We are delighted to have Michael Edwards join the team at Real Regulatory as a Senior Regulatory Consultant. Michael has worked in regulatory affairs since 2000, having held positions in the UK medicines competent authority, a couple of CRO/consultancies, a couple of small/medium pharmaceutical companies, and as an independent consultant, as well as taking some time out during that time to do post-graduate research and complete a PhD investigating the vascular bioactivity in vitro of the phenolic phytochemicals anthocyanins, and their in vivo degradation products or metabolites, in the Department of Nutrition at Norwich Medical School. His first degree was BSc Pharmacology with Toxicology (First) at King’s College London, including a year-long industrial placement in a large pharmaceutical company research centre. His regulatory experience includes clinical phase through post-marketing authorisation, national and European procedures. Michael will be a valuable asset to our company and to our clients. https://bit.ly/2Ulm2jS
At a recent virtual meeting of the ICH Assembly, the ICH has announced that Turkey’s Medicines and Medical Devices Agency (TITCK) is now one of its regulatory members and that Lebanon’s Ministry of Public Health (MOPH) is now a new observer. During the meeting, the Council also announced that the following guidelines have reached Step 4 in the ICH process: M8 electronic Common Technical Document (eCTD) v4.0 guideline; S11 Nonclinical Safety Testing in Support of Development of Paediatric Pharmaceuticals guideline; and S5(R3) Guideline on Revision of S5 Guideline on Detection of Toxicity to Reproduction for Human Pharmaceuticals. The Council has also announced that the Q3C(R8) guideline on residual solvents, which is currently under revision to include the permitted daily exposures for three new impurities, has reached Step 2 of the ICH process, and that the 4Q(R1) Common Technical Document (CTD) guideline will be revised.
Further updates given by the ICH during the Assembly may be found at the following link: https://bit.ly/RealCMC-2Y63Xai
Joint procedural information is available from EMA and the FDA for medicine developers planning to submit a PIP to EMA and an iPSP, to the FDA, respectively, for a COVID-19 vaccine or treatment, the document can be found under this link https://lnkd.in/d4mespk.
The joint document aims to make it easier for developers to submit paediatric development plans simultaneously to the regulators, to help speed up the development and approval of COVID-19 treatments and vaccines. Both agencies are encouraging medicine developers to submit PIPs and iPSPs early.
The FDA has just released 26 new and 43 revised draft product-specific guidances on the development of generic drugs. The documents are intended to clarify the FDA’s recommendations on demonstrating bioequivalence of generics to the corresponding reference products. The new drafts include recommendations to support ANDAs for generic versions of the acute myeloid leukemia drug gilteritinib, the PARP inhibitor talazoparib, the HIV-1 treatment dolutegravir/lamivudine, fish oil triglycerides, subcutaneous buprenorphine and extended-release metformin. The updated guidance documents include altered recommendations for generic versions of type 2 diabetes drugs dapagliflozin, dapagliflozin and saxagliptin, the renal failure treatment ferric citrate and transdermal buprenorphine.
The European Commission’s updated ‘Annex to the European Commission guideline on Excipients in the labelling and package leaflet of medicinal products for human use’ is effective from 22 November 2019. The guidance describes the information that should be available in the package leaflet on excipients that are known to have a recognised action or effect. In order to ensure compliance with the new guidance, marketing authorisation holders are required to submit a type IB variation within three years from the publication of the revised Annex. HPRA has pointed out that applicants should also be aware that some of the updates included in the Annex were also published in the previous version of the document, therefore, applicants are requested to submit the relevant variations by 9/10/2020.
