Transcript Slide 1

Selling Your Pharmaceutical Products to
USA, Europe and ASEAN Countries
Regulations and Registrations
Ludwig Huber, Ph.D
Chief Advisor, Global FDA Compliance
Ludwig Huber
Phone: +49 7902 980582
E-mail:
[email protected]
Page 1
Overview
Regulations and Guidelines: Overview
• Regulations along the drug life
• Good Laboratory Practices, Good Clinical Practices
• Good Manufacturing Practices
Organizations Overview: Roles and responsibilities
• Local healthcare agencies: FDA, EMA
• International healthcare: ICH, PIC/S, WHO
• Pharmacopeias: EP, USP, JP, CP
• Industry Organizations: ISPE, GAMP
Registration Processes
Required documentation
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Ludwig Huber - LabCompliance
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Regulations and Quality Standards
Type
Application
Industry
Controlled by
Good Laboratory
Practice
Preclinical,
toxicology studies
Pharma
development
Healthcare
Agencies
(+ Env. agencies)
Good Clinical
Practice
Clinical trials
Pharma
CRO
Healthcare
Agencies
Good
Manufacturing
Practice
Manufacturing
Quality control
Pharma
manufacturing,
quality control labs
Healthcare
Agencies
ISO 17025
Testing and
Calibration
Food, environm,
chemical
Private/public
accreditation
bodies
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Slide 3
Value of ISO 17025
Product shipped from country A to B
Country A
Country B
• Routine testing only tested in one accredited laboratory of
country A
• International comparability of test results through
traceability to the same standard
• Confidence in test results through validated methods and
estimated and documented measurement uncertainty
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Ludwig Huber - LabCompliance
Slide 4
Regulations Along the Drug Life
Basic
Research
Drug
Preclinical
Preclinical
Discovery Development
Development
GLP
Not Regulated
Clinical
Trials
Phase I, II, III
GCP
Manufacturing
incl. APIs
QC Laboratories
GMP
21 CFR 11 Electronic Records&Signatures
Lead to
Drug Target
IND
Submission &
Review
BLA/NDA
Submission &
Review
Post
Marketing
Surveillance
Safety, Quality, Efficacy
GLP = Good Laboratory Practices
GMP = Good Manufacturing Practices
GCP = Good Clinical Practices
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GxP = GLP+GCP+GMP = Predicate Rules
IND = Investigational New Drug Application
BLA = Biologic License Application
NDA = New Drug Application
Ludwig Huber - LabCompliance
Slide 5
FDA Regulations Along the Drug Life
Regulated
BioEquivalency
Studies
BioEquivalency
Manufacturing
incl. APIs
QC Laboratories
GMP
21 CFR 11 Electronic Records&Signatures
ANDA
Submission &
Review
Post
Marketing
Surveillance
Safety, Quality, Efficacy
GMP = Good Manufacturing Practices GxP = GLP+GCP+GMP = Predicate Rules
ANDA = Abbreviated New Drug Application
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Ludwig Huber - LabCompliance
Slide 6
Key GLP Requirements
General Quality System
• Documentation
• Personnel
• Facilities
• Equipment calibration and maintenance
• Validation of procedures and methods
Specific to GLP
• Appointment of study director
• Study plan and study protocol
• Appointment of an archivist
• Specific QAU responsibilities (e.g., approval of study)
• Retention of samples and records
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Slide 7
Key GCP Requirements
General Quality System
• Quality assurance system (equipment, validation of
procedures)
• Record keeping, Qualified personnel
Specific to GCP
• Primacy of subjects rights vs. ther interests of study
• Scientifically sound protocol
• Supporting data (from pre-clinical or clinical studies)
• Investigational drugs manufactured under GMPs
• Subject confidentiality
• Informed consent obtained from subjects
• Favorable risk benefit balance
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Slide 8
Key GMP Requirements
General Quality System
• Quality Assurance System
– Personnel, equipment, computer systems,
documentation, subcontractors, self inspection,
handling complaints, Out-of-specification results
Specific to GMP
• Raw materials
• Process validation
• Validation of methods and procedures
• Cleaning validation
• Dealing with OOS situations through failure
investigations
• Integrity, authenticity, availability of records
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Slide 9
Electronic Records & Signatures
FDA/EU Regulation
• 21 CFR Part 11, EU Annex 11 to EU GMP
Objective
• Using e-records and signatures must be as trustworthy
and reliable as using paper records and handwritten
signatures
Requirements
• Validation of computerized systems,
• Limited and authorized access to computer systems
• Electronic audit trail, review of electronic audit trail
• Accurate and complete copies of records,
• Instant availability of e-records
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Slide 10
Organizations and Regulations
Canada
GMP
EU Directive
and Annex
EMA
EP
Pharmacopeia
China GMP, SFDA
Pharmacopeia
US FDA
Regulations
Japan-MHLW
Pharmacopeia
US FDA
Inspection
Policy Guides
USP
ASEAN
Harmonization
ANVISA
TGA/GMP (PICS)
Pharmaceutical Inspection Convention Scheme (PIC/S)
WHO, ICH, ISO
(Australian) Therapeutic Goods Administration, , ICH-International Conference for Harmonization, FDA = Food
and Drug Administration, WHO = World Health Organization, USP – United States Pharmacopeia, EU =
European Union, ASEAN = Association of 10 South East Asian Nations
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United States Food and Drug
Administration (FDA)
Member
• United States Government
Tasks
• Promulgates and enforces US regulations
Impact
• By far the highest impact on pharmaceutical industry through
toughest enforcement. Can stop manufacturing in the US or stop
import.
