of bundling step
• Implementation of pack by layer concept Increase of output and reduction of data integrity issues caused
by human errors during scanning
Aggregation of shipper cases to pallet (manual option) In this scenario, the operator begins the process by
opening a new pallet on the pallet controller application
Automated palletizing of shipper cases and pallet
running on the mobile computer, usually using a hand-
aggregation are possible if automated equipment is
held scanner. When a pallet is opened on the mobile
available and fully connected with the serialization
computer, the operator scans the serialized code on the
system. This scenario is considered the best option in
case and places the cases on the pallet. The operator
regard to OEE as it renders the operator’s intervention
repeats this process until the pallet has reached capacity
minimal (only required when a partial pallet needs to
or until the last case has been added to the pallet (see
be closed) and reduces any opportunity for human
Figure 7). The pallet is automatically closed once the
error. When there is not a business case for automated
pallet has reached full capacity. Partial pallets can be
aggregation, then manual palletizing supports manual
manually closed on the mobile computer. For applications
pallet aggregation on the packaging line. In terms of OEE,
that require an online pallet label printed, the packaging
this option is not as good, but there are considerations
module downloads a unique serial number to the pallet
and a recommended typical process flow that can help
printer when the pallet is closed.
increase OEE for this scenario.
3.1.5 Considerations for system design for deviation management process may also require an
serialization and aggregation update to include the necessary steps to facilitate the
management of discrepancies related to serialization/
The GAMP® 5 ISPE standard provides pragmatic industry
aggregation and, by extension, the impact on the OEE.
guidance towards achieving compliant, computerized
Serialization-related discrepancies are most likely to be
execution systems that are fit for intended use. This
found during the reconciliation process. Reconciliation
standard describes a flexible, risk-based approach to
is a fundamental stage in the pharmaceutical finished
compliant GxP-regulated computerized systems, based on
goods packaging process that ensures all regulatory
scalable specifications and verification. GAMP® 5 provides
requirements for distribution and sale of a medicine
guidance to ensure that the serialization and T&T systems
are met. As part of good manufacturing practices
(L3/L2 systems) used for routine packaging activities are
(GMP), reconciliation ensures that the correct number
maintained in a validated state throughout the lifetime of
of finished goods materials have been used during
the system. It also requires that the system has controls
production. Serialization reconciliation ensures that
in place to ensure the integrity of the data managed
serial numbers are used correctly for finished products
by the system, enabling delivery of the correct market
with traceability in each phase of the pharmaceutical
UPI requirements from a technical perspective. Before
packaging process, beginning with the generation
applying GAMP® 5, it is essential to describe all roles and
of serial numbers, and ending with the supply of
responsibilities, and to ensure that these are aligned across
serialized, finished goods to the market. The deviation
functional departments and systems. This also serves as
management process in a pharmaceutical environment
a baseline for a role-based and focused training approach
is normally led by the quality department. Since the
described further on page 27.
introduction of serialization, additional resources
3.1.6 Considerations for deviation management from information technology, production, technical
for serialization and aggregation operation and engineering have also played an
important part during deviation investigations and
After considering requirements for implementation of
in resolution processes.
serialization and aggregation on packaging line(s), the
Key takeaways
• undamental changes to the technical configuration of manufacturing lines and packaging processes
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require potential investment of around $100,000 or more.
• he lack of global standardization of T&T requirements means that systems cannot be designed in a
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future-proof way. Future requirements can very quickly outgrow the capabilities of installed hardware,
driving further investments to keep systems current. Continuing dialogue between regulatory
agencies, pharmaceutical industry and system suppliers is essential to ensure readiness for the future,
patient safety and to keep costs to healthcare systems low.
• ith respect to regulatory requirements, commonly accepted approaches decrease the risk of failures,
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reduce the cost of implementation and ultimately improve patient safety.
• I ndustry is striving for standardization of regulatory requirements; the GS1 standards are widely
endorsed by the healthcare industry.
• Reduction of systems complexity should be a priority. Different systems must be able to exchange
data in a safe and error-free way. A full implementation of standards defined by GS1 and Open-SCS to
facilitate optimal system design and integration is needed3, as well as co-existence of multiple vendors
within one packaging site10.
