The Open Serialization Communication Standard (OPEN-SCS; opcfoundation.org) Group, a collection of healthcare sector companies dedicated to standardizing packaging line serialization and aggregation data exchanges, presented its latest findings at the Food & Drug Administration’s December 5-6 Public Meeting on enhanced drug distribution security, per the DSCSA. The group was invited to share its accomplishments in connection with electronic interoperability, standards for data exchange, data architecture, and aggregation & inference.
In the pharmaceutical sector, the lack of standardized track & trace-related communication has posed significant constraints on implementing workable serialization solutions. FDA’s Drug Supply Chain Security Act outlines the critical steps necessary for building an electronic interoperable system that, by 2023, can trace prescription drug products distributed in the U.S.
Ideally, the forthcoming electronic interoperable systems devised by the OPEN-SCS Group will enhance FDA’s ability to protect consumers from exposure to drugs that may be counterfeit, diverted, stolen, intentionally adulterated, subject to fraudulent transaction, or otherwise harmful. Presenters at the public meeting included Dirk Rodgers, a member of the group’s steering committee and Regulatory Strategist at Systech International; and Adriano Fusco, marketing director of the group and Director of Strategy & Development at Antares Vision.
Rodgers introduced the work of OPEN-SCS, explaining its origin as a working group of the Open Platform Communications (OPC) industry consortium, and its mission to “specify functional interoperability of packaging serialization solutions to seamlessly integrate the operations and business processes across organization and regulatory bodies, aligning with other industry groups and standards whenever appropriate.” He explained how OPEN-SCS cooperates with other key groups, such as GS1, ISPE, and ISA. Although horizontal data exchange with these groups is essential to success, he explained the particular importance of the OPEN-SCS group’s focus on the vertical exchange of DSCSA data elements passed between the levels of a serialized packaging solution.
Rodgers emphasized that, in 2023 – the deadline for full supply chain aggregation – the quality of DSCSA transaction documentation exchanged by trading partners will only be as good as the quality of serialization data established during initial packaging operations. “Today’s packaging solutions are not standardized and have no security built-in, leaving them susceptible to incompatibilities, inaccuracies, data loss and theft,” he said. “They have no common name space from line to supply chain, and no common data structure for data exchanges, so the interfaces between solution layers become fragile, threatening data integrity.”
On the meeting’s second day, Adriano Fusco addressed the challenges of implementing aggregation on production lines and distribution centers, and provided an overview of the solutions commonly adopted for bottles and cartons on fully automated, semi-automated, and manual packaging lines where aggregation is performed by operators with specially designed machines. He also presented an overview of the operations of the largest distribution center in Turkey, which has been working in full aggregation mode since 2012 to comply with its own national mandate.
The Agenda, materials and even the webcast of meeting can be viewed on the FDA website: https://www.fda.gov/Drugs/NewsEvents/ucm559090.htm.