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11
Prescription (legal) status
Categories vary country by country
• NP („OTC”)• POM• Subcategories
Prescription
22
EU Directive
Main categories• NP• POM
renewable/non-renewable prescriptions
special medical prescr.
restricted medical prescr., reserved for use in spec. areas
33
EU Directive
A medicinal product is NP, if it does not meet the criteria of POM
(Very important!)
(In many countries just the opposite is applied)
44
EU Directive
When POM?• danger, even used correctly, if without
medical supervision• frequently used incorrectly presenting
danger• APIs with activity/ADRs still be
studied• parenterals
55
EU Directive
POM, sub-category specialist’s prescription
• narcotic/psychotropic substance
• if used incorrectly, abuse/misuse
• novel active principle, precautionary
66
EU Directive
POM, sub-category restricted use
• can be used in hospitals only
• can be diagnosed in hospitals only
• specialist’s supervision (e.g. ADRs)
77
EU Directive
(SUB)CATEGORIZATION
• Taking into account single and max. daily doses, strength, dosage-form, pack unit
• Annually updated published list of POM (sub)categories
88
EU Guideline
Goal:
To help MAHs when applying to change the classification
(i.e., to harmonize the swithches!)
• POM/NP criteria
• switch application criteria
99
Guideline NP or POM?
Direct danger: even if used correctly
• Toxicity
• Serious and existing less serious ADRs
• Interactions with commonly used drugs
1010
Guideline NP or POM?
Indirect danger:
• Masking conditions that would require medical attention. NP: time-limit must be set
• Wider use increase resistance, particularly in general population
1111
Guideline NP or POM?
Risk and consequences of incorrect use
• If used according to indications (too many contra-indications, precautions, warnings, etc. May lead to incorrect use
• If the opposite: off-label or longer use
1212
Guideline NP or POM?
Self-assessment/diagnosis• Symptoms can be correctly assessed by
patients (may vary country by country!)• Natural course of disease, duration or
re-occurrence of symptoms may be self-assessed
• Contraindications, etc. can be understood by the consumer
1313
Guideline NP or POM?
• The way patient info is written
• „If not POM, must be less dangerous”
• Layman’s terms used?
• Explanation of use?
• Explanation when should not be used?
1414
Good question - who is „Patient”?
1515
Summarising the legal status
Ailment Treatm. ADR Dr’s diagn. Med.Att. Status
Minor any NS none no NP
Major single NS yes no NP/POM
Major long NS yes rare NP/POM
Major long S yes rare NP1/POM
Major any any yes yes NP2/POM
1if the patient can be informed…
2the smallest pack size
1616
In case of rigid systems...
The NP/POM choice may cease to exist!
Rigid systems:
• Drugs are officially classified either NP or POM (NP may be prescribed but not vice versa!)
• If NP no reimbursement
1717
Professional switches?
• It must be realised: this is a semi-political matter!
• If no consensus between reimbursement-policy makers and DRAs, affordability problems may occur!
1818
The second issue:
OTC distribution channels in the country
and/or
1919
The third issue:
Patients, their perception to medication, knowledge on drugs, etc.
(Average patient does not exist!)
2020
Back to the registration: Accompanying sheets
• SmPC (Summary of Product Characteristics = Data Sheet) for professionals
• PIL for patients• Label• (Assessment
Report written by the DRA)
Medi
cine
2121
Issuance of the MA
• Civil Service authoritative text (what is contained is binding!)
• The Accompanying Sheets annexed
STAMP
2222
Actual marketing (in many countries)?
Pricing and reimbursement negotiations!
• MA: risk/benefit• Pricing,
reimbursement: cost/benefit
2323
MA withdrawn (deletion from the Register)
• Applies to „the product”!
• Who may initiate:
• MAH - without specifying any reason (!)
• Medical Boards, DRA - with good reason (risk/benefit)
• Civil Service authoritative decision
2424
Withdrawal/Recall from the market
• It applies to a given batch of the medicine!