New measures for all UK arrivals have been announced, including a 14 days’ self-isolation for anyone entering the UK, apart from a “short” list of exemptions. At moment of writing, these measures are due to come into effect on 8 June, although this could change given the backlash from the UK travel industry. The “short list of exemptions” is not really all that short, and amongst the many listed are including the following of note to the pharmaceuticals and clinical trials sectors: qualified persons and responsible persons for human medicines, clinical trials and pharmacovigilance quality assurance inspectors for human medicines sponsors and essential persons needed for clinical trials or studies The new measures can be found at: https://lnkd.in/ddFU_XE
The list of exemptions can be found at: https://lnkd.in/dVUpska
Horseshoe crabs’ blood has long been used in the pharmaceutical industry to detect the presence of bacterial endotoxins, causing concern amongst animal rights groups who are pushing for the use of synthetic alternatives. The USP Microbiology Expert Committee had proposed the inclusion of synthetic recombinant factors in ‘Chapter 85 Bacterial Endotoxins’. Based on public comments received, this will not happen. Instead, a new general chapter will be drafted, to provide guidance on the qualification of alternative tests by demonstrating comparability: <1085.1> Use of Recombinant Reagents in the Bacterial Endotoxins Test – Photometric and Fluorometric Methods Using Recombinantly Derived Reagents The proposed new general chapter should be available for public consultation by November 2020. More information may be found at the following link: https://bit.ly/RealCMC-3eFwASp
This matches the approach taken by Ph. Eur. in 2016 when ‘Chapter 5.1.10 Guidelines for Using the Test for Bacterial Endotoxins’ was updated. Ph. Eur. is further ahead as it has already published a new section ‘2.6.32 Test for bacterial endotoxins using recombinant factor C’ in supplement 10.3, effective from 1 January 2021.
The European Medicines Agency (EMA), European Commission and Heads of Medicines Agencies have updated their ‘Questions and answers on regulatory expectations for medicinal products for human use during the covid-19 pandemic’. The guidance document now includes a new section on temporary flexibilities for good manufacturing practice (GMP) and good distribution practice (GDP) that pharmaceutical companies may employ during the pandemic to ensure an adequate supply of medicines used to treat COVID-19 patients. A new section on the suspension of on-site inspections of plasma collection centres has also been included. Temporary flexibilities related to the duties of the responsible person (RP), the use of new equipment or newly authorized storage and distribution sites, and deviations from normal practice are also discussed in the document. Further information is available at the following link: https://bit.ly/RealCMC-2VYSVnu
The EMA has released several updates to its pre-authorisation and post-authorisation procedural advice for users of the centralised procedure. Some of the updates include:
The EMA now aims to respond to queries within 10 days instead of 5. Other changes as can be seen in the tracked documents linked here: https://lnkd.in/dpW7TF7
The International Council for Harmonisation (ICH) Management Committee and Assembly has indicated that it intends to collaborate more closely with the Pharmaceutical Inspection Co-Operation Scheme (PIC/S) and that new topics and reflection papers are currently under development.
ICH Management Committee has proposed that the PIC/S would be involved in ICH guideline work relevant to regulatory assessor [MG1] and inspector disciplines, during the public consultation following Step 2b. Additionally as an ICH Observer, the PIC/S may also request to be part of Plenary Working Parties which would allow its involvement prior to Step 1.
A revised draft reflection paper on model-informed drug development and an update on a draft reflection paper on patient-focused drug development are also in the pipeline. The Biotechnology Innovation Organization has also proposed to develop a reflection paper on gene therapy harmonization. https://bit.ly/RealCMC-3eagyQe
Pharmeuropa has released new supporting information on the new draft Ph. Eur. Chapter 2.4.35 ‘Extractable elements in plastic materials for pharmaceutical use’, which is open for consultation until the end of June 2020. The document proposes that the long‑established individual tests for specific elements are maintained in the Ph. Eur. general chapters on plastic materials, since the quality of plastic materials influences that of the containers manufactured from them.
In future, cross‑reference to this new general chapter will also be made in each existing Ph. Eur. text on plastic materials. The supporting information also indicates that all the existing Ph. Eur. general chapters on plastic materials should be revised to delete the heavy metals test and to perform the tests on target elements according to the new general chapter. https://bit.ly/RealCMC-3bUORJM
“Field Safety Notices (FSNs) are a key part of the medical device vigilance system. Manufacturers are required to inform users about corrective actions involving their device as soon as possible using a Field Safety Notice (FSN). Published on the 20th May by the MHRA to advise manufacturers on how to write clear FSNs to maximise response rates the guidance provides supplementary information to MEDDEV 2.12/1 rev 8 (how to write and distribute effective FSNs) and covers such topics as good traceability, content, effective targeting of FSNs and Field Safety Corrective Action (FSCA) strategy. Manufacturers are advised to read the document via the following link: https://bit.ly/36hrYiH.
