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Rx-360Upstream Supply Chain Security A Supplier Collaborative Approach to Mitigate Risk and Enhance Transparency

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Rx-360Upstream Supply Chain Security

A Supplier Collaborative Approach to

Mitigate Risk and Enhance Transparency

www.Rx-360.org

www

.Rx

-360.

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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

(2)

Rx360

Supply Chain Security Agenda

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)

3

The problem

(4)

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

(5)

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

(6)

Rx-360

Membership

Broad and Inclusive

Global

Small and large companies

Suppliers and manufacturers

Branded and generic

Regulatory agencies, standard setting bodies,

and industry organizations participate as

Observers

6

(7)

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

(8)

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

(9)

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

(10)

Must Focus on End to End Supply Chain

(11)

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

(12)

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

(13)

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

(14)

Upstream Supply Chain White Paper

Awareness Section

Supply chain security = Patient Safety

2008 heparin issue

75% formal supply chain security focus

97% took measures to ensure products are not

adulterated or misbranded

Recognition that it requires a different mindset

Awareness of Geopolitical events

Know the Supply Chain

Rigorous identification, selection, & monitoring

(15)

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

(16)

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

(17)

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

(18)

Upstream Supply Chain White Paper

Supply Chain Mapping

Key Benefits of Supply Chain Mapping:

Enhanced transparency

Development of risk profiles

Manage according to risk profile

Risk mitigation through continuous improvement

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

(19)

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

(20)

Upstream Supply Chain White Paper

Intended Use

Need for care in selection of materials for production and

labs supporting product

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

Much of the necessary quality aspects may not exist such

as:

Change management

Quality documentation

Quality agreements

Supply chain transparency

(21)

Upstream Supply Chain White Paper

Risk Assessment Tools and Approaches

Enables informed decisions about mitigating

(reducing or accepting) risk throughout the raw

material supply chain

Examples of tools

Failure Mode Effects Analysis (FMEA)

Cause & Effect Analysis (C&E matrix)

Kepner-Tregoe

Preliminary Risk and Hazard Analysis (PRHA/PHA)

(22)

Upstream Supply Chain White Paper

Risk Mitigation Considerations

Common risks to consider:

Adulteration

Supply

Quality

Political and geopolitical

Fit for use

Contamination

Counterfeiting

(23)

Upstream Supply Chain White Paper

Questionnaires / Surveys

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

Customers and suppliers need to understand how to best deal

with the practice of sending and receiving questionnaires,

respectively

Establishing an internal knowledge management system

can serve as a resource database to facilitate the

processing of customer questionnaires

(24)

Upstream Supply Chain White Paper

Questionnaires / Surveys

Improvement opportunities for pharmaceutical

manufacturing companies and their suppliers

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

For excipients, there exists a standardized proposed set of

requirements described in the

Excipient Information

Package Guide

Rx-360 Supplier Led working group recently(Aug.2014)

published a standardized questionnaire templates

(25)

Rx-360 Supplier–Led Working Group

25

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.

Development of template quality agreement(s)

Development of standardized approach(es) to change

notification processes

Development of uniformly accepted definitions

Any additional projects

(26)

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

(27)

In Conclusion – 1of 2

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

(28)

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

(29)

Supply Chain Vulnerabilities Cited as the #1 Risk for Life Science Companies in the

(30)

Snapshot of Rx-360 Website: A Resource!

30

www.Rx-360.org is your one stop location for securing the supply chain

(31)

Privilege & Responsibilities

31

Serving patients is a privilege that comes with responsibilities...

Our 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

(32)

Appendix

(33)

Upstream Supply Chain Working Group

Charter – Problem Statement & Goals

(34)

Upstream Supply Chain Working Group

Charter – Scope Definition

References

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