• Decided by the DRA, MAH may initiate it
• In Hungary: DRA informs by telefax the Nat. Publ. Health Serv., and central health-care organs
• Then “info-cascade” in the counties
2525
European Union
• The present marketing authorisation rules and procedures
2626
Certain EU terms
• Sources of law:
Regulation
Directive
• Brussels: Commission, DGs DG Enterprise, DG SANCO
• London: European Medicines Agency (EMA)
2727
EMA
• Established in 1995
• Both 2 DGs pharmacists until now
• Task: centralised MA procedure, ADR monitoring, guidance, appeal procedures
• Committees (one per member state)
28
EMA Committees
• C’ttee of Human Medicinal Prodcts CHMP• C’ttee of Veterinary Medicinal Products
CVMP• C’ttee of Orphan Medicinal Products COMP• Herbal Medicinal Products C’ttee HMPC• Pediatric Committee PDCO• C’ttee of Advanced Therapy Medicinal
Products CAT
28
2929
MA procedures in the EU
Procedures• Centralised CP• Decentralised DP• Mutual recognition
MRP• National
3030
Centralised MA procedure
• Mandatory: biotech substances, HIV/AIDS, cancer, diabetes, neurodegenerative diseases, orphan drugs (5:100,000), somatic cell- and tissue therapy medicinal products
• Possible:
new active substances
“high-tech products”
new, “important” indication
blood products
3131
Centralised procedure
• One single application to EMA• CHMP-assessment (2 rapporteurs from MSs)• 210 days dead-line, then EMA issues
Accompanying Sheets (SmPC, PIL) and Assessment Report in all languages
• MSs: 15-day possibility for „serious risk to public health” appeal
• Then signature by the Commission in Brussels: MA valid for the whole EU
• If negative: banned for the whole EU!
3232
Decentralised procedure
• Possible: any product for which CP is not mandatory
• “Referens MS (DRA)”, RMS where the first application is submitted (“lead market”) and
• Concerned MS (DRA) CMS where to submit later
3333
Decentralised procedure
• Application dossiers sent to RMS and CMSs, validation
• RMS: preliminary MA issued (time-frame!), Accompanying Sheets and Assessment Report (also in English)
• Discussion with to CMSs = final MA = national MAs in RMS and CMSs
• Opposing opinions: appeal (see CP)• Any changes: similar procedure
3434
Mutual recognition• (When the MA has already been issued in
one MS)• The Firm requests an AR (in English) from
the national competent authority (it is the RMS then)
• It, together with the full documentation submitted to CMSs asking a „recognition” of the AR (time-frames!)
• Opposing opinions: appeal (see CP, the decision is binding)
• Any changes: similar procedure
3535
EU registration collaborations
• Many Working Groups and Committees under EMEA and Commission
• EMEA CHMP Q, S, E, Herbal Medicines, Pharmacovigilance, Heads of Agencies, etc. Working Parties
• Commission Pharmaceutical Committee
36
Back to the general regulatory affairs concerning registered
drugs on the market
3737
Post-marketing surveillance
• GMP (manufacturers), GDP (wholesalers), GCP (CT sites), GLP (safety study laboratories)
• Drug Adverse effect monitoring (Pharmacovigilance)
• Mandatory Quality defect reporting national system
3838
Pharmacovigilance
Doctors and Marketing Authorisation Holders must report (to the DRA)
• serious• unexpected (not listed in the information for
professionals)
side effects (=adverse drug reactions, ADRs),
level of seriousness, time-frames may be specified in the law
39
A little story: what happens to these ADR reports?
