AmerisourceBergen Corporation Serialization
Transcription
AmerisourceBergen Corporation Serialization
AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements V3 1 Table of Contents Purpose 3 Definitions, Acronyms & Abbreviations 3 References 5 Pharmaceutical (Rx) Serializations Labeling 5 What does the DSCSA require for a data carrier? 5 Three Key Definitions 6 Existing FDA Guidance (Example) 6 Converting a NDC (National Drug Code) to a GTIN (Global Trade Item Number) 6 GS1 Application Identifiers 6 AmerisourceBergen Pharmaceutical (Rx) Labeling Standards & Guidelines 7 AmerisourceBergen Unit (Primary) Label Requirements 7 Unit Level Barcode & Label Examples 8 Homogeneous Case Label Requirements 10 Case Label Barcode & Label Examples 11 Pallet and Non-Homogeneous Case Label Requirements 13 Pallet and Non-Homogeneous Case Label Barcode & Label Examples 13 Summary Case Specifications (from HDMA Guidelines for Barcoding) 17 Purpose The purpose of the ABC (AmerisourceBergen Corporation) Labeling Requirement Specification Document (LBRS) is to define, outline and communicate to all ABC suppliers and customers the business requirements that AmerisourceBergen must meet in order to be compliant and adhere to industry best practices with the Drug Supply Chain Security Act (DSCSA). The AmerisourceBergen labeling requirements will be defined at each packaging level with clear labeling guidance stemmed from the GS1 General Specification Guide and HDMA Bar Code Guidelines. DSCSA sets forth multiple phases of compliance starting November 27, 2013 through to November 27th 2023 and impacts all members of the prescription drug supply chain. The Labeling Requirement Specification Document will outline the affected AmerisourceBergen business units as well as timing of compliance to the law. On November 27, 2017, each manufacturer must comply with applying a Product Identifier (SNI) (Standard Numerical Identifier) placed on all saleable packages and sealed homogenous cases. With requests for verification, manufacturers must also reply with an indication of whether or not the product identifier provided in the request for verification from trading partners corresponds to the product identifier affixed or imprinted by the manufacturer within 24 hours. AmerisourceBergen will ultimately utilize the manufacturer’s SNI within multiple business and IT processes, thus communicating the labeling requirements to ALL suppliers will benefit the organization greatly. Definitions, Acronyms & Abbreviations Acronym / Abbreviation Definition DQSA Drug Quality and Security Act: US Federal law signed into law by President Obama on November 27, 2013, that outlines critical steps to build an electronic, interoperable system to identify and trace certain prescription drugs as they are distributed in the United States. DSCSA The Drug Quality and Security Act (DQSA), was signed into law by President Obama on November 27, 2013. Title II of DQSA, the Drug Supply Chain Security Act1, outlines critical steps to build an electronic, interoperable system to identify and trace certain prescription drugs as they are distributed in the United States. FDA Food and Drug Administration: A government agency established in 1906 with the passage of the Federal Food and Drugs Act. With the passage of DSCSA the FDA now has expanded regulatory authority of wholesalers and dispensaries. GS1 GS1 is a neutral, not-for-profit, international organization that develops and maintains standards for supply and demand chains across multiple industry sectors. AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 3 Definitions, Acronyms & Abbreviations Acronym / Abbreviation GS1 2D Data Matrix Definition GS1 DataMatrix is a two-dimensional (2D) barcode that holds large amounts of data in a relatively small space. GS1-128 GS1-128 is an application standard of the GS1 implementation using the Code 128 barcode specification. The former correct name was UCC/EAN-128. GTIN Global Trade Item Number (GTIN) is an identifier for trade items developed by GS1. For the purposes of serialization the industry will be using a 14 digit GTIN which contains he encoded 10 digit NDC. Homogeneous Case Non-Homogeneous Case Product Case Label Serial Number Verification sGTIN Shipper Label