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Good Supply Practices
Supply by Design for the 21st Century
Xavier Health Mission
www.XavierHealth.org
• FDA/Xavier PharmaLink Conference • FDA/Xavier MedCon Conference • Xavier AI Summit • Xavier Combination Products Summit
Leading Innovation
CONFERENCES
INITIATIVES
DEVELOPMENT • Medical Device Leaders Certificate Program • Cultural Quantitation and Transformation • EU MDR Workshop • Good Supply Practices Workshops and Training
• Xavier Artificial Intelligence Initiatives • Chief Quality Officers Forum • Xavier Supply by Design Initiative • Amerisource Bergen Serialization Pilot Study • Development of a Bachelor of Quality Science
Over 150 FDA officials and industry professionals engaged on our teams
GMP GSP
GIP GDP
Increase Product Confidence
With the End in Mind
4
5 countries
39 companies
2 industries + FDA
4 New Key Concepts
1 Major Paradigm Shift
11 Practical Solution Tools
Problem Statement
We are unable to reliably and consistently ensure the supply of incoming materials used in
products to serve the Pharmaceutical and Medical Device industries
Therefore, we need greater assurance that suppliers can reliably and consistently supply safe
and quality materials/products to limit adverse impact on end-user safety and brand equity
Gap Analysis – Points to Ourselves
1. Product and Process Knowledge. We lack understanding of our own product and process to know what we truly need from our suppliers.
2. Supply Chain Development. We circumvent our own systems when developing our supply chain, and do not engage our suppliers as subject matter experts.
3. Supply Chain Management. We do not behave as trusted partners in our supplier relationships, and do not respect the business of our suppliers.
7
Paradigm Shift
• August 2012: we wanted to focus on certifying our suppliers
• July 2013: top data is pointing to ourselves as the root cause
August
2012
July
2013
We are
Causing
Problems
Our Suppliers
Are Causing
Problems
Action Provoking! 8
% of time willing to share process capability data and/or composition of material with customers
9% 5%
8%
12%
56%
10%
<10
10-25
26-50
51-75
>75
Not Sure
Data from Suppliers
% of customers who ask to see your process capability data and/or composition of material information
17%
17%
15% 11%
29%
11%
<10
10-25
26-50
51-75
>75
Not Sure
Data from Suppliers
% of time it is critical to know the intended-use of your product/material
9% 7%
7%
11%
58%
8%
<10
10-25
26-50
51-75
>75
Not Sure
Data from Suppliers
% of customers who share their intended-use of your product/material
4% 7%
13%
18% 52%
6%
<10
10-25
26-50
51-75
>75
Not Sure
Data from Suppliers
% of customers ask for your input on specifications for your product/material
8% 15%
17%
23%
29%
8%
<10
10-25
26-50
51-75
>75
Not Sure
Data from Suppliers
4 New Concepts
1. Supply by Design
2. Cross-Functional Alignment
3. Self-Qualification
4. Relationship Risk Mapping
Key Differentiator!
GSP Value
Quality by
Design
Supply by
Design
Product in Development
Product on Market
Integrated Risk
Reduction
16
Cross-Functional Alignment
Who do you Involve Today?
17
Cross-Functional Alignment Functional
Area Examples of
what is needed from the supplier by the functional
area
Examples of what can be contributed to the
supplier selection process by the functional area
Does the functional group feel their involvement has
been missed, or not at the right time?
Score likelihood of involving each cross-functional member going
forward
EH&S Supplier’s capabilities
Supplier’s compliance
Impact of material and supplier
Supplier’s Risk Profile
Carbon footprint
Safety Data Sheets
Identify regulatory requirements
Assurance of Supplier’s compliance
Audit supplier Supplier/material
impact on Company, e.g., Waste disposal, hazards, Risk class
Environmental impact
Historical experience with suppliers
18
Communication Strategy
What information are companies concerned
about sharing?
Why would the suppliers need to know this
information?
What is the risk of sharing this
information?
What is the benefit of sharing this
information?
Actual flexibility in shipping/production schedules
To understand demands and work collaboratively to meet needs
Supplier may take greater risk. Supplier may delay manufacturing if extra time is allowed
Improve availability of supply from synergies of treating supply chain as a single system. Supplier may be able to adjust their schedule
Function of supplier's product in formulation/device
To assist in choosing correct product to supply for given function
IP concerns May raise cost
Get the best product for the application
Cost/profit margin
To come to an agreement on price that is fair for supplier and manufacturer
Supplier may increase their price
Long term benefit of relationship building. Assists supplier with improving efficiencies 19
If We Are Causing, or Could Have Prevented All of Our Supply Chain
Failures, then….
20
How Qualified are We to be in Our Own Supply Chain???
21
Self-Qualification Example
Section 4: Product and Process Technical Capability Score
1 Our process control ranges and product specification ranges are supported by data and/or have scientifically sound justification.
2 Our technical transfer for process and/or analytical/test methods meet predetermined protocol requirements first time.
3 We understand the process capability of our key suppliers for their manufacturing process, and have action limits around that process capability.
4 We discuss with our Key Suppliers the appropriate specifications to have in place for their material, and have documentation to demonstrate the suppliers’ agreement with those specifications.
Category Examples of Criteria to Assess Relative
Importance?
Does Supplier fit your need?