• ADR Data Banks at national, regional (e.g. European Union) and global (e.g. WHO ADR Monitoring Centre in Uppsala, Sweden)
• All ADR data put into the Banks• From time-to-time, professionals review similar
data• If the connection between taking a drug and the
ADR is possible: it is called a signalsignal and national ADR centres, professional societies, etc. signalised: monitor this ADRs of this drug strictly
• If the connection becomes proven (many cases!): it comes to the information material of the drug
40
A signal generation story (WHO Uppsala Monitoring Centre)
• Spontaneous reports ot the Data Bank• Data „mining” with softwares• Signal generation review • If causality probable: signal message to
the National Monitoring Centres• If proven later: part of the information
material of that drug
41
Signal to the hydroalcoholic extract of a medicinal plant:
Teucrium chamaedrys
42
Signal generation example 1
• Teucrium chamaedrys: the hydroalcoholic (alcohol-water) extracts of the herb are extremely bitter. It is frequent component of reductant (anti-obesity) tees
• There were more than 20 data on hepatic adverse reactions (jaundice, hepatitis) in the WHO database
• In cases when the patients, after recovery, drank the tee again, the same symptoms were recurring very quickly (in 2 days, the note at the registration was: rarely possible!)
43
Signal generation example 2
• How to start the review?• If the quick recurrence is true, that would mean
an immunological mechanism• Literature search: can liver damage be caused
via immunological mechanism? • Answer: yes!• Literature search: the main components of the
plant are diterpenoids and fenyl-ethanoid glycosides, they are free radical scavengers
44
Signal generation example 3• But these are small molecules, too small for an
immune response. Could they modify human proteins by binding on them? (E.g. an alkylating mechanism)?
• Literature search: – the tsructure of the plant components: there is no
alkílating agent among them– but, if free radical scavengers, they perhaps will be
metabolised via oxidation• Literature search: what could be oxidised
metabolites of these components? There is a furane ring on the side chain of one of the triterpenoids (the tecurin-A)
45
Signal generation example 4
• Literature search: the oxidative metabolism of the furane ring is:
• Irodalmazás: this epoxid can alkylate the human epoxid hydrolase enzyme, the resulting modified protein is „foreign”, there will be antibody formation against it…
O
CYP450
OO
46
Signal generation example 5• But the extracts of the plant are widely used in various products
as amarum. If this is the basis of the adverse effect, why is it so rare?
• The place of oxidative metabolisms is the liver. Perhaps is there something in the liver to react with the epoxide, other that the mentioned enzyme?
• Literature search: the epoxidesaz epoxidok prefer reaction with „soft” (according to the Pearson classification) nucleofils
• Is there such compound in the liver? Yes! The
γ-L-glutamyl-L-cysteinil-glycin (glutathion)
-HN-CH-CO-NH-
CH2-SH
47
Signal generation example 6
• Now we already know why only the anti-obesity tees caused the (relatively high number of the) adverse effects
• Glutathion: extreme diurnal changes in the organism! When fasting, its level goes almost to zero! And people whi take anti-obesity tees are fasting…
• The signal is ready!WHO Signal, March 2006, pp. 8-17
4848
National mandatory quality defect reporting system
• Wholesalers, marketing authorisation holders must report to the DRA drug quality defects, pharmacies even suspected ones
• Prerequisite: at least organoleptic checking of incoming drugs mandatory
4949
You may say that no quality defect can never be identified
by organoleptic checking – is it true?
5050
„the same” tablets in the same package unit
5151
„the same” coated tablets
5252
One ointment, if check the inside…
5353
the same ointment
5454
Drug assessment for registration:
multidisciplinary business!
5555
There is sThere is still a big mistake!till a big mistake!
• In certain Universities it is presumed that assessment of medicines can be taught by simply teaching chemistry, analysis, technology, pharmacology, some clinical sciences, etc.
• That is not true! That is not true!
5656
Big mistake!Big mistake!
Medicine evaluation means the recognition of the links between data generated under different scientific disciplines
5757
Big mistake!Big mistake!• E.g. if a medicine (registration
application) is evaluated by chemists, analysts, pharmacists, pharmaco-logists/toxicologists and clinicians separately, this a wrong evaluation!