Examples for documents
• 21 Series Code of Regulations (CFR), e.g., Good Laboratory
Practices, Good Manufacturing Practices for drugs and medical
devices , Good Clinical Practices, Food Additives, Electronic
records (Part 11), related guidance and inspection guides
Website
• www.fda.gov
Corresponding agencies in other countries
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World Health Organization (WHO)
Member
• All countries which are Members of the United Nations may
become members of WHO by accepting its Constitution.
In 2013 192 members
Tasks
• Develops GMP guidelines and training material, contracts drugs
and APIs mainly used by development countries
Impact
• High impact on development countries.
Guidelines use as source for local regulations.
Drug and API contractors must comply and are audited by WHO
Examples for documents
• GLMs, GLP Training documentation
Website
• www.who.int
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International Conference for
Harmonization (ICH)
Members
• Industry and government,
• Industrial countries (US/Canada/EU/Japan)
Tasks
• Develops guidelines on selected topics
Impact
• Guidelines signed into regulations in most member countries
• Entered into the federal register in the US, but not in regulation
Examples for documents
• Active pharmaceutical ingredients (Q7 for GMPs of APIs). ICH Q2
for method validation, ICH Q10 for Quality Systems, ICH Q9 for risk
assessment. M4 Series Common Technical Documents (and
eCTDs) for drug registration
Website
• www.ich.org
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Page 14
United States Pharmacopeia (USP)
Offices
• United States, Europe, India, China
Tasks
• Develops legally binding standards for FDA regulated industry;
for techniques and methods
Impact
• Binding standards for FDA regulated industry
Examples for documents
• Chromatographic system suitability testing, Dissolution testing,
Analytical Instrument Qualification, method change vs. adjustment
Website
• www.USP.org
Corresponding organizations in EU (EP), China (ChP) and Japan (JP)
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Pharmaceutical Inspection Convention
Scheme (PIC/S)
Members
• 43 Regulatory Agencies EU, Australia, Canada, Singapore, Malaysia,
Argentina, South Africa, US FDA, Indonesia, Taiwan, New Zealand
Waiting list: Thailand, Philippines
• Tasks
• Develops GMP type standards and guidelines for inspectors and
GMP standards similar to EU, WHO
Impact
• Guidelines becoming regulations in Singapore, Australia, Switzerland
• Guidelines seen as standard by industry in EU and SE Asia
Examples for documents
• GMP Guides, QC Lab training Guide, Good computer practices,
validation master plan, API facilities inspection guide, Annex 11
Website
• www.picscheme.org
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International Society for
Pharmaceutical Engineering
(ISPE)
Members
• Industry, organizations in EU, America, Japan
Tasks
• On-line shop for GAMP products, provides trainings around
the world, consulting agencies e.g., US FDA
Impact
• High influence on US FDA and EMA
Examples for documents
• Authored Part 11 white paper and influenced new FDA Part
11 Guide
• ISPE Journal
Website
• www.ISPE.org
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Page 17
Good Automated Manufacturing
Practice (GAMP) Forum
Members
• Industry from Europe, America
Tasks
• Develops guidelines on using automated systems in
regulated industry
Impact
• Industry standard, referenced by Agencies, e.g, FDA, EU
Examples for documents
• GAMP 5 - Validation of computer systems
• Electronic records, signatures, archiving
• Network qualification
Website
• www.ispe.org
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ASEAN Mutual Recognition Agreement
• 10 member countries
• Signed in April 2009
• Goal: Mutual recognition of
GMP inspections
• Likely to follow PIC/S GMPs
• Will increase pressure on companies without recognized
GMPs (e.g., PIC/S) through increased competitiveness
• Officially came into force on Jan 1, 2011
• Procedure to get mutual recognition for GMP certificates
and inspection reports established
ASEAN - Association of Southeast Asian Nations
Brunei Darussalam, Cambodia Indonesia, LAO PDR, Malaysia,
Myanmar, Philippines, Singapore, Thailand, Vietnam
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Page 19
Procedure for Recognition of GMP
Inspection Certificates in ASEAN
Countries
• ASEAN Joint Sectoral Committee (JSC) on GMP
Inspection was set up in 2011 with Singapore as chair
• ASEAN members submit applications for listing
• ASEAM PIC/S members are listed without further
assessment (Singapore, Malaysia, Indonesia)
• Non-PIC/S-members must be assessed though a Panel
of Experts formed by JSC
• After assessment the Panel of Experts will submit the
recommendation to JSC
• Listed members can exchange GMP certificates and
inspection reports
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Page 20
Registration in the United States
• Small molecule chemical based generic and innovator
drugs are registered through the Center for Drug
Evaluation and Research (CDER).
