The SDL Pharma Labeling Solution Meets the Unique Needs for Multilingual Labeling Background and Scope Pharmaceutical drug development processes are typically divided into several phases: discovery, clinical, registration (regulatory), production, safety, sales and marketing. Together, they reflect the overall pharmaceutical product life cycle. Starting with the late clinical phase, information is required in multiple languages as it is shared beyond the source lab or home office. SDL has multiple solutions that make the pharmaceutical translation process more efficient, less costly and easily auditable by any regulatory agency. In fact, SDL has developed a solution specifically to support the pharma global labeling process. This whitepaper introduces the new global labeling solution that combines leading translation management technologies with services specialized to support the pharmaceutical industry. With this total solution, the central global labeling group and local-language affiliate organizations are enabled to optimize all the translation steps required to support the drug labeling process. Contents Regulatory framework........................................................................................................................................................... 2 Label changes (on top of label changes).................................................................................................................. 2 The unique pharmaceutical labeling challenge................................................................................................... 2 SDL Pharma Labeling Solution A translation management system purpose built to support the multilingual labeling process.......................................................................................................................... 3 The mandated way of handling tracked changes and comments........................................................... 3 Translation memory (TM).................................................................................................................................................... 5 Terminology management................................................................................................................................................ 5 SDL WorldServer enables centralized control of the translation process............................................. 5 Other features of the SDL Pharma Label translation.......................................................................................... 6 Process setup and workflow definition pays dividends for every labeling project........................ 7 Summary....................................................................................................................................................................................... 8 Language White Paper | SDL Pharma Labeling Solution Regulatory framework Pharmaceutical companies deal with stringent regulations whenever they submit product information (PI) into a world-wide product registration process. This is a critical process, as it determines how well decades of discovery and clinical investments will be understood and adopted by stakeholders including patients, health care professionals and payers. Submitting product information, and doing it accurately the first time, directly impacts corporate revenues, company reputation and future medical advances. 2 The unique pharmaceutical labeling challenge The process to create a new drug is extremely complex. While a translation management system will benefit many parts of the process, this white paper will focus exclusively on the complexities of drug labeling. There are several important requirements for language translation in the labeling process: • During the label change process, regulators require that the science team mark all requested amendments in the original submission using Microsoft Word’s “Track Changes” and “Comments” feature. • The applicant then must prove that all changes in the source documents have been adequately reflected in each of the targeted languages, again using Microsoft Word “Track Changes” and “Comments. • The regulations further stipulate that there be proof that no other portions of the text have been altered in any way. Label changes (on top of label changes) Formal regulations, which vary by geography, stipulate how PI has to pass regulatory review. In the EU, PI validation must be done in 24 languages. Moreover, global pharmaceutical companies are required to conduct business in 50+ languages, with data requiring constant updates and regional coordination. Currently, there are a limited number of new chemical or biological substances which are entering the market as initial submissions. However, advances in medical practice and pharmacovigilance are driving the requirements for continual updates of PI across the globe. In practice, this means that every drug manufacturer with an active portfolio is facing thousands of yearly updates to required translation projects with very tight timelines, hundreds of stakeholders and strict procedures in order to gain regulatory approvals. Managing changes in this mandated way creates technical challenges for labeling managers beyond just language translation. Most automated translation solutions today work on the entire body of the text and do not support the processing of tracked changes in the way outlined by governmental regulations. Generally available translation tools have not been designed to support these specialized requirements. Additionally, current systems are not concerned with recording, preserving and displaying an audit trail of the changes in the final output. In most non-regulated instances, users are only concerned with seeing the final translated document as it will be seen by the end user. However, when regulators review translated PI they also want to see the final translated content with tracked changes. Why does this have far-reaching consequences? • Since conventional translation management tools do not support this unique requirement, a parallel manual process must exist in the pharma industry to preserve the history of the changes. All changes have to be painstakingly and very accurately re-introduced into the final delivery documents. This is tedious manual work requiring costly overhead, particularly in the tight time spans required by regulations. White Paper | SDL Pharma Labeling Solution • After re-submission to the regulatory bodies, the reviewer again uses the “Track Changes” tool to make further comments. As a result of the tight timeframes of the process, these changes rarely find their way back into the automated processes of conventional translation tools. This negatively affects future label update submissions as the new changes will not benefit from previous updates. • Not being able to use a specialized translation management tool forces