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.
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