All blueprints

Manufacturing that evolves with your therapy.

Chain of identity, custody and release evidence carried through every patient’s lot. Neil, your AI agent, prepares each process change for your team to verify and release.

Illustration of a seal beside a microscope, screening plate and cryovials.
Receipts › RCV-014

CT-014 starting material

Identity
Typed by hand
Collected
Not recorded
Procedures › Receipt
v05
Scan
Expected identity
Record
Collection time
Hold
Unresolved identity
Receipts › RCV-015

Collection to receipt

Identity
P-015, scanned

Figure 1. Neil drafts the receipt check as a new procedure version; your team verifies and releases it.

Summary

The problem
Chain of identity is often a labelling step that is not connected to the floor, and a batch record assumes starting material that patient cells rarely provide. A mix-up or a slow review can cost a patient their treatment window.
Seal’s approach
Patient or donor identity, material genealogy, process versions and release evidence belong to one record. A mismatched scan stops the step, the batch record branches on what the cells do, and QA reviews while the batch runs.
Neil
Seal’s AI agent builds receipt and handoff checks, exception paths and process revisions from your requirements, and assembles the evidence for release. Your team verifies and releases each change. About Neil.
What changes
Collection sites, logistics, manufacturing and QA work from the same record, so status, identity checks and release evidence are already assembled when the next party needs them.
Where to start
One patient or donor lineage from collection to release, including a mismatched scan and a failed viability check. Book a demo.

1A traditional MES records the batch. Seal carries the patient through it.

A traditional MES was built for a process that runs the same way every time, on material that arrives as specified. In cell and gene therapy, chain of identity often sits in a labelling system that is not connected to the manufacturing floor, the batch record assumes starting material that patient cells rarely provide, and review begins when manufacture ends. Each handoff between separate systems is a gap in the data.

Seal is where the work runs. The product, the patient or donor identity, material genealogy, process versions, actual work and release evidence belong to the same model. The identity check is part of each step, the batch record follows what the cells do, and release evidence is assembled while the batch runs.

A traditional MESSeal
Chain of identityA label scanned beside the recordPart of every material record
A mismatched scanA warning that can be dismissedA stop until it is resolved
Patient materialCorrected by handBranches on the recorded measurement
ReleaseReview after manufactureReview while the batch runs
Clinical sitesStatus from a separate portalRead from the same record
Process changeA revalidation projectA new version; old lots keep theirs
AIText to paste elsewhereNeil proposes a configured change

A therapy’s manufacturing operation must develop alongside the science. Starting material, analytical methods, equipment and the process itself can change between early studies and routine production. In Seal, each change becomes the next version of the workflow, assessed for its intended use and released under change control, while the lots already made keep the basis they were made on.

2Neil prepares the change. Your team decides.

Neil is Seal’s AI agent. It works across the same records your team does, within the permissions of the person asking, and what it produces is work in the system: a receipt check, an exception path, a process revision or an assembled release package. It does not hand back text to paste somewhere else.

Neil preparesYour team decides
Handoff checksIdentity checks and exception pathsWhether they fit the product
VerificationThe cases to testWhether the behaviour is right
Process revisionThe next study or process draftWhat has been established
LineageThe descendants of an affected sourceImpact and disposition
ReleaseThe evidence for each requirementThe release decision
Procedures › Receipt
draftv05

Build receipt checks that tie each incoming container to its expected material, identity and collection time.

Neil

  • A scan compared with the expected material and identity.
  • Collection and receipt times, with their time zones.
  • A hold when identity or required evidence is unresolved.
  • Cases to verify: another identity, a missing collection time.
  • Draft (met)Prepared, with sources
  • Verification (not met)For your team
  • Release (not met)Under change control
Figure 2. Neil prepares the receipt check and the cases to verify; your team verifies and releases it

Give Neil the receipt requirements and it prepares the identity checks, the exception paths and the cases your team needs to verify: a container that belongs to another identity, a missing collection time, a new version taking effect. Everything it produces is preparation. Nothing takes effect until a qualified person has reviewed it, and lots already in progress keep the version they started with.

In line with the EU’s draft GMP Annex 22 on AI, Neil is not used in GMP execution. It helps set up configuration, which your team verifies and releases under change control. Customer data is not used to train AI models, and the requester’s permissions govern what Neil can read. See how Neil fits Annex 22 and more about Neil.

3Make chain of identity the data model.