• It is also the message of the EU Directive!
5858
Examples to indicate the spirit Examples to indicate the spirit of interdisciplinary medicine of interdisciplinary medicine
evaluationevaluation
Naturally, this topic can not be covered in a few minutes. However, it may be indicated by a few examples
5959
Penicillin powder for injection in Penicillin powder for injection in vialsvials
• Quality Dossier: water content not more than 2.5 % — what shall I check during evaluation of this medicine?
• As a requirement per se : may be acceptable
• The anal. method (not Karl Fischer) seems to be O.K.
• However, a good assessor tends to be anxious to check:
6060
Penicillin powder for injection in vials - topics to check
The main decomposition route is hydrolysis• Water content in the samples for stability
studies (much less than 2.5 %?)
• Water content in clinical trial samples (the
same question, for the sensitisation potential of decomposition products, chiefly the penicillin-polymers is higher)
6161
Penicillin powder for injection in vials, 2
• By the way, is there any data in the clinical trial reports about the time between reconstitution of the injection solution and the administration (hydrolysis! Was it required
to use the solutions within a specified time?)• Was the decomposition rate after
reconstitution determined? And its temperature dependence?) (If not, can I
evaluate the clinical safety at all?)
6262
Penicillin powder for injection in vials, 3
• Is there anything in the SmPC about the quick use after reconstitution?
• Is this issue addressed when the possibility of administration after mixing with a slow infusion is discussed from the medical point of view?
6363
Next example: CYPNext example: CYP450450
metabolism, 2metabolism, 2• Is the interaction issue reflected in
the clinical trial plans? (was the concomitant medication studied, or was it “carefully avoided”? Oxydator-phenotype classification of trial subjects? Patient exposure high enough?)
6464
Next example: CYPNext example: CYP450450
metabolism, 3metabolism, 3• Does the SmPC and the PIL reflect
the significance of the issue and the clinical data?
• By the way, let us go back to the chemical part and check whether the whole issue was reflected in the purity (related substances qualification) part
6565
CYP450 metabolism… 4
CH3–CH2-O
NH-C-CH3
O
NH-C-CH3
O
Cl
fenacetin intermedier-product: p-chloro-acetanilid
6666
CYP450 metabolism, 5
CH3–CH2-O
NH-C-CH3
O
NH-C-CH3
O
Cl
fenacetin intermedier-product: p-chloro-acetanilid
CH3–CH-O CH3–CH2-O
OH
NH-C-CH3
O
N-C-CH3
OHO
fenacetin CYP450 metabolism
6767
How to facilitate the multidisciplinary drug
assessmentElectronic submissions!
6868
Importance of electronic submissions
• Huge paper submissions
vs. a few CD - handling, archiving, etc...
this is true. PLUSPLUS:
• EU procedures: more fast-track recognition than assessment!
6969
Paper submission:
330,000pages per
application
7070
Electronic submissions for registration
Past:
Present/future:
7171
Electronic applications
1000 - 3000 hyperlinks connect the related text parts of chemical - pharmaceutical - preclinical - clinical - SmPC/PIL etc.
7272
Electronic dossier assessment: navigation, 1
METABOLISM: Expert Report: CYP450 interaction possibilitiesCYP450 interaction possibilities
Preclin. Dossier?
Clin. Expert Report?
Clin. Dossier, CT Protocol design?
CT results
SmPC?
SmPC: expiry date/ expiry date/ spec. Storagespec. Storage
Ch/Ph Expert Report
Ch/Ph Dossier, Stability results, statistical CI
7373
Electronic dossier as-sesment: navigation, 2
Ch/Ph Dossier: Impurity ProfileImpurity Profile
Ch/Ph Expert Report
Tox. Expert Report (discusseddiscussed?)
Tox. Dossier (same profilesame profile?)