• Biological drugs and generic versions through the Center
for Biologics Evaluation and Research
• Main required documents: Investigtional New Drug
Application (IND), New drug application (NDA), Biologic
licence application (BLA) and for generics the
Abbreviated New Drug Application (ANDA)
Foreign Companies need an US based Agent as contact to FDA
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Page 21
FDA Marketing Authorization
Based on quality, safety and efficacy data from
• Pre-clinical studies – focus on safety
• Clinical studies – focus on efficacy
Can easily be 100 000 or more printed pages
Relevant FDA Regulations
• 21 CFR 314 (New drug application)
• 21 CFR 601 (Biologic license application)
Relevant Guidelines
• Common (Electronic) Technical Documents (CTD), ICH M4, M4Q,
M4S, M4E (accepted by FDA)
FDA Form 356h and Instructions for filling out
• Instructions for Filling out Form FDA 356h – Application To Market
A New Or Abbreviated New Drug Or Biologic for Human Use
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Slide 22
FDA Form 356h
US Agent
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Slide 23
Marketing Authorization Process
• Applicant requests a pre-submission meeting with FDA
• Applicant submits NDA to CDER or CBER (paper or electronic)
• Preliminary technical screening and response within 60 days (e.g.,
completeness)
• Review conducted by a team of technical specialists from
different offices (chemists, physicians, statisticians,
pharmacologists)
• FDA informs applicants for easily correctable deficiencies
• Applicant resubmits NDA
• FDA prepares preliminary review report
• FDA may conduct GMP inspections
• Final review by appropriate Director (may consult advisory team)
• Action letter issued within 180 days of the start of the review,
unless extension agreed with applicant
• Approval issued if submission acceptable
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Slide 24
Registration in Europe
• Through the European Medicines Agency (EMA)
• Marketing authorization can be applied through
– Centralied procedure (most common)
– National procedure: only applied if registration is
desired in a single country
– Mutually recognized procedure: useful to extend
single country application to all Europe
• Biological drug applications are evaluated through the
centralized procedured by EMA.
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Page 25
Required Documentation
Policy
Master
Plan
High level, strategic documentation
(regulations, business, quality)
Training
Maintenance
Validation, Audits
Test procedures
Operation manuals,
QC procedures
Process related
documentation, approaches
(SOPs)
Product/event related documentation
(work instructions, also called SOPs
or test scripts, protocols)
Product test records, batch
records, validation results,
training records, chromatograms
Compliance Records
(batch/event related
documentation)
Use the same set throughout the
organization
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Slide 26
Inspections and Documentation
Example: US FDA
• 483 Form Inspection Observation
– only deviations listed
– written for inspection exit meeting
• Establishment Inspection Report (EIR)
– very detailed
– more like an inspection protocol
• Warning Letter
– Reviewed by FDA centers
Look for examples on www.fdawarningletter.com
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483 Form Inspectional
Observations
• Written during or after the inspection
• Discussed with and handed out to the
user firm in the inspection exit meeting
• May reflect the view of single inspector
• Major problem: inconsistency
• Available to the public, including to competition, through
FOI (Freedom of information)
• Can have negative impact on company’s reputation
• Can have other consequences: withholding product
approvals
• Compamies are advised to respond within 15 business
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Slide 28
Establishment Inspection
Reports (EIR)
• Written when the inspector is back in the office
• Very detailed inspection protocol, e.g., lists
question/answers and positive and negative findings
• Observations are classified as “No action indicated
(NAI) ”, “Voluntary Action Indicated (VAI), or “Official
action indicated (OAI)”
• Reviewed by regional headquarter office
• Most Helpful in preparation for FDA inspections
• Available through FOI and private service providers
(e.g., some are listed on www.fdawarningletter.com)
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Slide 29
Warning Letters
• Issued in case of severe deviations
• Reviewed by higher level FDA officials in FDA
centers
• Frequently make reference to 483 inspection
observations and to company responses because
of inadequate response
• Companies must respond within 15 days with
corrective action plan
• Typically follow inspection scheduled
• The FDA publishes warning letters
http://www.fda.gov/ICECI/EnforcementActions/War
ningLetters/
www.fdawarningletter.com
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