Rx-360Upstream Supply Chain Security
A Supplier Collaborative Approach to
Mitigate Risk and Enhance Transparency
www.Rx-360.org
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Presenter:Rob Welsh, VWR International, LLC
VP Category Management – Production Chemical Operations Co-Chair Rx-360 Supply Chain Security Steering Committee Co-Chair Rx-360 Upstream Supply Chain Committee
Rx360
Supply Chain Security Agenda
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Background on
Rx360
Mission, Objectives, Operating Structure
Membership, Accomplishments
Supply Chain Security Steering Committee
•
Upstream Supply Chain Committee
Formation (June 2013), Charter & Focus, Participants
Highlight Whitepaper content published April 2014
•
Resources to ‘Know Your Supply Chain’
3
The problem
Rx-360
Mission
Protect patient safety by sharing
information and developing processes
related to the integrity of the healthcare
supply chain and the quality of materials
within the supply chain.
Patient safety should never be compromised as a
competitive advantage
Rx-360
Objectives
Bringing Industry and Regulators Together to Protect Patients Worldwide
Exchange public information to allow firms to adopt best practices across industry
Bring industry experts together to develop
responses and action when the supply chain is threatened
Act as a clearinghouse for suspicious supply chain information
Share individual audits and conduct joint audits
Consider joint technological development for securing supply chain and detecting
adulteration
Rx-360
Membership
Broad and Inclusive•
Global
•
Small and large companies
•
Suppliers and manufacturers
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Branded and generic
•
Regulatory agencies, standard setting bodies,
and industry organizations participate as
Observers
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Current Rx-360 Membership
Manufacturers (27) • AbbVie • Amgen • AstraZeneca • Baxter • Bayer • Bend Research • Biogen Idec • Boehringer Ingelheim • BMS• Daiichi Sankyo Co., Ltd.
• Eli Lilly
• Forest Laboratories
• Roche/Genentech
• GSK
• Impax Laboratories Inc.
• Johnson & Johnson
• Merck & Co.
• Merz Aesthetics • Mylan Inc. • Novartis • Pfizer • Pharmaceutics International, Inc.
• Procter & Gamble
• Sanofi-Aventis
• Takeda
• Teva
• UCB Pharma S.A.
Suppliers (30)
• AMPAC Fine Chemicals LLC
• Ash Stevens
• Aurisco
• Avantor Performance Materials, Inc.
• BASF
• Cambridge Major Laboratories, Inc.
• Cardinal Health
• Doe & Ingalls
• DSM Nutritional Products Ltd.
• FUJIFILM Diosynth Biotechnologies U.S.A., Inc.
• GE Healthcare
• Hikal
• Hovione
• Imperial Health Sciences
• Labochim
• LifeConEx
• Life Technologies Corp.
• Ligand
• Merck KGaA
• Neuland Laboratories Limited
• Novozymes
• OSO BioPharmaceuticals Manufacturing LLC
• Resilinc
• Sartorius AG
• Sigma Aldrich
• Spectrum Chemical Mfg. Corp.
• TempTime • VWR • West • York Container
Members
Observers
Auditors (13) • Auckerman Consulting • blue inspection body GmbH • BSI Supply Chain Solutions • MPC Consulting LLC• PharmaPact Consulting Services • PSC Biotech Corp.
• Regulatory Compliance Associates • Rephine Ltd.
• RMC Pharmaceutical Solutions Inc. • Safis Solutions LLC
• SQA Services Inc. • STS Consulting • The Weaver Group, Inc.
