Monday, February 26, 2018

Next phase of EPCIS hopes to bring standard in line with long proven technology concepts

Excited to see leading technology concepts being applied to EPCIS as part of GS1's EPCIS 2.0 call to action (Link)

JSON and REST have been leading formatting and integration approaches in IT applications across many industries for many years.
  • JSON- compact data format/messaging that has shown significant benefits over XML, especially in high volume use cases which are paramount in serialization/track & trace applications
  • REST- the overwhelming leading A2A/B2B integration approach, with significant benefits over asynchronous integration methods such as AS2 and the heavily outdated SOAP protocol.
It will be interesting to see how pharma vendors supporting EPCIS adapt to these potential changes.   Concepts like JSON and REST have been used in serialization/track&trace applications in other industries for many years.   Time for pharma to catch up, and make no mistake, this isnt about the industry looking for new and emerging technologies like AI and blockchain.  This is about the industry catching up to technology trends that were happening 5+ years ago. 

Take a look:

"Rather, the kinds of organizations that favor SOAP tend to be slower to change and more heavily driven by integrating with other government agencies that are behind in technology, or by grant programs tied to a particular technology stack, and they often have legacy systems that require the use of SOAP. "

"Service-oriented architecture (SOA), which gained wide acceptance using web services built on SOAP, has been popular within organizations as a mechanism for sharing information across the enterprise. However, the use of a REST architecture, along with associated technologies such as JavaScript Object Notation (JSON), is accelerating the development and use of APIs. Some of the most popular services such as Twitter, Netflix, and Facebook are now processing API calls on the order of billions per day or month."

Technology adoption, such as this, is fueled by the vendors whom the industry puts their trust in to provide the best solutions.  In pharma this certainly won't be seamless, however, as some large players have long ignored support for these concepts.    

You don't need to be an expert on these terms (leave that for the IT folks) but if your current implementation is heavily rooted in antiquated technologies like AS2, SOAP (and soon to be XML) or hasn't committed to a clear enhancement path as part of their roadmap you're well behind the curve.

Monday, February 19, 2018

Important Public Service Announcement from GS1 and what it means for your Serialization Implementation

GS1 recently released a PSA (Public Service Announcement) noting a specific practice which is currently widespread in pharma serialization implementations and is decidedly non-compliant with GS1's EPCIS standard.  In addition to being non-compliant the practice also infringes upon GS1's property.  See GS1's PSA at the end of this post.

Following GS1's lead I will help bring attention to these types of data compliance and quality issues through this blog.

What is the root issue? In simplistic terms many serialization vendors are communicating ’where' traceability events occur in a non-compliant fashion by populating the GS1 GLN (Global Location Number) incorrectly in EPCIS events.

How widespread is this issue?  Considering multiple 'top' L4/L5 serialization vendors support this non-compliant practice this is a highly widespread issue.  Numerous sources brought this to the attention of GS1 leading to the PSA.  Additionally, proper use of GLN/SGLN has been part of the EPCIS standard since its inception over 10 years ago- So this particular item is alarming not only because of its pervasiveness, but also because of how basic and longstanding the underlying concept is.

How does this impact me?  
  • Non-compliant EPCIS, in any form, leads to challenges in sharing traceability data with downstream partners (Distribution, 3PL, Customers)
  • Not addressing data quality items, such as this, immediately will end up costing the industry more time and money to correct these issues as the volume of live, serialization data increases (often paying the same vendors to fix their own mistakes)
  • Widespread issues such as this introduces contractual concerns for those responsible for providing compliant EPCIS integrations
  • Tolerating non-compliant data in your serialization implementation significantly reduces your ability to harness emerging technologies such as AI and blockchain which demand good quality data
How can I determine if my implementation suffers from this issue?  The key here is don't just take my word for it- you must check your data for yourself. 

I know for some that's easier-said-than-done but fortunately there is no lack of services and tools to quickly find standards compliance issues such as this:
  • The late Ken Traub developed an immensely helpful, FREE tool which will instantly tell you whether an EPCIS message is compliant, as well as provide a summary breakdown of its content.  (Link)
  • I have offered a FREE service to analyze serialization data and provide compliance feedback (Link)
  • The Jennason Serialization Test Tool provides automated serialization test data generation which can be used to ensure your L4/L5 solution properly supports the standards and can also detect non-compliance (Link)
If the options above are still too much effort ask your L4/L5 provider if any of your data is non-compliant per this PSA.  Then let me know their response- I'm eager to hear!!

The message to the industry is simple- take responsibility for your implementations by leveraging the tools readily available to support you.  Otherwise the 6.6% compliance rate we saw with DSCSA barcodes will seem pretty good by comparison.

I appreciate the work being done by Ralph Troger (GS1 Germany) and Craig Alan Repec (GS1 Global) to educate the industry on the proper use of standards by highlighting these non-compliant practices at both a global and country level.  A second 'thank you' to GS1 Brasil for their efforts in making this PSA visible to their members. 

I look forward to GS1 US taking the same vigor in protecting their property and standards.

GS1 Public service announcement on proper use of GLN/SGLN in EPCIS
GS1 Public service announcement on proper use of GS1 EPC URIs

Sunday, February 11, 2018

Lawsuit against HDA dropped.

Notice that Tracelink dropped its lawsuit against the HDA regarding the Origin service was released this week.  Read the press release here (Link).

The absolute correct outcome, in my opinion.   From the start this lawsuit misrepresented the scope of Origin and read more like a bloated piece of marketing material.  I think of no other term but ‘frivolous’ when I see it publicly stated this case was based on ‘misunderstandings’.