We’re proud to have our Real expert, Dorothée Fouchier, attending the virtual 2nd Joint DIA-EUCOPE Workshop on ATMPs, Innovative Gene and Cell Therapies, next week alongside our industry peers to discuss the challenges, opportunities and political implications of advanced therapies. If you’re also attending, get in touch! To arrange a meeting visit: https://lnkd.in/dc_SDsr
The European Medicines Agency (EMA) has reduced the fee for on-site GMP inspections by 100%. This fee reduction is only applicable in cases where the GMP compliance of a manufacturing site with restricted access due to the COVID-19 pandemic, could not be confirmed via a distant assessment and an on-site inspection is, therefore, required. Fees for Plasma Master Files inspections will also be similarly reduced.
The EMA has also advised that during this initiative, remuneration to national competent authorities (NCA) will not be reduced, if the NCA provides a comprehensive inspection report for the distant assessment and a subsequent independent report for the on-site inspection. Further information is available here: https://bit.ly/RealCMC-2XbhKMr
The scope of EMAs ITF covers regulatory, technical and scientific issues arising from innovative medicines development, new technologies and borderline products. The objective of the interactions with the ITF is to facilitate informal exchange of information and guidance during the product development process. Interactions take the form of informal brainstorming discussions are led by experts from the Agency network, working parties and committees. These meetings are free of charge and 1.5 hours long. ITF has just issued a new briefing meeting request form in order to standardise company initial dialogue. The form can be found here: https://lnkd.in/dTK2axt
The MHRA inspectorate posted ‘How to manage temporary GDP process changes and risks through the COVID-19 pandemic’ on their blog on the 13th May to advise companies on how to manage changes to GDP processes to address exceptional circumstances that have arisen due to Covid-19. Such changes should be documented either as deviations, change controls or similar and incorporate quality risk management principles. Changes may be documented either as single reports or an over-arching one specific to COVID-19. The post has a link to GDP flexibilities introduced by the MHRA to assist with distribution of medicines during COVID-19 pandemic documented in ‘Guidance Exceptional GDP flexibilities for medicines during COVID-19’. The GDP flexibilities introduced cover Supply Chain, Transportation, RP, Facilities & Equipment and Reporting.
Companies applying these flexibilities need to report to Covid19.GMDP@ mhra.gov.uk as outlined in the guidance, however you only need to report once for each flexibility and reports don’t require approval to implement. The post can be accessed via this link: https://bit.ly/2LIjR5g
The 505(b)(2) route to marketing authorisation in the United States has become very popular. Companies owning a product registered (or eligible to be registered) via this pathway might also wish to submit their product in Europe. Real Regulatory can help companies navigate the significant complexities involved in choosing an appropriate legal basis for submission, setting regulatory strategy and dealing with scientific advice and marketing authorisation procedures.
Read the linked article for an overview of the intricacies and the ways in which we can assist. https://lnkd.in/dzjU_Jj
The UK’s Medicines and Healthcare products Regulatory Agency (MHRA) has released a new version of its ‘Application for new Manufacturer’s “Specials” Licence (MS) (Human Use).
To access the new version of the application form please see the following link: https://bit.ly/RealCMC-2ThytN4
EMA has published an overview of how the Agency will accelerate its regulatory procedures so that marketing authorisations of safe, effective and high-quality COVID-19 related medicines can be granted as soon as possible. The rapid procedures described in the inventory https://lnkd.in/deaz5Ki can accelerate every step of a medicine’s regulatory pathway and the Agency is fully mobilised to deliver these fast-track assessments in the shortest possible timeframes while ensuring robust scientific opinions are reached. The text of the press release can be found under https://lnkd.in/d-qhK4B
In particular, EMA will review applications for a PIP, deferrals or waivers for treatments and vaccines for COVID-19 in an expedited manner, in order to speed up an approval. The compliance check can also be expedited, if needed. For these products,
There is also a possibility for the developer to provide a focused scientific documentation, to be agreed on a case-by-case basis. Full details can be found under this link https://lnkd.in/d2SRyn8
EMA’s Scientific Advice Working Party (SAWP) has updated meeting dates in September 2020. The full tabulations under link https://lnkd.in/djmCNCP include deadlines for submissions for scientific advice, protocol assistance, qualification of biomarkers and parallel consultation EMA/EUnetHTA requests.