Associations (19)
• Alliance for Safe Online Pharmacies • ANSI-ASQ National Accreditation Board • APIC
• Bulk Pharmaceutical Task Force
• Consumer Healthcare Products Association (CHPA) • Council for Responsible Nutrition
• European Fine Chemicals Group (EFCG) • European Generic Medicines Association (EGA) • EXCiPACT
• Health Distribution Management Association (HDMA) • International Society for Pharmaceutical Engineering (ISPE) • IPEC Americas
• IPEC Europe • NSD Bio Group
• Parenteral Drug Association (PDA) • Pharmaceutical Quality Group (PQG)
• Pharmaceutical Research & Manufacturers of America (PhRMA) • Pharmaceutical Supply Chain Initiative (PSCI)
• Rx Response
Rx-360
Delivers Operational Results
• FTC Clearance Letter Received
• Issued 47 Regulatory Flash Reports
2010
• Managed Fukushima Response
• Joint Audit Pilot
2011
• Audit programs go live
• 6 SC Security White Papers Issued
2012
• Held Upstream SC Security Conference
• Asia & Supplier-Led Work Groups Kickoff
2013
• Initiated Medical Device & Serialization Architecture Work Groups
• Release of auditsPLUS, BSI Partnership
Supply Chain Security Steering Committee
Co-Chairs: Rob Welsh ([email protected])Joe Newell ( [email protected] )
• Develop and share best practices and information on key supply chain security processes and enhance collaboration among supply chain stakeholders on issues of supply chain security
• Produce white papers • Participate in webinars
• Create action teams as needed
Supply Chain Security
A c co m p li s h m e n ts D el iv er a b le s
• Benchmarking Teams produce White Papers/Webinars
• 18 White Papers on Supply Chain Security (95 contributors from 32 companies)
• E.g., SCS Management System, Cargo Theft, Illegal Diversion • Upstream Supply Chain Security
• Serialization Support
• Traceability Data Exchange Architecture Work Group
• Serialization Implementation Discussion Group
Must Focus on End to End Supply Chain
Upstream Supply Chain WG
White Paper Evolution
• June 2013: Committee formed • July 2013: Survey Developed
• Aug 2013: Rx360 Membership Surveyed
34 Respondents; Pharma Respondents represented 80% of the Largest 15 Pharma Mfg.s by Revenue
50/50 Mix of Pharma Manufacturers & Suppliers
• Sept 2013: 6 Common themes identified • December 2013: in-person meeting
Majority of writing took place
• February Workshop at Amgen Thousand Oaks
• Webex sessions and phone calls to finalize through Jan.-Feb. • April 22nd date of publication and linked to website
Appendix 1 – Survey
Appendix 2 – Supply Chain Mapping
Appendix 3 – Risk Assessment Tool
• May 8th Webinar conducted and linked to website
Upstream Supply Chain Working Group
• Bretta Lichtenhan, EMD Millipore
Corporation
• Charles Calvert, Boehringer
Ingelheim
• Ken Crossley, VWR Corporation • Michael Fairbanks, Perrigo Co. • Hugo Galaio, Hovione
• William Harclerode, Forest
Laboratories
• Michael LeBlanc, Avantor
• Rob Welsh, VWR Intl. LLC • Maria Macedo, Hovione
• Dawn Palmer, Amgen
• Susan Rabideau, Fugi Film • Timothy P Reinhardt, Pfizer • Karen Seiberlich, Amgen • Carmen Wolf, Boehringer
Ingelheim
• Joyce Yuan, Bristol Myers
Squibb
• Greg Halvacs, Cardinal Health
Upstream Supply Chain White Paper
6 Themes/Topics
1.
Supply Chain Security Awareness
2.
Supply Chain Mapping
3.
Intended Use
4.
Risk Assessment Tools and Approaches
5.
Supplier Questionnaires / Surveys
6.
Change Control and Change Notification
Upstream Supply Chain White Paper
Awareness Section
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Supply chain security = Patient Safety
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2008 heparin issue
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75% formal supply chain security focus
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97% took measures to ensure products are not
adulterated or misbranded
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Recognition that it requires a different mindset
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Awareness of Geopolitical events
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Know the Supply Chain
Rigorous identification, selection, & monitoring
Upstream Supply Chain White Paper
Awareness Section
Present State
Consideration to be given to:
Review and verification of paperwork (certs)
Tamper evident devices and packaging
Photo libraries to identify packaging deviations
Adulteration testing of at-risk materials
Upstream Supply Chain White Paper
Awareness Section
~75% of respondents have a formal supply chain security
focus on upstream process materials such as API’s,
excipients, and primary contact materials
Program responsibilities span diverse groups
Purchasing: raw materials from reputable sources
Receiving: verifying material ordered
Warehousing: storing materials securely
Transportation: transporting materials in a controlled manner
Quality Assurance: ensuring quality and pedigree of materials through audits, supplier monitoring, and testing
Upstream Supply Chain White Paper
Awareness Section
‘Know the Supply Chain’
Develop a Knowledge Mgmt. System
• Mfg. and logistical capabilities, experience, reputation, and financial
condition
• Quality processes inclusive of CAPA plans • Qualification procedures of their suppliers
Robust ongoing monitoring
• Review systems, audits, and inspections • Agreed upon KPI’s
Upstream Supply Chain White Paper
Supply Chain Mapping
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Key Benefits of Supply Chain Mapping:
Enhanced transparency
Development of risk profiles
Manage according to risk profile
Risk mitigation through continuous improvement
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Current challenges
1) Supply chain information is often not easily obtainable - data can be difficult to capture automatically due to origin from various sources
2) Supply chains can be very complex - involving multiple products, multiple countries, multiple logistics providers, and multiple steps.