Chain of identity is often handled by a labelling system that is not connected to the manufacturing floor: it generates barcodes and relies on someone scanning them. Seal makes chain of identity part of the record structure itself.

Collections › COL-014
Patient
P-014
Container
C-014
Lots › CT-014
Patient
P-014
Started from
COL-014
CT-014 › Containers
CT-014-A
P-014
CT-014-B
P-014
Figure 3. The coded identity P-014 is part of the collection, the lot and each final container

Each relevant material record carries a link to the configured patient or donor identity. The apheresis bag records the patient it came from. The cryovial records the patient it belongs to. The batch record records whose cells it is processing. When a technician scans a vial, Seal records the scan and checks the identity against the batch.

That check applies at each step, transfer and handoff. The chain is enforced as the work runs, and documented as a result.

4Block a mismatch rather than warn about it.

A warning dialog relies on the person reading it. Configure a mismatch as a stop instead: when a scanned container does not match the current batch’s patient, the step cannot proceed.

Lots › CT-016 › Receipt
stopped
Expected
P-016
Scanned
P-061

Supervisor review and a deviation before processing resumes

Figure 4. A container scanned with another patient’s identity stops the step until a supervisor resolves it

Under time pressure, people click through warnings they have seen many times. Across thousands of patient batches, a small override rate becomes a real risk.

The exception path requires supervisor involvement and deviation documentation, with the mismatch logged, investigated and resolved before processing resumes. An unreadable label stops the step in the same way, until the material is resolved against its authorised source record. A matching scan satisfies only the identity check; material status, timing and the remaining receipt checks still govern progression.

Configured checks at each handoff stop material being released to the wrong batch, and product being shipped against the wrong patient. Each point where a mix-up could occur can have a gate that prevents progression with mismatched identities.

5Model the product, the material and the patient separately.

The ontology needs to represent more than a patient identifier on a batch. Define the product, process version, patient or donor reference, collection, incoming material, manufacturing lot, intermediate, sample and final container, and link each transformation and custody event to the objects it affects.

ModelIdentity followsThe record must answer
Autologous cellsPatient to final containerIs this material this patient’s?
Allogeneic cellsDonor, banks, lots and unitsWhich units share a source?
Viral vectorConstruct, bank, pools, lotsWhich lots share an input?

That gives the team a route from a released unit to its starting material, processing history and evidence. A platform that models only one patient and one batch cannot describe every cell or gene therapy operation, so configure the model around the product rather than forcing these relationships into a single genealogy. A split creates identified descendants; a pool records all contributing inputs; a sample keeps its source and collection point. Record quantities and dispositions so material use can be reconciled through the process.

Autologous workflows are patient-centric: the patient ID organises the record from collection to infusion, including repeated collections, split material and multiple containers. Allogeneic workflows are donor-centric: lots are tracked from donation through banks and manufacturing, with genealogy connecting donor material to every patient who receives product derived from it. Chain of identity, dynamic batch records and concurrent release apply to both; what differs is how identity is tracked and how genealogy is structured. The autologous, allogeneic and viral vector blueprints describe each model in detail.

Use coded identity references in operational views, with access to identifying information limited to the roles that need it. US tracking rules for HCT/Ps require a distinct identification code that relates the product to its donor and its records, and the code may not include the person’s name or medical record number.¹ A courier, laboratory analyst and clinical coordinator have different jobs. Configure what each can read or change, including documents, labels and linked records, and carry the access design through to exports and integrations.

6Let the batch record respond to the material.

Patient cells vary in quality, quantity and behaviour. Seal batch records branch on recorded measurements, so the record follows what the material needs.

Lots › CT-014 › Day 7 count
culture extended
Viable cells
Below target
Viability
Within the continuation range
Rule
BR-CT-04: culture to Day 10
Added
A repeat count, a new harvest date
Figure 5. Rule BR-CT-04: a Day 7 viable-cell count below target extends culture to Day 10, with a repeat count and a new harvest date

A process tuned for ideal starting material has to accommodate the variation of real patient material. A static batch record assumes consistent input, and deviations from the plan end up as handwritten corrections that a reviewer must interpret later.

A low cell count can route the batch to an expanded culture protocol. Viability below threshold can alert QA and open an investigation workflow. When a step runs long, time-limit tracking shows how much margin remains.

The record reflects how the batch actually ran, including the branches the material required.

7Review the batch while it runs.

A product whose shelf life is measured in hours or days cannot wait for a review measured in weeks. In Seal, QA reviews data during the batch, and the release evidence is assembled as each result is accepted.