Clin. Dossier (same profilesame profile?)
7474
The Essence of Hyperlinking
“If Regulatory Affairs comprise an art of recognising If Regulatory Affairs comprise an art of recognising interdisciplinary relations when reviewing dossiers, interdisciplinary relations when reviewing dossiers, hyperlinks may be taken as ‘Materialization’ of hyperlinks may be taken as ‘Materialization’ of these interdisciplinary relationsthese interdisciplinary relations” TLP, 1998
(Quoted in: Witzel et al.: Damos Experience Report, Lorenz GmbH, Frankfurt, 1998)
7575
Different hyperlinking needs: review structure
External or internal
assessors?
C’ttee/Peer review?
Rapporteurs?
Or concrete Q/A’s to/from experts?
Quality assessment connected to laboratory analyses?
REVIEW SOFTWARE INTRANET?
7676
Different hyperlinking needs: DRA structure
Highly specialised review
units (e.g., Quality, GMP,
Toxicology, Pharmacology,
Clinical, SPC/PIL,
Registration sections)
or
more concentrated expertise (such as Qua-lity, GMP, Biomedical and Registration)?
7777
The next registration issue
We are living in a World where the human beings are the same everywhere!
Why do not we collaborate in drug registration?
7878
Drug registration: an international business
• It became as international as the drug development
• Apart from the European Union where the system of Community medicine registration exists, there are many related international collaborations
7979
Content
• Why collaboration?
• Why regional collaboration?
• Which collaboration technique to be chosen?
8080
Content
• Why collaboration?• Why regional collaboration?
• Which collaboration technique to be chosen?
8181
“Every State is responsible for its public health issues” -
why collaboration?
8282
Fact:
Drug development became an international business
8383
Medicine development is a global business...
8484
To answer this challenge, DRAs should also go beyond frontiers (They
are doing so!)• GMP, GLP, GCP inspections over the
globe? Or information sharing (e.g. WHO
Certification Scheme…)recognition? (If you do not require such data, this is recognition without information! )
• Information on foreign drug/CT app-rovals/rejections (Are you not interest-ed?)
• PhV (Are you satisfied with your country’s reports, if any, alone?)
8585
Next argument
• Is Q-S-E assessment based on science? YES
• Is science international? YES
• Then?
8686
Next argument• Drugs are for patients to cure diseases
• Are patients and diseases different in different countries?
• ICH assessment: mostly not, in a few per cent yes
• Exaggerated! Pharmacogenetic and pharmacokinetic differences in the same population
8787
Concrete example (Drug Y)
• No pharmacokinetic differences between Caucasian, Japanese and Black races
• Combined effects of gender, age smoking within the same race: the Creatinine Clearence in young smoking males 3 times higher than that in elderly non-smoking females
B.K. Malhotra, 2001
8888
Further argument
• If new medicines of proven high efficacy appear, is there a public health interest to make them available as soon as possible?
• It were very difficult to answer “no”!
• But let us discuss it in more detail, it is a hot topic!
8989
Thus, all DRAs benefit the international collaboration when
registering drugs...
…by using/taking into account• literature data• foreign DRA decisions (e.g. WHO channel)• foreign registration and GMP certificates (e.g.
WHO Certification Scheme…)• foreign PhV data
in a non-structured way!
9090
Entering into collaboration
The national DRA will have access to these and even more data/information in a structured way!
9191
Content
• Why collaboration?
• Why regional collaboration?• Which collaboration technique to be
chosen?
9292
Why regional collaboration,1
Sometimes: all DRAs did it before!
See countries before splitting into new States
9393
Why regional collaboration, 2
Many do exist successfully!
1999 Geneva WHO/CIOMS Meeting on Regional Harmonisation: many identified
• Latin America (at least 2)• Africa• Middle East• South-East Asia...
9494
Changing drug selection, medical practice...
