Supply
Chain Management–Boon Or Bane For The Medical Device
Industry
Anil Chaudhari
CEO, Operon Strategist
An Medical Device Consulting Company, Pune |
Manufacture of medical devices is
governed by regulatory requirements at every stage -
procurement of materials, manufacture process,
labeling, packaging, sterilization &
distribution in foreign markets. As per regulators &
ISO standards, specific requirements have to be met at
the time of purchase of products. elaborate contract
agreements between manufacturer & vendor should be
signed to define the extent of control. Depth of
contract agreements may cover but is not limited to
costing, delivery timelines, product liability,
product specifications, process parameters,
notification to manufacturer about any changes in
product/process/activity etc. |
.
The phrase supply chain management (SCM) invokes images of
the three biggest e-commerce enterprises presently
operating in India – home grown Flipkart & Snapdeal &
American giant Amazon.
Flipkart, Snapdeal & Amazon are examples of companies who
have effectively & efficiently used the supply chain
management to deliver diverse products to millions of
customers across the country.
So
why can’t it be replicated in the medical device industry?
Why is the medical device industry slow in adapting to the
changing trends in the logistics field? The answer lies in
the different working models of Flipkart & medical device
manufacturer. Flipkart follows a marketplace model of
e-commerce which acts as a facilitator between buyer &
seller by providing an information technology platform on
a digital & electronic network i.e. Flipkart is not
involved in the manufacture of any of the products it
sells. On the other hand, medical device manufacturers
source raw materials (components, semi-finished goods,
packing materials, finished goods), manufacture /
assemble, label, package, sterilize&distribute their
products. Another important factor to be considered while
applying supply chain management in the medical device
industry is the regulatory requirements. Manufacture of
medical devices is governed by regulatory requirements at
every stage – procurement of materials, manufacture
process, labeling, packaging, sterilization & distribution
in foreign markets.
According to the expectations of regulators & ISO
standards, specific requirements have to be met at the
time of purchase of products. Clause 8.4 Control of
externally provided processes, products & services in ISO
9001:2015 and Clause 7.4 Purchasing in ISO 13485:2016
outlines the need to document the criteria for selection,
monitoring, evaluation & re-evaluation of vendors. The
criteria thus established should be proportionate to the
risk associated with the medical device. It also requires
the results of all these activities be documented &
records maintained. The clause also requires the
manufacturer to determine the controls to be applied to
external vendor. Subpart E purchasing controls (820.50)
also states similar requirements at the time of purchase
of products & services. However, the type & extent of
control of the manufacturer over the vendor depends on
potential effect of purchased product/service on the final
product quality. For this reason, elaborate contract
agreements between manufacturer & vendor should be signed
to define the extent of control. The depth of contract
agreements may cover but is not limited to costing,
delivery timelines, product liability, product
specifications, process parameters, notification to
manufacturer about any changes in product/process/activity
etc.
Manufacturers can follow ‘push’ or
‘building-to-stock’model which is producing stock on the
basis of anticipated demand. Another model that
manufacturers can follow is the ‘pull’ or
‘building-toorder’model which is producing stock in
response to actual demand. In order to overcome the
drawbacks of both pull & push model, the push-pull model
can be used wherein both the push & pull models are
incorporated at different points in the supply chain. In
this, upstream units employ ‘building-to-stock’, while the
downstream units employ ‘building-to-order’. For a legal
manufacturer, upstream activity may include but is not
limited to procurement of raw materials, components,
semi-finished goods, finished goods, packing materials,
sterilization services, other relevant lab services etc.
The downstream activities may include but is not limited
to distribution of final product via the network of
distributors, wholesalers & retailers.
Manufacturer looking to adapt supply chain management must
follow the same regulations that they would if they were
individually sourcing materials. Prior to including
vendors in the supply chain, manufacturers must conduct
vendor qualification to ensure that the vendor will supply
quality products/service& will follow the delivery
schedules. If required, manufacturers can sample & test
the vendor materials prior to finalizing them as approved
vendors. Materials/services will always be sourced from
theses approved vendors. These vendors are also evaluated
regularly to ensure that they continue providing quality
services. Elaborate & descriptive contract agreements
between manufacturers & vendors will ensure no ambiguity
in the scope of services of the vendor. In case of
discrepancies in the services of the vendor at the time of
actual delivery, a manufacturer can always stop sourcing
from the vendor & instead look for alternate vendors who
will provide quality services.
Supply chain management can be applied even on the
downstream side, i.e. for the distribution of finished
products from the manufacturers to the consumers either
directly or through a network of distributors, wholesalers
& retailers. Once again when the manufacturer is looking
at applying supply chain management for distribution of
finished goods, they have to follow all applicable
regulations. A main concern during distribution is
maintaining the integrity of the final product while in
distribution so that the product reaching the consumer is
of the same packaging & labeling as originally intended by
the manufacturer. For this, packaging
validation is completed at the time of design &
development to ensure that the packaged product is not
damaged during handling & distribution. Manufacturers
outsourcing logistics via the supply chain must give clear
instruction on how to handle the product. If any special
environmental conditions are required to be met, it must
be clearly instructed to the logistic vendor. Again,
elaborate contract agreement will help reduce ambiguities
in the scope of the logistic vendor. As with other
activities involved in the manufacture of a medical
device, the validation of supply chain must be carried out
to demonstrate the integrity & feasibility of the supply
chain in maintaining the quality & safety of the product.
The idea of supply chain management in medical device
industry sounds appealing. It can help manufacturers focus
on design, development & manufacture of the product while
outsourcing the supply chain management to a reputed firm.
It will help in reducing the overall expenses that are
incurred during the sourcing & delivery of materials &
dispatch of semi-finished & finished goods. Several
factors need to be considered while studying the
feasibility of applying supply chain management at a
manufacturing site. The type of product being
manufactured, raw material availability, country
regulations, customs and taxes are only some of the
deciding factors. While it may not always work in favor of
the manufacturer, it nevertheless has proven to be an
efficient management tool in other industries which we
hope can be equally adapted in the medical device industry
in the coming future.
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