active pharmaceutical ingredient assessment update 2015 · pdf fileactive pharmaceutical...
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Active Pharmaceutical Ingredient
Assessment
Update 2015
1Copenhagen, Denmark 23-26 November 2015 - API Assessment update
API: active pharmaceutical ingredient
APIMF: active pharmaceutical ingredient master file (aka ASMF, DMF)
FPP: finished pharmaceutical product
PQT: Prequalification Team
IGDRP: International Generic Drug Regulators Programme
Acronyms
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Part I: The status of API assessment
Part II: Advice to applicants
Part III: The IGDRP
Introduction
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There are three procedures used in PQT related to API
information:
• API Prequalification
• APIMF Procedure
• APIMF amendment procedure (Post acceptance)
Part I: API Assessment
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API Assessment
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EDQM CEPFull Data APIMF
Procedure
Drug Master File
(APIMF)
Prequalified FPP (standard Process)
Clinical FPP API
GMP (CRO, FPP, API)
Prequalified API
GMP API
WHO List of Prequalified Medicinal Products WHO List of Prequalified APIs
PQ API
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Website – APIMF Procedure
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Website – API Prequalification
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Amendments
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Q&A Documents
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215 APIMFs accepted or under assessment
This includes:
85 Prequalified APIs and,
55 applications seeking API Prequalification
We are pleased with progress so far!
Some statistics
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API Starting material selection
The API-QIS
Understanding the amendment procedure
Part II: Advice to Applicants
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This guy is the probably unaware of the starting material selection
issues.
Correct selection and justification remains a problem.
Getting early advice should be considered.
API Starting material selection
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This is increasingly common.
The information provided on the steps undertaken by external
intermediate suppliers should be of the same quality as those
steps undertaken by the API manufacturer.
Identifying necessary information in the APIMF can be a challenge
for assessors when dealing with external intermediate
manufacturers.
See the published Q&A document (APIMF Procedure) for
information on organisation of this information.
External Intermediate manufacturers
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This is a summary document present in the assessment report and
is finalised as part of the acceptance of an APIMF.
API-QIS
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The API-QIS is a very useful document for PQT. It ensures mutual
understanding of key information between PQT and the APIMF
holder.
An annotated API-QIS is requested as part of all APIMF
amendment applications, to verify the changes being proposed.
The accepted API-QIS is attached to the acceptance letter of every
amendment to ensure on-going understanding of key information.
Applicants have 7 days to raise issues on the information in the
API-QIS when they received the draft acceptance letter.
API-QIS
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The conditions and documentation requirements for a given
change category are spelt out in the amendment guidance.
These requirements must be fulfilled, or an alternative chance
category chosen.
There is a specific manner in which the application forms should
be filled. Follow this. There are example applications forms on the
website.
There is specific documentation and replacement subsection that
are required to be included.
APIMF Amendments
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APIMF Amendment procedure
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Link
Why so pedantic? - SPEED
New amendment applications have a very high priority for
completion.
Responses to questions raised on an amendment have a lower
priority.
It is important to get it right the first time.
APIMF Amendment procedure
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We have obtained additional resource to help with API
assessment.
The initial focus will be to reduce amendment assessment times.
Then to reduce assessment times new APIMFs.
Speed of assessment
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The International Generic Drug Regulators Programme
(IGDRP)
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http://igdrp.com
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The International Generic Drug Regulators Programme
(IGDRP) was created in 2011 to promote collaboration and
convergence of generic drug regulators in order to address
challenges posed by increasing workloads, globalization and
complexity of scientific issues.
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The IGDRP - membershipAgencia Nacional de Vigilancia Sanitaria (ANVISA)
China Food and Drug Administration (CFDA)
European Directorate for the Quality of Medicines and Healthcare (EDQM) (Observer)
European Union:
– European Commission - DG SANTE (EC)
– Coordination Group for Mutual Recognition and Decentralised Procedures - Human(CMDh)
– European Medicine Agencies (EMA)
Federal Commission for the Protection against Sanitary Risk (COFEPRIS)
Federal Service for Surveillance in Healthcare and Social Development
Health Canada
Health Sciences Authority (HSA)
Ministry of Food and Drug Safety (MFDS)
Ministry of Health, Labour and Welfare (MHLW)
Medicines Control Council (MCC)
Medsafe
Swissmedic
Taiwan Food and Drug Administration (TFDA)
Therapeutic Goods Administration (TGA)
U.S. Food and Drug Administration (US FDA)
World Health Organization (WHO) (Observer)
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The IGDRP
Three working groups have been identified. These are:
• An ASMF/DMF working Group (2013)
• A Biowaivers working group (2013)
• IT business needs working group (2015)
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ASMF/DMF Working Group
Chair and co-chair – TGA and WHO
ANVISA, COFEPRIS, EDQM, EU, HC, HSA, MCC, MFDS,
PMDA, Swissmedic, TFDA.
Objective: foster international collaboration and work sharing
in the area of evaluations for ASMFs/DMFs.
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ASMF/DMF Working Group
Initial projects:
• Survey among member of their respective ASMF/DMF procedures.
• Development of an ASMF/DMF lexicon of quality terms.
Recent projects
• Agreement on the common ASMF/DMF information fields that should be recorded at the time of submission.
• Agreement of an ASMF/DMF common quality assessment report template (M 3.2.S).
• Consideration of the criteria for when a separate ASMF/DMF should be provided. e.g different polymorph, salt…
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ASMF/DMF Working Group
Many of these documents will be soon published on the
IGDRP website.
Please understand that these are model documents. They
are not mandatory for adoption by member organisations,
but members are committed to their implementation as and
where possible.
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ASMF/DMF Working Group
The projects so far have been preliminary steps towards
information and work sharing.
NEXT Project:
Investigating the possibility of an ASMF/DMF common
database for IGDRP members.
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Common ASMF/DMF database
Small steps….
Initially this is envisaged to contain descriptive information
describing the ASMF/DMFs held by members.
…such as, ASMF holder name, ASMF version numbers, sites,….
The ability to identify common ASMFs among members
would be significant progress.
It is the first step towards report sharing and work sharing.
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Common ASMF/DMF database
The biggest challenge to progress is the ability to share
information between agencies.
The simplest solution is to obtain permission directly from
the APIMF holder, rather than through agency to agency
agreements.
This is the approach WHO PQT would like to take, but we
will need your support.
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Further information
The PQ website is a good source of information, please
read.
http://www.who.int/prequal/info_applicants/API_info_applicants.htm
Or email me at:
Thank you
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