Release › CT-014-A
review open
  • Identity (met)Reconciled to P-014
  • Batch record (met)Reviewed during the run
  • Viability (met)Accepted
  • Deviations (met)None open
  • Sterility (not met)Result awaited
  • Decision (not met)For the authorised person
Figure 6. Release requirements for CT-014-A, each in its own state, with sterility still open

The sequence of manufacture, then review, then release does not fit a product made of living cells. EU GMP for advanced therapies recognises that some products must be released before all quality control tests are complete, with certification organised in stages.² Test results are reviewed as they arrive and deviations are investigated as they occur. The Certificate of Analysis is assembled incrementally as each test is accepted.

The authorised reviewer assesses the complete product-specific release package, including identity, required results, deviations and unresolved conditions. The release decision stays with the quality unit; the evidence can be assembled as the work progresses.

7.1Preserve the state of every release requirement.

Configure the product’s review plan around manufacturing completion, identity reconciliation, analytical results, deviations, required assessments and the authorised release decision. Record the source and review state for each requirement. A result can be available, awaiting review, accepted, invalidated or superseded; those states should remain distinguishable.

Where the applicable product strategy permits a result to arrive after an earlier release stage, retain the rationale, required decision and follow-up work in the record. Use the product’s approved arrangements to define the workflow. A dashboard showing completed tasks cannot supply that authorisation by itself.

Connect the release decision to the specific containers and label versions in scope. Dispatch, custody and receipt then extend the same history. A late result or subsequent quality event can be traced to the lots and distributions it affects, with follow-up assigned and its outcome retained. The EU guidelines also expect a procedure for a result that is out of specification after release, including liaison with clinical staff.²

8Run the handoffs from collection to infusion on one record.

Cell and gene therapy involves several organisations: the clinical site that performs collection, the logistics provider that manages cryogenic transport, the manufacturing facility that processes the cells and, often, a different clinical site that performs infusion. Seal gives them one view from collection to infusion, each scoped to its own part.

Clinical site 03 › P-014
  1. Collected
  2. Received
  3. In process
  4. QC testing (current)
  5. Released
  6. Shipped
  7. Infused
Figure 7. A clinical site reads its patient’s status from the record manufacturing writes to

Each handoff between separate systems is a gap in the data. In Seal, clinical sites are given scoped access to the same record, where authorised users can coordinate collections and the required information. They receive shipping instructions and tracking information, and they can see when their patient’s product enters manufacturing, progresses through processing, passes QC testing and ships back. When a patient asks where their treatment is, the clinical team can answer from the current record instead of waiting on the manufacturer.

Logistics partners see pickup and delivery requirements. Manufacturing has the context for incoming material before it arrives. Access is scoped so that each site works with its own patients’ records, and the status each party reads comes from the record the others write to. Patient orchestration adds clinic enrolment and collection scheduling on the same platform, and a patient hub connection can exchange selected therapy milestones with a patient-support provider.

A manufacturing slot depends on more than a calendar entry. Collection, transport, receipt, equipment readiness, staff qualification, room availability and the selected process all affect whether work can begin. Represent the dependencies and responsible parties together, with actual status and the source time behind it.

Configure handoffs to record the expected container, identity reference, custody, condition and receipt assessment. An expected arrival, a courier delivery and a manufacturing acceptance are different events. Keep delays, damaged containers, missing records and temperature questions connected to the affected material and the decision about its use.

Within manufacturing, record the event from which each hold or processing clock starts, the applicable time zone and the limit configured for that process version. A rescheduled step needs an assessed plan; changing a calendar entry does not change the underlying time allowance. Where external systems provide events, preserve their references and identify missing or inconsistent timestamps.

These relationships let the operations team see what needs intervention across concurrent lots. They also give a clinical coordinator a useful status for the patient’s product, within the information and actions agreed for that role.

9Carry development knowledge into the manufacturing process.

Development teams need freedom to investigate starting-material variability, culture conditions, recovery, potency and the performance of analytical methods. Configure structured protocols that retain actual conditions, interventions, reagent lots and sample lineage while allowing the study to record departures from its plan.

Link a selected parameter or operating range to the studies and observations behind it. Distinguish a result obtained with one donor, scale or analytical method from a conclusion intended to apply more broadly. When a method, reagent or manufacturing site changes, the team can identify which evidence needs reassessment before carrying the conclusion forward.