SSCC(18) A packaging container, often called a case or shipper, that contains all of the same NDC or product. A packaging container that contains mixed products This is the label that is applied to homogeneous cases. This typically contains the GTIN, Quantity, Lot, Expire, and quantity encoded in both linear and 2D DataMatrix barcodes. This is the process (systemic or manual) of ensuring that a serial number in ABC’s possession is in fact a valid serial number per the manufacturer by the definition of Product Verification as outlined in DSCSA. For the US market, sGTIN is a serialized GTIN. When referring to a serial number, it is in fact always referring to the GTIN + SN combination. A Serial Number by itself is not unique until combined with a GTIN. Example: (01)0030456219999(21)1003451 is a valid Serial Number, (21)1003451 is not because it is not with an associated GTIN. This is a label that is applied to non-homogeneous cases, or totes and Pallets. This label often contains logistics information and the SSCC (18). The serial shipping container code (SSCC) is an 18-digit number used to identify logistics units. In order to automate the reading process, the SSCC is often encoded in a barcode, generally GS1-128. AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 4 Definitions, Acronyms & Abbreviations Acronym / Abbreviation Definition The term standardized numerical identifier refers to a set of numbers or characters used to Standard Serialized Numerical uniquely identify each package or homogenous case. The SNI is composed of the National Identifier (SNI) Drug Code that corresponds to the specific product (including the particular package configuration) combined with a unique alphanumeric serial number of up to 20 characters. Product Verification Bundle / Interpack The term `verification’ or `verify’ means determining whether the product identifier affixed to, or imprinted upon, a package or homogeneous case corresponds to the standardized numerical identifier or lot number and expiration date assigned to the product by the manufacturer or the re-packager. Inner pack (s) of saleable units within a case. References GS1 General Specifications Version 1.4 http://www.gs1.org/docs/gsmp/barcodes/GS1_General_Specifications.pdf HDMA Guidelines for Bar Coding in the Pharmaceutical Supply Chain (2011) http://www.healthcaredistribution.org/publications/hdma-guidelines-for-bar-coding-in-thepharmaceutical-supply-chain-quick-start-guide H.R. 3024; Drug Quality and Security Act (DQSA), Title II – Drug Supply Chain Security Act (DSCSA) http://www.fda.gov/Drugs/DrugSafety/DrugIntegrityandSupplyChainSecurity/ DrugSupplyChainSecurityAct/ Pharmacuetical (Rx) Serialization Labeling What does the DSCSA require for a data carrier? Unless the Secretary allows, through guidance, the use of other technologies for data instead of or in addition to the technologies the applicable data: • Shall be included in a 2-dimensional data matrix barcode when affixed to, or imprinted upon, a package • Shall be included in a linear or 2-dimensional data matrix barcode when affixed to, or imprinted upon, a homogeneous case The accepted ABC industry standard is to implement a GS1 2D data matrix ECC200 with different barcode sizes used where applicable. AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 5 Pharmacuetical (Rx) Serialization Labeling Three Key Definitions • Standardized Numerical Identifier – The term ‘standardized numerical identifier’ means a set of numbers or characters used to uniquely identify each package or homogenous case that is composed of the National Drug Code that corresponds to the specific product (including the particular package configuration) combined with a unique alphanumeric serial number of up to 20 characters. • Package – a ‘package’ as smallest individual saleable unit of product for distribution by a manufacturer or re-packager that is intended by the manufacturer for ultimate sale to the dispenser of such product. • Product Identifier – The term ‘product identifier’ means a standardized graphic that includes, in both human readable form and on a machine-readable data carrier that conforms to the standards developed by a widely recognized international standards development organization, the