An updated draft of the impurities guideline for residual solvents, ICH Q3C (R8), has been published. ICH Q3C recommends acceptable amounts for residual solvents in pharmaceuticals, and this draft only contains information on three additional solvents: 2-methyltetrahydrofuran, cyclopentyl methyl ether, and tertiary-butyl alcohol.
The Permitted Daily Exposure (PDE) for each has been set at 50mg/day, 15mg/day and 35mg/day respectively. The document is open for consultation until 30 July 2020. Once agreed upon, this data will be integrated into a complete ICH Q3C (R8) guideline document: https://lnkd.in/gEh9PGU
The EMA has released a new Clinical pharmacology and pharmacokinetics Question & Answer. The new Q&A (4.12) clarifies the EMA’s position on the demonstration of bioequivalence for the anticoagulant drug dabigatran etexilate. The following clarifications are provided:
Bioequivalence should also be demonstrated in the presence of proton pump inhibitors. Further details are available here: https://lnkd.in/ghYb-vP
A promising new model of the gastrointestinal tract could speed up drug development. Created by MIT engineers, the model tests how well drugs are absorbed in the small intestine and should help oral drug formulation. The model uses pig intestinal tissue, and more closely replicates the human intestine than the currently used approach of testing these formulations in human colorectal cancer cells.
The system can be used to test up to 10,000 samples per day and its results have been found to be 90% accurate, through tests carried out using 60 drugs already approved by the FDA. In contrast, tests using colorectal cancer cells have a near 50% percent accuracy: https://lnkd.in/gRiw-zy
The FDA has released draft guidance explaining how combination product developers can demonstrate that their emergency-use injectors will reliably deliver drugs as intended in a life-threatening emergency. The draft guidance specifically applies to emergency-use injectors that are prefilled or co-packaged with emergency drugs or biologics. The document expands on FDA’s ‘Technical Considerations for Pen, Jet, and Related Injectors for Use with Drugs and Biological Products’ guidance that was released in 2013.
The “FDA recommends that emergency-use injectors include design control specifications for successful injection reliability of 99.999% with a 95% level of confidence”, which ensures that the emergency-use injector performance is as safe and reliable as possible as well as feasible. The guidance also provides a model for establishing reliability and recommendations for completing a reliability report to submit premarket submissions for these products. https://bit.ly/3dlH6xs
The European Commission has released some new questions and answers on regulatory expectations for medicinal products for human use during the COVID-19 pandemic. The document includes the following guidance (questions 2.2 – 2.4) on the manufacturing and importation of finished products and active pharmaceutical ingredients:
The EC has released the above guidance in order to prevent disruptions in the availability of medicines during the pandemic. https://bit.ly/2VYSVnu
EMA has adopted the ICH S11 guideline. It is due to come into effect on 26th September 2020. The guideline provides direction on the nonclinical safety studies important to support a paediatric development program. It will recommend standards for the conditions under which nonclinical juvenile animal testing is considered informative and necessary to support paediatric clinical trials, and also provides guidance on the design of the studies. A streamlined drug development and higher scientific rigor while minimizing the unnecessary use of animals will be achieved with the implementation of this new harmonised ICH guideline. The full text can be found here https://lnkd.in/dbkTrr2
The BWP was convened in order to recommend the virus strains for the manufacture of seasonal influenza vaccine for 2020/2021. Having considered the information on international surveillance by WHO presented by the representative of the WHO Collaborating Centre for Reference and Research on Influenza at the Francis Crick Institute (UK), the CHMP BWP Ad hoc Influenza Working Group, consisting of experts on influenza from the Member States, considered that the WHO recommendation on the composition of vaccines for 2020/2021 should be followed. The recommendations can be found under this link https://lnkd.in/dSgTVp4
The EMA has announced that general fees payable to EMA by applicants and marketing-authorisation holders are increasing by 1.6% on 1 April 2020. Full details of the new fee levels are available in Commission Regulation (EU) No 2020/422 amending Council Regulation (EC) No 297/95, its implementing rules and the corresponding explanatory note on fees, published on 19 March 2020. These documents include the new fees for all types of procedures handled by the Agency, except for pharmacovigilance procedures. Every year, the Agency adjusts its fees on 1 April, in line with the European Union (EU) inflation rate for the previous year. The current increase reflects the inflation rate for 2019, as published by Eurostat, the EU’s statistical office. https://lnkd.in/eJFEjHQ