Neil can compare the permitted runs, surface missing context and prepare the next study or process draft. The same process definition becomes a starting point for manufacturing, with the required identity checks, sampling, calculations and review gates added for its intended use. Earlier studies keep their original versions; the manufacturing version records what has been established and what remains to be resolved. The process development and technology transfer blueprints follow that route in detail.

10Improve the process while protecting patient records.

Repeated manufacturing work should improve the organisation’s ability to deliver. A recurring custody discrepancy may reveal a missing receipt check. An investigation may show that a timestamp needs a clearer definition. A review may expose a calculation that should be built into the workflow. Capture those lessons as proposed improvements to the process components your team maintains.

Neil can help turn the finding into configuration: a required reference, a revised calculation, an exception path or a review step. Persistent memory can retain relevant context and previous decisions; versioned skills can describe how to prepare a lineage assessment, compare a process revision or assemble release evidence. Specialists can refine these methods as they learn from reviewed work.

Keep patient information, donor characteristics, sequences, product-specific limits and restricted programme results within their authorised scope. Reusable skills should contain methods and approved examples appropriate to their audience. Review remembered content and supporting files before reuse across programmes. A generalised lesson requires scrutiny; removing a patient’s name does not establish that the remaining information can be shared.

For example, a team can reuse a method for verifying the lineage of a pooled intermediate while retaining each programme’s identities and measurements in its own records. The skill defines the relationships and checks to inspect; the agent reads the permitted evidence for the current job. This gives the next programme a better method without requiring a combined pool of restricted records.

11Qualify changes against the way the work can fail.

Use a representative product flow to test the configured system: a mismatched container, an unexpected split, an incomplete custody event, a late analytical result and an operator whose qualification does not cover the activity. Verify the intended response and the evidence left for review. Include label reprints, corrected identifiers and integration interruptions where they are part of the operation.

A proposed process revision should identify the affected instructions, fields, calculations, review paths and integrations. Record requirements, test results, deviations and approval with that revision. Existing lots keep the process version they used, while later work can adopt an approved improvement.

Start with one lineage and one manufacturing workflow, then extend the tested components across products and sites. Evaluate whether the team can reconstruct a material’s history, locate an unresolved release requirement and configure the next workflow with less repeated work. Those are concrete demonstrations of a platform that can evolve with the therapy.

12Show the inspector the control, not only the procedure.

Regulators examine cell and gene therapy manufacturing closely. For HCT/Ps within the scope of 21 CFR 1271.290, US establishments must maintain tracking from donor to consignee or final disposition, and back.¹ EU GMP for advanced therapy medicinal products expects a system that tracks cells and tissues in both directions, from donation through manufacturing to delivery to the recipient, with the traceability data retained for at least 30 years after expiry and available rapidly in case of an adverse reaction.³ Map the product’s applicable requirements into its identity, genealogy and review controls.

Seal captures each scan, validation and decision with its context. When an inspector asks how chain of identity is ensured, the answer can include the configured control that enforces it at each step, alongside the procedure that describes it.

Audit trails and electronic signatures are part of the record rather than added afterwards.⁴ They support the manufacturer’s compliance with the applicable requirements; they do not establish it by being present. Documentation is still required, but much of the evidence is captured as the work is done.

References

  1. 121 CFR 1271.290, Tracking: establishments must maintain a system that tracks each HCT/P from the donor to the consignee or final disposition, and back, using a distinct identification code that may not include the individual’s name, social security number or medical record number (paragraph (c)). eCFR
  2. 2European Commission, Guidelines on Good Manufacturing Practice specific to Advanced Therapy Medicinal Products (2017), EudraLex Volume 4 Part IV, section 11.3.2: batch release before all quality control results are available, certification in stages, and the procedure for out-of-specification results obtained after release. European Commission
  3. 3European Commission, Guidelines on Good Manufacturing Practice specific to Advanced Therapy Medicinal Products (2017), EudraLex Volume 4 Part IV, section 6.6, Traceability data: bidirectional tracking from donation to the recipient, data retained for 30 years and accessible rapidly in case of an adverse reaction. European Commission
  4. 421 CFR Part 11, Electronic Records; Electronic Signatures. eCFR

AConnected across Seal

BCapabilities

CapabilityWhat it covers
Chain of identity enforcementEach scan is checked against the batch; a mismatch stops the step.
Dynamic batch recordsBatch records branch on recorded measurements, such as a low count.
Concurrent releaseQA reviews during the batch; the CoA builds as each test is accepted.
QC integrationResults linked to the batch, feeding the CoA and release prerequisites.
Vein-to-vein visibilityCollection, transport, manufacturing and infusion on one record.
Autologous and allogeneicPatient-centric or donor-centric genealogy on one platform.
Scoped clinical site accessClinical sites see and act on their own patients’ records.