standardized numerical identifier, lot number, and expiration date of the product. Existing FDA Guidance (Example) According to GS1 and current best practices, this is NOT an accepted SNI. Converting and a NDC (National Drug Code) to a GTIN (Global Trade Item Number) GTIN, like the USA regional NDC, is a product identifier valid and unique globally. GS1 Application Identifiers Data Field Application Identifier Data Field Length GTIN (01) Fixed length, 14 numeric digits Expiration Date (17) Fixed length, 6 numeric digits – YYMMDD format Lot Number (10) Variable length, up to 20 alphanumeric characters Serial Number (21) Variable length, up to 20 alphanumeric characters Quantity (30) Variable length, up to 8 numeric digits AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 6 AmerisourceBergen Pharmaceutical (Rx) Labeling Standards and Guidelines With the 2017 DQSA (Serialization) compliance date approaching, AmerisourceBergen Corporation has now defined business requirements and IT system capabilites for Rx labeling upon receipt from all suppliers. AmerisourceBergen Corporation has adopted GS1 standards and follows, and expects our trading partners to follow, HDMA Bar Code Implemetation Guidelines for labeling requirements within the Life Sciences Industry. In order to ensure uninterupted flow of serialized product, the following sections of this document will describe AmerisourceBergen’s requirements and examples to assist manufacturers as they implement serialization packaging and logistics capabilities. AmerisourceBergen Unit (Primary) Label Requirements ABC requires all Manufacturer’s to comply with the requirements based on HDMA Barcode Guidlelines and GS1 standards listed below: Requirement Number Requirement Description SN_VEN_0010 The manufacturer shall label their primary, lowest unit of sale in accordance with the HDMA Guidelines for Barcoding (Published 2011) SN_VEN_0020 The manufacturer shall encode the GTIN in the 2D GS1 DataMatrix AI(01) SN_VEN_0030 The manufacturer shall encode the Serial Number in the 2D GS1 DataMatrix AI(21) SN_VEN_0040 The manufacturer shall encode the Lot Number in the 2D GS1 DataMatrix AI(10) SN_VEN_0050 The manufacturer shall encode the Expiration Date in the 2D GS1 DataMatrix AI(17) SN_VEN_0060 The manufacturer shall label their lowest unit of sale with the GTIN in Human Readable format SN_VEN_0070 The manufacturer shall label their lowest unit of sale with the Serial Number in Human Readable format SN_VEN_0080 The manufacturer shall label their lowest unit of sale with the Lot Number in Human Readable format SN_VEN_0090 The manufacturer shall label their lowest unit of sale with the Expiration Date in Human Readable format SN_VEN_0100 The manufacturer shall verify the readability of the 2D GS1 DataMatrix, containing serialization information, to a minimum of a ISO Grade C AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 7 Unit Level Barcode & Label Examples 1. (GS1 ECC 200 2 D Data Matrix with HRI (Human Readable Information)) 2. (GS1 ECC 200 2 D Data Matrix with HRI (Human Readbale Information)) 3. (GS1 ECC 200 2 D Data Matrix with HRI (Human Readbale Information)) 4. Sample Serialized Unit Label. (It is recommended that only ONE 2D DataMatrix be place on each side of the label) AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 8 Unit Level Barcode & Label Examples “In accordance with the DSCSA Product Identifier required for the smallest individual salable unit of product, ABC requires encoding NDC [AI(01)+14 digit GTIN], unit-level serial number [AI(21)+1-20 digit serial number],expiration date [AI(17)+6 digit date in YYMMDD format] and lot number [AI(10)+1-20 alphanumeric lot number] using the 2D GS1 DataMatrix – ECC200 (referred to in this document as GS1 DataMatrix) Bar Code. The combination of GTIN + Serial Number MUST be unique! (Use an indicator digit of zero in the GTIN for the lowest saleable unit! This will ensure that product codes (NDC vs. GTIN 14) will not change between the linear bar code and the 2D data matrix.) Recommended Minimum Unit Size GS1 Data Matrix Specifications GS1 Data Matrix X Dimension Mil Size 10 Mil Quite Zone 10 Mil The encoded data should appear as: < FNC1>+AI (01) + GTIN+AI (21) + Serial Number + <FNC1> + AI (17) + Expiration Date + AI (10) + Lot Number The first FNC1 is used to indicate that this is a GS1 Data Matrix. The second FNC1 (also known as a Group Separator) is used to terminate the variable length serial number prior to starting the next AI. Since the lot number is last data element encoded in the bar code, there is no need to terminate using FNC1. The parentheses are not encoded in the bar code — they are only shown as human-readable. (HDMA Guidelines for Barcoding) AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 9 Homogenous Case Label Requirements ABC requires all Manufacturer’s to comply with the requirements based on HDMA Barcode Guidlelines and GS1 standards listed below: Requirement Number Requirement Description SN_VEN_0130 The manufacturer shall label their cases with a 2D GS1 DataMatrix ECC200 SN_VEN_0140 The manufacturer shall encode the GTIN in the 2D GS1 DataMatrix AI(01) SN_VEN_0160 The manufacturer shall encode the Serial Number in the 2D GS1 DataMatrix AI(21) SN_VEN_0170 The manufacturer shall encode the Lot Number in the 2D GS1 DataMatrix AI(10) SN_VEN_0180 The manufacturer shall encode the Expiration Date in the 2D GS1 DataMatrix AI(17) SN_VEN_0190 The manufacturer shall encode the GTIN in a 1D GS1-128 Linear Barcode AI(01) SN_VEN_0200 The manufacturer shall encode the Serial Number in a 1D GS1-128 Linear Barcode AI(21) SN_VEN_0210 The manufacturer shall encode the Lot Number in a 1D GS1-128 Linear Barcode AI(17) SN_VEN_0220 The manufacturer shall encode the Expiration Date in a 1D GS1-128 Linear Barcode AI(10) SN_VEN_0250 The manufacturer shall label their product case with the GTIN in Human Readable format SN_VEN_0260 The manufacturer shall label their product case with the Serial Number in Human Readable format SN_VEN_0270 The manufacturer shall label their product case with the Lot Number in Human Readable format SN_VEN_0280 The manufacturer shall label their product case with the Expiration Date in Human Readable format SN_VEN_0300 The manufacturer shall verify that the 2D GS1 DataMatrix, which contains the serialized information, is to a minimum quality of a ISO Grade C AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 10 Case Label Barcode and Label Examples HDMA Recommended Corner Wrap Case Label Product identification labels are recommended on two adjacent sides of the case. This can be achieved by using the HDMA Recommended Corner Wrap Case Label shown at right. A 4” by 10” Corner Wrap label is the industry standard for a standard case size. Case labels should be placed with the bar codes oriented in the “picket fence” orientation relating to the bottom of the case. That is, the bars should be perpendicular to the bottom edge of the case. Also, the GS1 Data Matrix should be placed away from the corner of the case as shown above. Non-Corner Wrap Case Label If the manufacturer is unable to comply with the required Corner Wrap Case Label, the case label requirement can also be achieved by placing Non-Corner Wrap 4” by 5” labels on two adjacent sides of the case. Non-Corner Wrap Case Label Placement When using a Non-Corner Wrap Case Label, the labels should be placed .75” from the shared corner and 1.25” from the bottom of the case as shown at right (on two adjacent sides). AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 11 Case Label Barcode and Label Examples “In accordance with the DSCSA, HDMA recommends encoding NDC [AI (01) + 14 digit GTIN], serial number [AI (21) + 1-20 digit serial number], expiration date [AI (17) +6 digit date in YYMMDD format] and lot number [AI (10) + 1-20 alphanumeric lot number] and case quantity [AI (30) + 1-8 digit case quantity] using two GS1-128 bar codes and one GS1 DataMatrix – ECC200. The combination of GTIN + Serial Number MUST be unique! The HDMA-recommended case label format MUST include two distinct GS1-128 bar codes on the label (one placed directly above the other) and one GS1 DataMatrix. The primary case GS1- 128 bar code (bottom bar code) encodes the GTIN and the case serial number. The secondary case bar code (top bar code) encodes the expiration date, lot number and quantity. The GS1 DataMatrix barcode combines all data elements from both primary and secondary GS1-128 bar codes. For case label size specifications, see