Integrated, modular, scalable and CFR 21 Part 11 enabled OPTIMIZE WEIGHING AND DISPENSING OPERATIONS USING ELECTRONIC DATA CAPTURE (EDC) By Jim Sexton, Vice President of Marketing, Rice Lake Weighing Systems It has been estimated that 50% of all the people in the United States file their taxes electronically. Since electronic filing is relatively new, how did so many people migrate from manual filing to electronic filing? What does this mean? A common adage says that in this life, only two things are certain: death and taxes. Historically, the annual tax deadline of April 15 in the United States is nothing short of pandemonium with a government imposed deadline. The US government has found a way to motivate its citizens to embrace electronic filing. By filing electronically, those who are due a refund receive it faster than those who file by US mail. If the government can find a way to entice people to adapt to a new, more efficient way of completing important tasks, like filing taxes, why hasn’t industry found a way to adapt to new, more efficient ways of completing important tasks? Electronic Data Capture (EDC) is the process of collecting data electronically. Generally speaking, EDC streamlines, replaces or significantly modifies the existing paper-based system in the United States. Ultimately, the goal is to store data in a centralized data storage repository – safe, secure and redundant with real-time access. Drug prices are significantly higher in the United States than in other parts of the world. More and more US citizens are flocking to countries like Canada and Mexico to get their prescription drugs filled. This is due in part to all of the research and development performed in the US. This is expensive and drives up the drug costs. Also, other countries don’t regulate the approvals process to the degree the US FDA does. Recent trends that influence the need for operational excellence in the pharmaceutical industry include 1: Real market growth is slowing Pharmaceutical shareholder returns are decreasing Drugs make a net profit on average of 19% (versus 7.5% for the rest of the S&P 500) High research & development (R&D) expenditures It takes 9 years to fully develop and market a new pharmaceutical Market drivers Several issues are driving the pharmaceutical market. These “market drivers” include: 18 major drugs will come “off patent” this year 4,400 new drugs are in the development pipeline “Big pharma” must launch anywhere from $300M to $500M or more per year in projected revenue drugs just to survive Development costs approach $1B for a single drug; typically, only 30% of this is recouped Litigation totals in excess of $10B 1 Dr. Bruce Maloff, Accelerating Drug Development Expectations and Opportunities utilizing Electronic Data Capture (EDC) Odds of FDA Drug Approval Lab Animals 1:10,000 Safety Dose 1:10 Pre-Clinical Phase 1 Efficacy 1:5 Long Term Effects 1:2 FDA Review 1:1.5 Phase 2 Phase 3 Phase 4 “Significant potential and need exists for improving the efficiencies of pharmaceutical manufacturing and associated regulatory processes.”2 Technological opportunities (e.g. Process Analytical Technology or PAT) are available for realizing this potential. However, industry is reluctant due to regulatory uncertainties. PAT provides an opportunity to move from the current testing and document quality paradigm to a continuous quality assurance paradigm. This paradigm shift could greatly improve our ability to ensure quality is “built-in” or is “by design”. This is the ultimate realization of cGMP or current good manufacturing practices 3. Process Analytical Technology (PAT) is a system for designing, analyzing, and controlling the manufacturing processes based on two principles: 1) understanding of the scientific and engineering principals involved; and 2) identification of the variables which affect product quality4. The PAT initiative is consistent with the current FDA belief that quality cannot be tested into products, but should be built-in or by design. According to the FDA draft guidance, the desired state of pharmaceutical manufacturing is that: o product quality and performance are ensured through the design of effective and efficient manufacturing processes o product and process specifications are based on a mechanistic understanding of how formulation and process factors affect product performance o quality assurance is continuous and real time o relevant regulatory policies and procedures are tailored to accommodate the most current level of scientific knowledge o risk-based regulatory approaches recognize both the level of scientific understanding and the capability of process control related to product quality and performance The primary goal of PAT is to provide processes that generate products of predetermined quality. In so doing, improved quality and efficiency are expected from: 2 o reduction of cycle times using on-, in-, or at-line measurements and controls o prevention of reject product and waste o real time product release o increased use of automation Dr. Ajaz S. Hussain, FDA Director Office of testing and Research, May 8, 2002 For more information on this topic, see the website-www.cgmp.com 4 www.fda.gov 3 o facilitation of continuous processing using small-scale equipment, resulting in improved energy and material use and increased capacity Tracer Pharmaceutical and Dispense Optimization Matrix5 Regulatory Compliance Production Planning and Scheduling Quality, PAT, Corrective and Preventive Action (CAPA) Audit Trail Electronic Batch Record (EBR) 21 CFR Part 11 Remediation Plant Warehousing Optimization WEIGH AND DISPENSE SOLUTION PREPARATION COMPOUNDING FILL FINISH • • • • • • • • • • • • • • • • • • • • • • • • Traceability weighing and dispensing optimization systems represent a comprehensive solution to reduce drug manufacturing costs, increase productivity and efficiency, improve time-to-market and drive regulatory compliance. Traceability systems optimize weighing and dispensing by reducing validation efforts and enabling 21 CFR Part 11 compliance. “Tracer” is a co-branded traceability system developed by Rice Lake Weighing Systems and UK-based Stevens Group. This system is modular, open-architected, and scalable to several thousand clients. Tracer’s embedded diagnostics ensure repeatability and proactive event management if there is a problem with the network or components (e.g. balances, scales, printers, thermometers). Tracer easily becomes the “traffic cop” for integrating micro-analytical lab balances, top loaders, bar-code readers, printers, and precision floor scales networked on the manufacturing floor. It is intuitive and has a large easy-to-use color Human Machine Interface (HMI) including impressive graphical displays. An extensive library of API links to ERP/MRP system is available. The system has previously been linked to SAP and JD Edwards. In detail, Tracer reduces validation through: Extensive, pre-defined macro functions and ingredient formulations Precise weighing and dispensing GAMP4 project methodology6 Making a full audit trail available Standard documented test specifications and real time embedded diagnostics algorithms Further, Tracer is 21 CFR compliant by virtue of integrating: Electronic signatures Electronic record of materials, personnel and equipment Strict version and document control 5 6 Rockwell Automation Encompass partner Rice Lake Weighing Systems ISPE Impenetrable security with built-in redundancy Audit trail Business record archiving Signature/record linking Multi-tier security levels Tracer is modular, scalable and open: ERP/MRP and WMS integration via API – 1000’s of references globally Standard support for any make or brand of balance/scale apparatus Integration with hand-held bar code scanners and RFID “Smart Label” printers Productive and Efficient Business Process Workflow Tracer ensures batch uniformity time after time through: 1. Accuracy and documentation of material additions Calculation of quantity of active ingredients based on desired potency Consistent tolerance checking 2. Traceability Assures materials are quality approved prior to production Real-time inventory control Captures lot, sub lots, containers and material properties for each production order Accurate, auditable and readily available records of material, equipment, production order, formulation and batch personnel 3. Improved business process workflow efficiency Standard, electronically managed work instructions Increased visibility of plant operations top to bottom BENEFITS OF A TRACER SYSTEM o o o Reduces risk and waste/real time inventory Improves consistency of quality Improves operations efficiency/productivity If you are considering a traceability investment, please contact Glenn Zalusky at Rice Lake Weighing Systems and discuss a site audit. Glenn can be reached at 800-472-6703, ext 5165. This paper was produced by Jim Sexton, vice president of marketing for Rice Lake Weighing Systems in Rice Lake, WI. Jim received his Bachelor of Science degree in Business Administration from Ohio State University in Columbus. Jim also holds a MBA from the University of Tampa. Jim can be reached at jim.sexton@rlws.com.