ICH has issued the results of a survey, which show that the EC and EMA, in collaboration with EU Member States, adequately implement and adhere to ICH guidelines, without introducing unjustified modifications: Adequacy of Implementation and Adherence to International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH) Guidelines: centralised procedure with EMA. https://lnkd.in/eiAUGbb These results are part of a 2019 study to monitor the adequacy of implementation and adherence to ICH guidelines in regulatory member and observer countries and regions. The study report provides a gap analysis based on authorities’ and companies’ views on the implementation and adherence of regulators to ICH guidelines. It reveals a close alignment between the self-declaration of the authorities and perception among companies. For more information, see ICH guideline implementation on the ICH website. https://lnkd.in/efGNCwZ
EMA has published its Regulatory Science Strategy to 2025 on 31st March 2020. It comes in response to the dramatic acceleration of the pace of innovation and the need to support the development of increasingly complex products, especially in the light of the ongoing COVID-19 pandemic. One of the fundamental principles of the strategy is the need for rapid and close engagement of all stakeholders and partners. The learnings from the handling of this public health crisis will be incorporated in ongoing adaptations in real-time. The five key goals of the strategy include: catalysing the integration of science and technology in medicines development; driving collaborative evidence generation – improving the scientific quality of evaluations; advancing patient-centred access to medicines in partnership with healthcare systems; addressing emerging health threats and availability/therapeutic challenges; enabling and leveraging research and innovation in regulatory science. https://lnkd.in/gXXxV2r
HPRA issued form ‘Application by a Manufacturer for a Regulatory Derogation for a non-CE marked Medical Device for COVID-19’ on the 24th March 2020 for manufacturer’s to apply to HPRA for permission for use of their non-CE marked medical device(s) by healthcare professionals in the context of COVID-19 outbreak. The form is intended to speed up the process of use of devices for COVID-19 and must be completed by the manufacturer or their authorized representative. The form is available from the following link https://lnkd.in/eYAjh-C
From 30th March 2020 EMA has implemented a new system to issue electronic certificates for human and veterinary medicines. EMA will no longer provide printed certificates. This will allow the agency to maintain the ability to provide these documents during the COVID-19 pandemic. The new format of the certificates is based on an electronically signed PDF document and will apply to all ongoing and future requests. The Agency will also consider whether the electronic signature should be implemented as a permanent solution as part of its efforts to digitalise its administrative processes for all documents requiring signature. Questions on the new electronic certificates can be sent by email to: email@example.com. More information on the certification of medicinal products is available on EMA’s website.
The recommendations on eligibility to the PRIME scheme adopted at the CHMP meeting of 24-27 February 2020 has been posted on the EMA website, along with the cumulative overview of recommendations on PRIME eligibility requests adopted since the scheme began in 2016. In keeping with the usual proportion of grants and denials, of 5 applications for the month, 1 was granted whilst 4 were denied. The one granted is a gene therapy for “treatment of X-linked Retinitis Pigmentosa owing to defects in Retinitis Pigmentosa GTPase Regulator” supported by clinical exploratory data. The four that were denied are chemical substances, all of which also included clinical exploratory data, in the therapeutic areas of cardiovascular diseases, gynaecology, endocrinology, and neurology. For further details, please click: https://lnkd.in/ePz256f
ICH Q12 covers technical and regulatory c onsiderations for pharmaceutical product lifecycle management. It has been in the works for quite a while and is intended to globally harmonise the management of post-approval changes to chemistry, manufacturing and controls (CMC). However, there are some conceptual differences between ICH Q12 and the current EU legal framework, meaning that there are limitations on how fully ICH Q12 can currently be implemented within the EU.