Supplier
Product &
Process
Technical
Capability
Possesses specific technical expertise, process
capabilities and experience
Suppliers have demonstrated process
improvements to afford future economies of
scale to support price negotiation
opportunities for ongoing win-win
Packaging type meets the business needs
(amount of material needed, type of package
needed)
Ability to handle hazardous material
We have familiarity with the equipment used
by the supplier
Supplier Requirement Alignment
23
Relationship Risk Mapping
24
0
10
20
30
40
50
60
70
80
Supplier 1 Score
Supplier 2 Score
Self Score
Operating Systems and Business Capability
Relationship Alignment
Quality and Regulatory Compliance
Product and Process
Technical Capability
Pulling it All Together
Supply by Design for the 21st Century
Good Supply Practices
1. Setting the Foundation a. Cross-Functional Team Formation
b. Self-Qualification
c. Knowledge Management (and supply chain intelligence repository)
d. Supply Chain Risk Management Triage
2. Internal Alignment a. Internal Alignment on Material
Requirements
b. Internal Alignment on Supplier Requirements • Single Source vs. Multi-Source
c. Communication Strategy
3. External Alignment a. Supplier Engagement
b. Holistic Supplier Qualification
c. Relationship Risk Mapping
4. Lifecycle Management
26
= Solution Toolkit
“Where do I Start?”
27
Risk Management Triage
28
Step 1:
Product-Related Risk
Impact of Product-Related Risk
(Low Impact = 0, Slight Impact = 3,
Moderate Impact = 7, High Impact = 10)
Manufacturing Complexity
Pharma: biologic, vaccine, sterile,
nonsterile, etc.
Device: Class III, Class II, Class I, etc.
Score based on the impact of the amount
of risk due to the complexity of the
manufacturing process
Product Sensitivity
Sterility, temperature sensitivity, light
sensitivity, etc.
Score based on the difficulty in maintaining
and assuring conditions to protect product
sensitivity.
Stock-out risk to patients
New product, orphan product, etc.
Score based on the impact that a stock-out
would have to patients.
Financial risk to the business
High cost of discards, loss of market
share, impact to shareholders, etc.
Score based on the financial impact that
risks would have to the business.
Overall Impact Score: Minimum = 0; Maximum = 40
Product Risk Determination
29
Risk Management Triage
30
Step 2:
Material-Related Risk Impact of Material-Related Risk
(Score 0, 3, 7, or 10)
Used in patient and/or business critical
products
No = 0; Yes = 10. Based on product
assessment.
Degree of use across product lines Score as low impact if the material is isolated to
few products
Available inventory (internally and/or
externally). Consider supplier’s reject/discard
rate
Score low if internal inventory is acceptable to
meet market demand and/or if inventory is
easily sustained (multi-sourced, etc.)
Criticality of the material to the finished
product. Consider impact of process capability
variability
Score low if the material does not play a critical
functional role in the finished product.
Material performance based on information in
the supply chain intelligence repository
Score low if historical performance is
acceptable
Financial impact - Cost of material and/or
service, cost and time of alternate source
Score low if financial impact is low
Overall Impact Score: Minimum = 0; Maximum = 60
Material Risk Determination
31
Risk Management Triage
32
Step 3:
Assess the Supplier’s performance against the outcome of the “Internal Alignment on Supplier Requirements” Tool
Risk Management Triage
33
Step 4:
High Volume Supplier
– The Supplier supplies many materials to your company
– No single material is what you would consider high volume
– No single material cuts across numerous product lines
– However, if a significant issue occurs with this Supplier (e.g., compliance, financial stability, facility issue, etc.), then many of your products are impacted
Example of Automatic Risk Elevation
34
1. Map your supply chain
2. Conduct a risk assessment
3. Start using the GSPs in a way that makes sense for your business and is commensurate with the need
Perhaps Start by: – Using the Cross-Functional Alignment tool to establish a cross-functional
team to operate within your current systems
– Using the Internal Alignment on Supplier Requirements Tool next time you need to make a change to a supplier or have a new product
– Developing a Communication Strategy
– Conducting the Self-Qualification
So, Where Can You Start?
35
Good Supply Practices
1. Setting the Foundation a. Cross-Functional Team Formation
b. Self-Qualification
c. Knowledge Management (and supply chain intelligence repository)
d. Supply Chain Risk Management Triage
2. Internal Alignment a. Internal Alignment on Material
Requirements
b. Internal Alignment on Supplier Requirements • Single Source vs. Multi-Source
c. Communication Strategy
3. External Alignment a. Supplier Engagement
b. Holistic Supplier Qualification
c. Relationship Risk Mapping
4. Lifecycle Management
36
• British Standards Institution (BSI) – Currently establishing a Steering Group to convert the GSPs into a Publicly
Available Standard (PAS)
• United States Pharmacopeia (USP) – Currently establishing an Expert Working Group to convert the GSPs into a
General Chapter above 1000
• APEC Supply Chain Security Toolkit – Possible to add as a tool in the Supply Chain Security Toolkit once change
management is established
• Global Training – Company Specific, Live Virtual, and Workshops – Through Pathway for Patient Health and BSI
GSP on a Global Platform
37
Good Supply Practices
• Supply by Design
• for the 21st Century
Thank you!!
Marla A. Phillips [email protected]
513-745-3073