27 Jun Make Sure You’re Doing Validation Right to Reduce the Risk of Serialization Going Wrong
A critical step in the serialization deployment process – the validation phase – has become a hot topic in the pharmaceutical industry. Pharma manufacturers are scrambling to assemble validation resources so they can meet the FDA’s DSCSA deadline, which mandates that they must serialize their products at the saleable unit by November 2017.
In doing so, pharma companies are discovering that the “self-validating” serialization software they thought they bought – including full validation support – is turning out to be a DIY product that resides on a multi-tenant platform (i.e., all customers share the same instance of the platform). The upshot is that any time the serialization provider updates its software, its clients must re-validate the system, which includes completing the critical, often complex regulatory documentation that shows the system has been tested and functions the way it’s supposed to function.
Recently, one of our competitors announced their launch of a new, automated validation product later in 2017. The product attempts to fix shortfalls that currently exist in its multi-tenant serialization software.
At OPTEL, we offer a well-architected, flexible, single-tenant platform (i.e., each customer gets a dedicated instance of the platform and code base) with three environments for testing, validation and production. By utilizing a single-tenant platform, our customers maintain control over their updates. In addition, OPTEL is an avid proponent of automated testing; we run over 5,800+ unit tests and 3,400+ functional tests nightly and growing. We also provide full validation documentation support for the core system and trading partner connections for the life of the service. Our platform features the most recent version of EPCIS and gives our clients the ability to update the system when they want based on their specifications, internal resources, and timelines — not ours.
Our team of in-house quality and validation experts, led by former auditor Tim Donelon, strongly believe there is significant risk associated with a multi-tenant, one-size-fits-all approach. The reason is simple: you have much less control of your system.
“Your Quality group likely has a minimum requirement to follow a GAMP 5 approach for computer system validation,” Donelon says. “By using a system with a multi-tenant platform with bug fixes/updates that occur multiple times a week or every other week, you run the risk of not being able to maintain a validated state for your intended use. Further, connections among trading partners still require validation in order for serialization data to flow. Without proper change controls in place assessing the impact and risk, those connection are in jeopardy every time an update/bug fix occurs outside of your control.”
To help you understand how our competitor’s validation deliverables stack up to ours, we offer a comparison of what we do versus what our competitor intends to launch later this year. Below is a chart that illustrates OPTEL’s complete validation offering as outlined by GAMP 5. OPTEL offers everything in green.
Later this year, one of our competitors will begin offering User Requirements Specification and Requirements Testing (see green bubbles) as part of its automated validation package, which is actually third-party service.
As we have warned in the past, be sure you’re getting the full story and not just marketing hype when evaluating serialization software, whether you’re still vetting software solutions or have selected a vendor and are not satisfied with the results. Contact us to learn more about our SWIFT implementation framework if you’re looking for serialization software that can simplify the deployment process and provide you with limited risk and dedicated, ongoing validation resources to maintain a validated state.