……problems not experienced elsewhereproblems not experienced elsewhere
• Hungarian example: the antipyretic aminophenazone shifted to paracetamol, resulting in a “few” deaths due to intoxication
• the same rapid action expected by patients/parents
• high alcohol consumption in Hungary
9595
Benefits of a regional collaboration
Apart from the psychological factor, should every country repeat evaluations (QC analyses, CTs, etc.) done in another country?
9696
Regional collaboration- counter-arguments
“We are more clever (knowledgeable, professional, etc.) than those in another countries”
(No comment!)
9797
Regional collaboration- counter-arguments
(The psychological factor)
The Hungarian ice-hockey team example
(Who would be the leader?)
9898
Regional collaboration - counter-arguments
Too many collaborations!
• Financing
• Time
(However - see benefits - the more the DRA can afford it the more benefits, also saving resources, are gained! See CADREAC, PERF...)
9999
Content
• Why collaboration?
• Why regional collaboration?
• Which collaboration technique to be chosen?
100100
Collaboration techniques, examples, evaluation
• Supranational as EU. General. “Forced” collaboration, limited sovereignty, i.e. Community Procedures, etc. It would be more than premature for SEE.
• Global technical, see ICH. Surely not a SEE goal
101101
Collaboration techniques, examples, evaluation (cont’d)
• Mandatory special such as former EFTA Conventions like PIC (GMP), or OECD (GLP), or Eu.Pharm. Mandatory recognition in special areas. Not worth-wile and may not be acceptable
102102
Collaboration techniques, examples, evaluation (cont’d)
• Not mandatory but information and expertise-sharing such as EFTA Schemes (e.g. Pharmaceutical Evaluation Report Scheme, PER). Shared info on registered medicines and the results of the evaluation, arguments for acceptance-rejection, common guidelines, etc. Consider it!
103103
How to build up a regional collaboration, 1
• Common meetings. Will needed
• Agreement between DRAs, it communicated to industry
• Start with info sharing ondrugs registered/refused, reason
CTs authorised refused, reason
Laws/regulations/guidelines issued
Implementation experiences, problems
Still nothing mandatory
104104
How to build up a regional collaboration, 2
If it works:
• Extension to collaborative development of
technical guidelines
procedural guidance
105105
How to build up a regional collaboration, 3
If it works, extension to
• Common drug evaluation
personnel changes, study tours
participation in each other’s drug evaluation
joint inspection teams
Still nothing is mandatory!
106106
How to build up a regional collaboration, 4
If it works, possible extension to
• Mutual recognition” (in the EU meaning) of marketing authorisation, inspections
still retaining the ultimate national responsibility for decision!
STEPWISE APPROACH, EXISTING FORMS, NO LEGAL OBLIGATION, IT WOULD BE WORTH OF TRYING!
107107
Hungarian international drug registration collaborations
• European Pharmacopoeia• Pharmaceutical Inspection Cooperation
Scheme (PIC-S)• OECD GLP Working Party...• WHO International Pharmacopoeia,
guidelines…• European Union…
108
Exam topic
109
Registration of drugs
• Different kinds of drug authorisations for use: the 3 levels according to WHO
• Medicine use possibilities, other than registered ones• Registration as product characterisation plus legal and
professional sides• The 3 main elements of the professional side• Characterisation of the content of an application (CTD)• The flow of the registration process of a new drug• The CJD issue• Prescription statuses, their reason, switches between these
statuses• Accompanying info for professionals and patients• Deletion from the register versus batch recall
110
Registration of generics and the European Union marketing
authorisation routes• Description of the application types (from fill
application to generics)• Patent protection and data exclusivity• Doha declaration• What is a generic drug. Ho9w to establish
equivalence• Discuss the EU Community procedures (3) in
short• The European Medicines Agency• International (global and regional) registration
collaborations
111
Levels of proof for the use of drugs
• List the levels of proof and their order
• Explain the clinical terminology