manual re-formatting of the final document when translating directly in Microsoft Word. In addition, the inability to review source and translated documents side by side makes analyzing translation changes difficult. • The requirement to maintain non-changed content exactly as in the original demands the ability to lock segments of the content. This is a feature not generally found in translation management systems. Under the short timelines demanded for the labeling change process, highly paid medical professionals are often pulled into manual translation tasks instead of managing tasks for which they were hired. A specialized language translation management system can significantly lower the multilingual work load, improve the quality of the final product, decrease associated costs and free valuable staff member time in managing the labeling process. While most industries today enjoy lower cost and higher translation efficiencies from using a translation management system, the specialized requirements of the pharmaceutical industry means that unless they use a system specifically built to support them, they cannot gain those benefits for their labeling process. Most of today’s translation management systems cannot handle Word-based labeling and review procedures. 3 SDL Pharma Labeling Solution A translation management system built to support the multilingual labeling process SDL has designed and built a translation management system to optimize the pharma labeling process. By enabling this new solution to handle Microsoft Word documents with source and target language tracked changes, SDL now offers highly tangible benefits to pharmaceutical companies, including fast label changes and quick creation of consistent, high-quality global product information. SDL WorldServer, the industry leading translation management system, now has these capabilities. When SDL WorldServer is combined with SDL Trados Studio translation editing tools and services experienced with working with the pharma industry, this creates a comprehensive, industry-unique labeling solution. The mandated way of handling Tracked Changes and Comments SDL’s Pharma Labeling Solution changes the way labeling information is processed. SDL has taken the necessary steps to enable its offering to address the very specific requirements of handling labeling documents. These include: Handling Tracked Changes during translation The translation editing process is enabled to efficiently handle tracked changes and regulator comments in the source and target languages. Various use cases are associated with this capability. These include, but are not limited to: 1. Using documents that have been amended using Tracked Changes 2. Improved internal review using Tracked Changes 3. Improved regulator review of the target language file with and without Tracked Changes 4. Preparation of file bundles going into regulator review (including the Microsoft Word document with and without tracked changes) 5. Toggling Tracked Changes across source and target segments to see different versions (original, final, final with markup) SDL Trados Studio is a translation editing tool that makes local language translators more efficient and effective. With a direct connection to SDL WorldServer, documents requiring translation are distributed to target translators. Given the short times frames required by regulations, optimized translation communication is required. White Paper | SDL Pharma Labeling Solution 4 The following screenshot from the translation editor in SDL Trados Studio demonstrates how changes are tracked and preserved between the source and target language documents. Figure 1: Translation of amended PI Protecting unchanged text during PI updates The SDL Pharma Labeling Solution will automatically lock down parts of the text to avoid unwanted changes. This increases the turn-around time for label changes, as it eliminates unnecessary translation or review work not in scope of the required label change. In the Figure below, the darkened text is visible to the translator to provide translation context, but they are unable to make any changes. Figure 2: Lock down of text not requiring translation White Paper | SDL Pharma Labeling Solution In addition to the ability to use Microsoft Word documents, SDL WorldServer has two key components that greatly improve translation quality and efficiency. They are: Translation memory (TM) Translation memory (TM) allows a translator to boost productivity while at the same time make translations more consistent. Technically, TM is a translation editor with a database which systematically stores all final regulator approved translations. Translators then use this database to identify content for which there are already approved translations. The TM will also identify new content and retrieve similar or “fuzzy” translations that translators can use to speed up their process. The benefits of a well-functioning TM include a reduction in the cost for translations as content is not needlessly retranslated, and more consistent translations over time. 5 SDL WorldServer enables centralized control of the translation process SDL WorldServer allows pharmaceutical teams in headquarters and affiliate functions to automate many of the manual work steps and manage the entire translation process programmatically. A single instance of SDL WorldServer ensures that all previous translation work and regulatory reviews are applied consistently to all new translation work. It enforces a consistent use and control of core corporate and drug terminology. There are many benefits to the labeling process of using a single translation system beyond the ability to create documents in Word, as described previously: • Each individual request for a label change creates a complex set of tasks across the multiple languages targeted. If done manually, translation managers would have to communicate individually with dozens of translators and reviewers. SDL WorldServer automates this entire process and can reduce the number of human steps to as few as four per document. • In addition to automation of manual work steps, a translation management system tracks where each document is in the translation process. At a glance, the project manager can see if the translation requests have been received, if the work is in process and what percentage of the documents have final translations available. • If a new language is added to the required target list, or a new document type requires a unique translation process, these can be added centrally and easily and then have automatic implementation for all future reviews. • SDL WorldServer can track the costs of document translation services if these are required for individual product line P&Ls. Terminology management Terminology management is an organized record of controlled words and phrases combined with their standard or mandated translations. This database allows you