Appendix. The encoded case primary GS1-128 bar code should appear as: < FNC1> +AI (01) + GTIN + AI (21) + Serial Number. The FNC1 is used to indicate that this is a GS1-128 Linear Barcode. (For a partial cases, an SSCC18 number will replace the GTIN and Serial Number, and the label will no longer have a GS1 Data Matrix) The encoded case secondary GS1-128 bar code should appear as: <FNC1> + AI (17) + Expiration Date + AI (10) + Lot Number + <FNC1> + AI (30) + Case Quantity The first FNC1 is used to indicate that this is a GS1-128 Linear Barcode. The second FNC1 (also known as a Group Separator) is used to terminate the variable length Lot Number prior to starting the next AI. Since the case quantity is last data element encoded in the bar code, there is no need to terminate using FNC1. The parentheses are not encoded in the bar code — they are only shown as human-readable. The encoded GS1 DataMatrix data should appear as: < FNC1> + AI (01) + GTIN + AI (21) + Serial Number + <FNC1> + AI (17) + Expiration Date + AI (10) + Lot Number The first FNC1 is used to indicate that this is a GS1 DataMatrix. The second FNC1 (also known as a Group Separator) is used to terminate the variable length serial number prior to starting the next AI. Since the Lot Number is last data element encoded in the bar code, there is no need to terminate using FNC1. The parentheses are NOT encoded in the bar code — they are only shown as human-readable. (HDMA Guidelines for Barcoding) AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 12 Pallet and Non-Homogeneous Case Label Requirements ABC requires all Manufacturer’s to comply with the requirements based on HDMA Barcode Guidlelines and GS1 standards listed below: Requirement Number Requirement Description SN_VEN_0360 The manufacturer shall encode the SSCC in the GS1-128 Barcode AI(00) on their pallets SN_VEN_0370 The manufacturer shall encode the SSCC in the GS1-128 Barcode AI(00) on their Partial Case Labels SN_VEN_0380 The manufacturer shall encode the SSCC in the GS1-128 Barcode AI(00) on their NonHomogenous/Mixed Case Labels SN_VEN_0390 The manufacturer shall label their full product pallets, Mixed Cases, and Partial Cases with the SSCC in Human Readable format SN_VEN_0400 The manufacturer should include the word “Partial” on the Partial Case Label SN_VEN_0410 The manufacturer shall verify that the GS1-128 barcodes, which contains the serialized information, is to a minimum of a ISO Grade C Pallet and Non-Homogeneous Case Label Barcode and Label Examples “A SSCC (Serial Shipping Container Code) label should be used for non-homogenous/mixed product cases and partial cases. There should be no product label information applied to a non-homogenous/mixed product case. At a minimum, the partial case label should include the SSCC 18 encoded into a GS1-128 Linear Barcode and the word “partial.” It is also recommended that the label not include the secondary linear barcode to avoid confusing this label with the Homogenous Case Label. To support logistics, HDMA recommends either the Pallet label or Mixed Case Label (Shown Below). HDMA further recommends the SSCC Pallet label for pallets shipped by ground freight carriers. A logistics unit could be a pallet, a case or a tote.” (HDMA Guidelines for Barcoding) The encoded SSCC in a GS1-128 linear bar code should appear as: < FNC1> +AI (00) + SSCC AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 13 Pallet and Non-Homogeneous Case Label Barcode and Label Examples The following diagram is an example of the HDMA-recommended SSCC label, for pallets and containers shipped by ground freight carriers, with each of its building blocks defined and described: SSCC 18 Product Code Break Down: AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 14 Pallet and Non-Homogeneous Case Label Barcode and Label Examples The following pictures are examples of the HDMA-recommended Partial (A) and Mixed (B) case label: Sample Partial Case Label Sample Mixed Case Label AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 15 Appendix Summary Case Specifications (From HDMA Guidelines for Barcoding) AmerisourceBergen Corporation Serialization Labeling Guidelines and Requirements 17 1300 Morris Drive Chesterbrook, PA 19087 www.amerisourcebergen.com