The practice of wholesalers/organizations setting the tone for track & trace adherence in the industry is nothing new.  If this practice caused such an anti-competitive environment for L4/L5 solution providers why didn’t we see lawsuits three years ago when T3 electronic exchange was ‘forced’ by some wholesalers even though not required by DSCSA?   The answer is because, at that time, providing electronic lot level T3s actually kept some of these same solution providers in business.   Seemed a little too convenient to start complaining about this practice now. 

My personal experience has been nothing but openness and collaboration with the HDA/ValueCentric teams who position the Origin service as a very complementary offering to L4/L5 solutions.   I look forward to my future efforts with them. 

The fact is the Origin service offers a very real and necessary function which is to guarantee the accuracy of product identification (GTINs) and related attributes.   We just saw how well DSCSA barcoding is progressing (Link) so services like Origin attempt to ensure we don’t repeat the same utter failure when it comes to DSCSA data.  Unfortunately, it only addresses one piece of the puzzle- product master data- so many data issues will still arise. Moreover, everyone should recognize Origin is not the only service that can meet this need.  Data pools, like GS1's GDSN, have for years been providing master data collaboration for numerous industries and across all segments (manufacturing, distribution, retail).  However, the reality is most pharma companies have not advanced to the point of adopting GDSN as part of a master data strategy and thus why services like Origin fill a specific and immediate need.

As for the press release, I’m encouraged by the mention of aligning with standards but unfortunately believe this is just marketing fluff once again- I’m happy to be proven wrong but don’t quite see the need for more workgroups/new standards when no less than two GS1 standards which support master data exchange have existed for 10+ years.  For me this, again, falls into the category of being a little too ‘convenient’- making public claims of alignment with GS1 standards for the marketing credit but then do little to actually deliver support in solutions.  It certainly wouldn’t be the first time this has happened- and continues to be pervasive- with numerous solution providers in this space.  

So, what does this all mean going forward?  For many this lawsuit was an interesting side-story to keep an eye on, but others may have some very real impacts and questions to be answered.  We now have one of the major track & trace providers who has undoubtedly caused many key wholesalers (who also operate many of the largest 3PLs) and their primary industry association to expend significant time and money to defend against this lawsuit. Do we really think that relationship is all warm-and-fuzzy?

Why is this important?  To this point there has been a practice for many pharmas to select L4/L5 vendors simply based off who their packaging provider/CMO recommended- but now the focus is rapidly shifting to integration with the same distribution/3PLs and wholesalers named in this lawsuit- all in support of the next wave of DSCSA milestones in 2019.  So now these pharmas, who took a short-term view into serialization compliance by focusing on packaging only, are left to wonder how the next phase of their serialization program will play out.  

Monday, February 5, 2018

A precursor of what's to come? Barcode issues are only the start...

GS1 US recently released a telling article about the current state of barcoding for DSCSA compliance (Link).  A great review and opinion from Dirk Rodgers was also released on Monday.  A highly suggested read (Link).

The crux of the study is that approx. 6.6% of all serialized barcodes evaluated by two of the largest wholesalers met expected quality requirements and DSCSA compliance.  The results of this barcoding survey, in my opinion, are staggering to say the least.   

Let's put this in perspective- imagine if the results had come back that 50% of the barcodes did not meet DSCSA compliance?   If these results held true, that means that in just 10 short months half of all products distributed in the US should be set aside for non-compliance.  That would be catastrophic to the industry.

So that fact that only 6.6% of barcodes evaluated met two of the largest wholesaler's expectations for quality and DSCSA compliance isnt just staggering- it should be a signal to the entire industry that the traditional ways of approaching serialization simply are not working. 

But what may be more interesting is-  How does the pharma industry view these survey results?   I'd love to think the majority of the industry is gravely concerned.  My fear is most are not.  My fear is many take a position of either:  A) I don't care,  B) That can't possibly apply to me because I use all of the 'leading' vendors or C) If that many are non-compliant then I'm probably in the same boat as everyone else and therefore don't need to worry about it.

It would generally be 'easy' to pin the blame for these results on CMOs/packaging sites- but doing so would miss the mark.  Non-compliance of this magnitude indicates a failure at multiple levels- this is an issue with both business and technical involvement, regulatory interpretation, requirements gathering, GS1 Standards education and, certainly, execution.    I have no doubt the majority of these implementations were fully tested/validated- which means these implementations were doomed for failure before they even started because they were being tested/validated against requirements which were already non-compliant.    

Part of this blame certainly goes back on vendors who are depended upon to be experts in this space.  Vendors at all levels should be able to recognize the issues that led to 6.6% compliance- that's not situational failure, that's systematic failure.  Even enterprise vendors, where most of my experience is rooted, are subject.  If your enterprise vendor didn't recognize these issues-  red flag.

But vendors can't be the only ones in the cross-hairs.  Whether the industry wants to admit it or not there has long been a mentality towards serialization to do as little as possible, as fast as possible for as cheap as possible.   This can't be ignored as a contributing factor.   A lack of necessary oversight and attention to detail has put the industry in the current situation and the scariest part might be- how many companies don't even know they have issues or are led to believe everything is 'OK'?

We now have a clear indicator of how well that mentality is working out for the industry.  And (sorry for the doom-and-gloom) my estimate is its only going to get worse when the focus shifts from barcoding to serialization data.   

The results from the GS1 survey are more likely to be a telling indicator rather than an unexpected blip on the industry's march towards serialization compliance. Where we go from here is in the hands of the industry-  the documentation, tools and services exist to help pharma companies get this 'right'.   Whether the industry chooses to pay attention and take the necessary steps remains to be seen.    

Popular Posts