Incompatible sections are those on scientific risk-based approaches to defining established conditions and associated reporting categories (described in Chapter 3.2.3 of the new guideline) and on the product lifecycle management document (PLCM, described in Chapter 5). Within the EU, regardless of the current text within ICH Q12, the definition of established conditions and their reporting categories must follow the requirements laid down in the current EU Variations Regulation and associated EU guidelines. The PLCM cannot currently be recognized if submitted. https://lnkd.in/g2vefsg
EMA has just published the adopted Qualification Opinion on the Multiple Sclerosis clinical outcome assessment (MSCOA) and an overview of comments received. The intent is for this COA instrument to serve as a primary, co-primary, or secondary endpoint to assess efficacy in clinical trials at various stages of drug development, including proof of concept, dose-ranging, confirmatory and registration trials. There are four specified performance outcome measures assessing important dimensions of multiple sclerosis (MS), which are considered as a battery of tests, some or all of which could be used as a dysconjugate composite endpoint by sponsors in a clinical trial. Full details are available here https://lnkd.in/d_WeSAN
An important incentive offered by the legislation is the possibility for sponsors of orphan medicinal products to receive reductions in the regulatory fees payable to the Agency. A special contribution is allocated annually to the Agency by the European Union (EU) for fee reductions for orphan medicinal products. Since the year 2000, over 2,233 orphan designations have been issued by the European Commission, of which so far 169 have resulted in authorised medicinal products. This link https://lnkd.in/ddDfHfV presents a nice table detailing the EMA policy on the level of fee reductions reflects the priority given to ‘protocol assistance’ and the support to small and medium-sized enterprises (SMEs) and other information on the scheme. EMA has issued this updated presentation on the statistics for Orphans https://lnkd.in/gt-xChE
The purpose of the re-organisation has been stated as to ensure that the Agency operates as efficiently as possible, taking into account the rapidly evolving landscape for pharmaceutical research and development, and driven by the need to recalibrate to a lower head count following the relocation of the Agency to Amsterdam in 2019. Several org charts have been issued. A new EMA org chart https://lnkd.in/ejYBSyJ, where operations in the area of human medicines have been integrated into one Human Medicines Division, which will be led by Alexis Nolte. In addition, four mission-critical task forces have been established to support the human and veterinary medicines divisions. Here is a link to the new task forces org chart https://lnkd.in/esvDkNe. Updates to the existing org charts for Stakeholders & Communication Division, Information Management and Advisory functions have also been issued and can be found on the site.
The National Standards Authority of Ireland (NSAI) has been approved for designation to the new Medical Device Regulations (MDR). This hugely significant achievement makes NSAI only the 11th notified body in the world to be designated to the new medical device regulation. Further information on this notable achievement can be found here < https://lnkd.in/dx5auvY>
As an NSAI certified ISO 9001:2015 company Real Regulatory congratulates the team at NSAI on the recent approval.
EMA has announced that two ICH Guidances – ICH E9(R1) addendum on estimates < https://lnkd.in/dgU3jCr> and sensitivity analysis in clinical trials and ICH S5(R3) on reproductive toxicology < https://lnkd.in/dWApy26> – will take effect in EU on 30 July 2020. The E9(R1) addendum presents a framework for defining an appropriate estimate for a clinical trial and conducting sensitivity analyses.
While the S5(R3) guideline, ICH sets out recommendations for a harmonized approach to assessing nonclinical developmental and reproductive toxicity (DART) testing used to support clinical trials and drug approvals.
EMA has published an updated status on the list of proposed actions to improve the regulatory framework for ATMPs. The complete list can be found under this link <https://lnkd.in/dvx_6RZ>.
Under line item 6, finalisation of the EMA guideline on investigational ATMPs is expected by Q4 2020. It is stated that ‘The Guideline will not change the competence of Member States to approve clinical trials but it will help create common standards for the assessment of these novel products.’ Under line item 7, in relation to the guideline ‘Quality, non-clinical and clinical aspects of medicinal products containing genetically modified cells (CHMP/ GTWP/671639/2008)’, finalisation is expected by Q2 2020.