to manage commonly used words as well as slogans or corporate phrases that must be translated in a particular way (for example, a company tag line, product or feature name). This eliminates subtle translation changes being introduced and maintains the quality and consistency of local language content with that of the source material. This is particularly important in the pharma industry, as drug terms have very precise meanings and these need to be preserved through the translation process. White Paper | SDL Pharma Labeling Solution 6 Other features of the SDL Pharma Label translation SDL’s new and unique approach unlocks the translation reuse mechanisms and the typical benefits from translation technology for labeling. Translation Memory and Terminology Management become applicable for labeling documents and can help lower the burden and cost in handling global product registrations. In the following, a few additional benefits are presented. Handling standard headers and standard text Involving the experts in the review Handling complex products with multiple strength and presentations The new SDL solution for global labeling simplifies the review of translated documents by both internal and external experts. The SDL solution can automatically create a Microsoft Word document which allows the reviewer to assess whether the requested changes are adequately reflected in the translations. The document clearly highlights the relevant text parts and allows the reviewer to use Tracked Changes and comments during the review step. All changes from the reviewer are then captured back in SDL WorldServer as a base for future amendments. Figure 3: Auto-propagate identical text parts Regulations require very specific “boiler-plate” translations, including headers or other standard textual portions of the document. During new document creation, these formats can automatically be inserted and then be locked against accidental changes. Complex pharmaceutical products are often brought to market in a wide range of strengths (e.g., 100ml or 150ml) or presentations (e.g., as a tablet, vial or cartridge). The more complex the product, the more redundant text parts have to be handled during new marketing authorization procedures. Using the SDL Pharma Labeling Solution, the translation editor ensures that identical text parts are automatically propagated across the documents. This mechanism of auto-propagation allows for highly consistent PI. The following screenshot demonstrates this mechanism. White Paper | SDL Pharma Labeling Solution 7 Process setup and workflow definition pays dividends for every labeling project Critical to the successful deployment of the SDL Pharma Labeling Solution is working with the enterprise experts to customize the workflows prior to deployment. SDL Language Solutions experts have studied and deployed literally hundreds of translation processes in industries of all kinds. They understand common translation pitfalls and are experts on the SDL technologies that compose the solution. Language Solutions experts will cover: • Linguistic Source Analysis – Translation experts will examine the existing labeling content and identify potential problems. They will review and analyze existing translation materials and clarify any linguistic questions. Jointly with the Pharma experts, translation best practice guidelines will be developed to ensure compliance with latest global regulations. • Linguistic Alignment & Strategy – SDL experts will work to create a single, high-quality translation database and a single terminology manager populated with all mandated phrases, terms and approved labeling translations. Then they will define a translation strategy to meet the business and regulatory requirements for the sponsor. • Process & Training – Using the strategy, the workflow features of SDL WorldServer will be customized to enforce the correct labeling document flow, from the central team, to affiliates, translators and the regulators. As part of this process, SDL will train and educate the stakeholders on the linguistic tools to support current and future labeling requirements. Following these initial steps will ensure a “fix once and for all” principle that will benefit every subsequent translation project. White Paper | SDL Pharma Labeling Solution 8 Summary The SDL Pharma Labeling Solution has been developed to enable the automation of the unique process required by pharmaceutical regulators. This solution can significantly reduce the efforts in labeling translations, improve quality and significantly lower the amount of administrative overhead typical of other translation tools. The majority of today’s translation management systems cannot handle the mandate of Microsft Word-based labeling procedures. SDL has met this challenge by enabling a Word-based translation process. There are four major benefits of the SDL innovation. The SDL Pharma Labeling Solution allows companies to: 1. Meet the aggressive mandated PI translation time windows by efficiently managing the frequent label changes during product maintenance in the linguistic phases. 2. Automate the translation process and unburden all stakeholders from many of the manual tasks such as formatting, tracking and routing work requests. 3. Lower translation workloads through the use of translation memory and terminology management so that pharma companies are paying for translations of only new content. 4. Improve the quality of the final labeling content by simplifying the review and linguistic quality assurance process With special focus on the initial set up of the SDL solution, these benefits can accrue automatically to all subsequent projects. These benefits shorten the translation process so labeling changes can occur within the tight windows mandated by regulators. Through this total solution of enhanced products and pharma-specific setup and training, SDL provides pharma companies with quantifiable benefits of faster performance, reduced administrative burdens and higher quality labeling output. SDL (LSE: SDL) allows companies to optimize their customers’ experience across the entire buyer journey. Through its web content management, analytics, social intelligence, campaign management and translation services, SDL helps organizations leverage data-driven insights to understand what their customers want, orchestrate relevant content and communications, and deliver engaging and contextual experiences across languages, cultures, channels and devices. For more information, visit www.sdl.com SDL has over 1,500 enterprise customers, over 400 partners and a global infrastructure of 70 offices in 38 countries. We also work with 72 of the top 100 global brands. SDL_wp_tech_Unravelling Mobile_EN_A4 Copyright © 2014 SDL plc. All Rights Reserved. All company product or service names referenced herein are properties of their respective owners.
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