5.2 100% reconciliation options (i.e. after destruction or consumption of a product) and
is an important part of the serialization reconciliation
and challenges process11. Usually, decommissioning of the serial numbers
According to a requirement of the EU regulation of the printed on to a folding box takes place at the location of
Falsified Medicine Directive (FMD) Q&A document sale or point of dispense. This can be at a public pharmacy,
(version 18 question 8.6): “serial numbers that are not a hospital or a wholesaler. However, during packaging
actually used as data elements in unique identifiers should and application of this unique identifier on to the folding
not be uploaded and stored in the repositories system as box, damage or loss can occur as well. If, at that moment,
they represent a security risk for the system.” the serial number has already been applied to the folding
For many companies, interpretation of this Q&A has box with the status ‘active’, the serial number on this
led to an assumption that the number of serial numbers folding box needs to be decommissioned. The majority
which are not accounted for should be close to 0%. of current systems for manufacturing serialized (not
In other words, 100% reconciliation. The reconciliation aggregated) product are not able to perform automated
requirement is essential in order for effective safety 100% decommissioning of all lost packages from one
features and counterfeit detection. However, the batch. Therefore, 100% reconciliation on lines without
statement in the EU FMD Q&A leaves room for aggregation is a manual or semi-automated task; this
interpretation and discussions are ongoing as to is time-consuming and can have lines not running for
whether the translation of a goal of non-accounted hours. If an additional decommissioning or aggregation
serial numbers close to 0% is accurate. is not performed, all numbers produced are reported
to regulatory repositories, i.e. the numbers released to
Decommissioning is the act of documenting the
regulators/repositories are correct but only a percentage
disassociation of a unique identifier from a specific
of the numbers are in the market due to unaccounted
instance of an object class, typically when the object no
losses, for example QC samples.
longer exists or reaches the absolute end of its life cycle
Key takeaways
• he statement in the EU regulation of the FMD Q&A document (Version 181 question 8.6) leaves room
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for interpretation and discussions are ongoing as to whether the translation of a goal of non-accounted
serial numbers close to 0% is accurate. Many companies interpret this as 100% reconciliation.
• Aggregation of serialized products can eliminate the need for decommissioning of serial numbers by
the manufacturer, but 100% aggregation requires costly line upgrades and is often weighed against the
fact that only some countries require aggregation.
• egardless of whether a company performs 100% manual reconciliation or uses aggregation, and in
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terms of the OEE, the percentage of loss should be continuously reduced, good line design is the best
option and key to avoid damage or loss and the need for decommissioning in the first place.
Level 5: Global-level software and system that enable management of all serialization
and regulatory data with partners, customers and regulatory authorities
Level 2: Production line software and systems that manage devices that serialize and pack
product and support device integration with site systems for conducting warehouse operations
Training is an area of serialization with which the industry training for many of the supplied markets. Any training
is struggling. There are aspects of serialization that are for serialization needs to reflect these aspects and, just
highly technical and elements of the process that are both as aseptic processes have specialized training, the same
virtual and practical. In addition, variability in intentional should apply for serialization.
regulation has led to various technical requirements from
The best-case scenario would be that specific
health authorities in different markets. This, in combination
requirements for markets should be standardized so that
with a lack of industry standards, has led to the need
an operator on the line does not need to be trained on
for different requirements for serialization training for
market specificities. Given that this is not the current state,
functions at different sites. For example, training for one
the following sections have been written with existing
market’s serialization requirements does not apply to every
variabilities and all system levels in mind (operators,
market and it is therefore necessary to develop specialized
regulatory, etc.)
Figure 9: Example from a major pharmaceutical company’s internal SOP describing how local and global roles and responsibilities correspond to the L1–L5 system
and required training
Key takeaways
• training plan has to be available for each company role/position that interacts with the L1–L5 systems
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and existing curricula should be updated with additional training required for serialization/aggregation.
• eveloping experts in serialization/aggregation processes should be part of the overall training goal, to
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adjust for lack of experience of training for serialization in the industry.
• ue to market variability and frequent system updates, periodic or corrective retraining is highly
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recommended and systems need to be established that will successfully identify when retraining needs
to be performed.
• ince serialization processes on the line include a range of different activities, the training team should
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be multidisciplinary to cover the range of topics required related to IT, quality, engineering, automation
and production.
• Certifiable exams can help showcase transferable industry knowledge and will motivate trainees.
• dedicated training facility or line for L1–L3 level training is recommended to avoid unwanted
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production downtime.
https://doi.org/10.46220/2021FF002
Disclaimer
This document represents a consensus view, and as
such it does not represent fully the internal policies of
the contributing companies.