3) Different actions which need to be taken by those who are responsible for various steps of the supply chain - as opposed to those who are ultimately accountable for the quality of the end product
Upstream Supply Chain White Paper
Supply Chain Mapping
• Complexity increasing with globalization
• 55% of Survey respondents utilize supply chain mapping • 2 Tool Templates:
Spreadsheet
Process Flow
• Future State
Supply chain mapping processes are best applied when both consistency in the documentation and flexibility in the process to accommodate a variety of business situations
Templates / tools could be used to assist in the development of supply chain maps
It is expected that the level of detail obtained for various product supply chains will vary with the level of risk identified within that supply chain
Tools could be modified to ensure the proper level of information is being collected
Upstream Supply Chain White Paper
Intended Use
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Need for care in selection of materials for production and
labs supporting product
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While various grades of materials may be technically
suitable for use, the material manufacturer may not intend
the material to be used in pharmaceutical production
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Much of the necessary quality aspects may not exist such
as:
Change management
Quality documentation
Quality agreements
Supply chain transparency
Upstream Supply Chain White Paper
Risk Assessment Tools and Approaches
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Enables informed decisions about mitigating
(reducing or accepting) risk throughout the raw
material supply chain
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Examples of tools
Failure Mode Effects Analysis (FMEA)
Cause & Effect Analysis (C&E matrix)
Kepner-Tregoe
Preliminary Risk and Hazard Analysis (PRHA/PHA)
Upstream Supply Chain White Paper
Risk Mitigation Considerations
Common risks to consider:
•
Adulteration
•Supply
•
Quality
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Political and geopolitical
•Fit for use
•
Contamination
•Counterfeiting
Upstream Supply Chain White Paper
Questionnaires / Surveys
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Majority of suppliers in survey receive 10 – 30
questionnaires per month (and some receive many more!)
As regulations increase and customers need to know more information, the burden on the supplier to provide this information grows
•
Survey results demonstrated that supplier questionnaires remain
a valuable tool for customer assessment of a supplier’s
compliance status for upstream raw material sourcing
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Customers and suppliers need to understand how to best deal
with the practice of sending and receiving questionnaires,
respectively
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Establishing an internal knowledge management system
can serve as a resource database to facilitate the
processing of customer questionnaires
Upstream Supply Chain White Paper
Questionnaires / Surveys
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Improvement opportunities for pharmaceutical
manufacturing companies and their suppliers
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Standardized approach
Develop guidance/templates to streamline the process of obtaining relevant information and reduce the time and effort required by the suppliers
Standardization could reduce the opportunity for error as well as the fatigue that suppliers experience in answering a large number of questionnaires
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For excipients, there exists a standardized proposed set of
requirements described in the
Excipient Information
Package Guide
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Rx-360 Supplier Led working group recently(Aug.2014)
published a standardized questionnaire templates
Rx-360 Supplier–Led Working Group
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Development of template supplier assessment
questionnaire(s) (SAQ) (released August 2014)
• Webinars held to introduce SAQ.
• The SAQ modules are available for download on the website under the ‘Suppliers’ tab.
Direct link: http://www.rx-360.org/Suppliers/tabid/397/Default.aspx
Updated versions of the SAQ will be posted to this page as they are released.
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Development of template quality agreement(s)
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Development of standardized approach(es) to change
notification processes
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Development of uniformly accepted definitions
•Any additional projects
Upstream Supply Chain White Paper
Change Control and Notification
• ~70% confirmed that notification of change area of disconnect
• Important for all to understand the potential to impact final product • It is the responsibility of the supplier to identify and provide notification of
any changes that are outside of the validated and/or fixed system
• Give the customer adequate time to assess the potential impact to its
product and manufacturing process when possible
• Some common examples of the Change Control content to be
established in the Supply Agreement and/or Quality Assurance Agreement are presented below:
Changes in product quality and / or source of key raw materials
Changes in size and type of production equipment
Changes in production site or batch size
Changes regarding subcontracting of manufacturing parts and/or analytical testing
Rework according e.g. ICH Q7
In Conclusion – 1of 2
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Supply chain security is critical to ensure the patients we serve
receive the trusted, quality medicines they deserve
•
In order to truly ‘Know the Supply Chain’, there must be a
rigorous supplier identification, selection, and management
process
•
Many companies are now formalizing the process for mapping
their supply chains, and are finding significant benefits
•
Understanding material quality and the material supply chain
will enable manufacturers to assess the risks and select the
appropriate material for use where the ultimate responsibility
lies upon the pharmaceutical manufacturer to assess and
determine if the material is fit for use
In Conclusion – 2 of 2
• As part of their business process, companies should establish the
acceptable level of risk and identify what is considered high risk
• Pharmaceutical manufacturing companies and their suppliers should
develop a standardized approach to requests for information, as in questionnaires
Such standardization could reduce the opportunity for error as well as the fatigue that suppliers experience in answering a large
number of questionnaires
• In general, it is expected that suppliers to the pharma/biopharma
sector have effective change control procedures in place (extending to their own supply base) to confirm that product characteristics and material supply will be unaffected by the intended change(s)
• The need for transparency in the upstream supply chain security
space continues to grow
Supply Chain Vulnerabilities Cited as the #1 Risk for Life Science Companies in the
Snapshot of Rx-360 Website: A Resource!
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www.Rx-360.org is your one stop location for securing the supply chain
Privilege & Responsibilities
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Serving patients is a privilege that comes with responsibilities...