CConnected records

Entity
What it records
Kind
Patient
The individual receiving therapy. In autologous workflows, the patient ID organises the record from collection to infusion.
type
Donation
Apheresis or tissue collection event.
template
Chain of Identity
The identity link from patient to final product, checked at each scan, transfer and handoff.
template
P-014
Coded identity of a patient receiving an autologous therapy.
instance
Donor
The source of material in allogeneic workflows, linked through genealogy to every patient who receives product derived from it.
type
Apheresis Kit
Collection kit carrying unique identifiers that are scanned against the patient and batch.
type
KIT-014
Used for collection COL-014.
instance
Shipment
Logistics record for cryogenic transport, with pickup, transit and delivery status.
type
SH-014
Cryogenic shipment of COL-014 to the manufacturing site.
instance
Batch
Manufacturing record for one patient’s or donor’s material, carrying the identity it is processing.
type
Batch Record
Batch record that branches on recorded measurements, such as an extended culture when a cell count is below target.
template
CT-014
Manufacturing lot processing P-014’s cells.
instance
Product
Final product awaiting release and infusion, labelled with its patient identity.
type
CT-014-A
Final container linked to P-014’s chain of identity.
instance
Certificate of Analysis
Release document assembled incrementally as each test result is accepted.
instance

DQuestions and answers

How do you prevent patient mix-ups?

Each scan checks identity against the batch record. If a scanned item does not match the current batch’s patient, the configured step stops rather than showing a warning that can be dismissed. Processing continues only after supervisor involvement and a documented deviation.

Can this handle both autologous and allogeneic therapies?

Yes. Autologous workflows organise the lineage around the patient, including collections, splits and final containers. Allogeneic workflows trace donor material through banks, manufacturing lots and distributed products. Configure identity checks and genealogy for the actual transformations in each process.

What about time-sensitive processes?

Time limits are tracked from the moment a time-critical step begins, such as four hours from thaw, and the record shows how much margin remains. Operators can be alerted as a limit approaches. If a limit is exceeded, the event is recorded as it happens and routed to investigation.

How does this integrate with clinical sites?

Clinical sites are given scoped access to the same record to schedule collections, enter patient information, follow shipments and see product status. Access is configured so each site works with its own patients’ records rather than manufacturing detail.

What about logistics and cold chain?

Shipment records capture pickup, transit and delivery, with temperature data where the logistics provider supplies it. A transport excursion outside the defined limits can open a deviation linked to the shipment and batch.

How do you handle release for products with short shelf life?

QA reviews data during manufacturing and the CoA is assembled as each test is accepted. When the final release test is accepted, the remaining work is a review of the summary, a final chain-of-identity check and the authorised person’s signature. EU GMP for advanced therapies allows staged certification where a product must be released before all tests are complete.

Can we scale from clinical trials to commercial?

Yes. The same records and chain-of-identity checks apply to the small volumes of a clinical trial and to commercial throughput. Scaling adds batches and sites to the same model rather than changing the controls.

What does Neil do in a cell or gene therapy operation?

Neil is Seal’s AI agent. It builds receipt and handoff checks with their exception paths, prepares the cases to verify, drafts the next study or process revision, follows the lineage of an affected source and assembles the evidence for each release requirement. Everything it produces is a proposal for a qualified person to review.

How does Neil fit the EU’s draft Annex 22 on AI?

Neil is not used in GMP execution. It helps set up configuration, which your team verifies and releases under change control. The regulatory guide explains how this maps to the draft annex.

Can Neil release a product or change a running lot?

No. The release decision stays with the quality unit and the authorised person. A process change takes effect only after your team has verified and released it, and lots already in progress keep the version they started with.

What regulatory frameworks do you support?

Seal provides audit trails, electronic signatures and chain-of-identity records that support the manufacturer’s compliance with requirements such as 21 CFR Part 11, EU Annex 11, 21 CFR 1271 and EU GMP for advanced therapies. The manufacturer remains responsible for its compliance, and system validation documentation can support its submissions.

See your process in Seal.

Bring a procedure or a recurring problem. See how your team can use Neil to configure the workflow, investigate the results and improve the next version.

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