ECTD Digital Handbook PDF
ECTD Digital Handbook PDF
ECTD Digital Handbook PDF
git
alHandbook
www.
fdanews.
com
eCTD Digital Handbook
FDAnews
300 N. Washington St., Suite 200
Falls Church, VA 22046-3431
Web: www.fdanews.com
Main telephone: (703) 538-7600
Toll free: (888) 838-5578
Fax: (703) 538-7676
Copyright© 2007 by FDAnews. Print: ISBN: 1-6000-132-9, Digital: 1-6000-133-7. Price: $335. All rights reserved.
No copyright is claimed in the text of guidances, regulations and excerpts from regulations quoted within this work.
Photocopying or reproducing this book in any form, including electronic or facsimile transmission, scanning or electronic
storage, is a violation of federal copyright law and is strictly prohibited without the publisher's express written permission.
The book may not be resold. FDAnews only sells its publications directly or through authorized resellers. Information
concerning authorized resellers may be obtained from FDAnews, 300 N. Washington St., Suite 200, Falls Church, VA 22046-3431.
While every effort has been made by FDAnews to ensure the accuracy of information in this book, this organization accepts no
responsibility for errors or omission. The book is sold as is, without warranty of any kind, either express or implied, respecting
its contents including but not limited to implied warranties for the book's quality, performance, merchantability, or fitness for
any particular purpose. Neither FDAnews nor its dealers or distributors shall be liable to the purchaser or any other person or
entity with respect to any liability, loss, or damage caused or alleged to be caused directly or indirectly by this book.
eCTD Digital Handbook
Table of Contents
Part 1 Tutorial
Section 1.2 FDA Overview of the eCTD Guidance and its Implementation.
• This presentation helps the student on:
o Electronic submission guidances using eCTD specifications providing regulatory submissions
in electronic format for human pharmaceutical product applications and related submissions.
• Includes NDA, ANDA, BLA, IND, DMF and associated submissions.
o Preferred format for submissions
Part 2 Guidances
Section 02 Guidance for Industry M4 The CTD - Efficacy Questions and Answers.
• This is one in a series of guidances that provide recommendations for applicants preparing the
Common Technical Document for the Registration of Pharmaceuticals for Human Use (CTD)
for submission to the U.S. Food and Drug Administration (FDA). This guidance provides
answers to questions that have arisen since the finalization of the harmonized CTD guidance
documents. This guidance specifically addresses questions related to efficacy. Other question
and answer (Q &A) guidances are under development to address general questions as well as
questions related to quality and safety. The questions and answers provided here reflect the
consensus of the ICH parties.
Part 3 Submissions
Section 04 Electronic Submission Guidances.
• PowerPoint presentation on providing regulatory submissions in electronic format including:
o Overview.
o Available guidances-traditional electronic submissions.
o Electronic submissions using eCTD specifications.
o eCTD guidance — changes from eNDA guidance–continuation of eNDA guidance.
o Submissions 101 references.
Section 05 Providing Regulatory Submissions in Electronic Format Using eCTD Specifications.
• This is one in a series of guidance documents intended to assist applicants making regulatory
submissions to the FDA in electronic format using the electronic common technical document
(eCTD) specifications. This guidance discusses issues related to the electronic submission of
applications for human pharmaceutical products and related submissions, including abbreviated
new drug applications (ANDAs), biologics license applications (BLAs), investigational new
drug applications (INDs), new drug application (NDAs), master files (e.g., drug master files),
advertising material, and promotional labeling. At this time, this does not include applications
supporting combination products.
Section 15 Evaluation and Research ISS/ISE: Where Do They Fit in the CTD-eCTD.
• PowerPoint presentation that provides advice on how to:
o Differentiate between ICH guidelines and FDA requirements for the CTD/eCTD.
o Identify the goals of the CTD/eCTD for both industry and regulators.
o Identify strategies to include the ISS/ISE in the CTD and eCTD submission formats.
Part 5 Training
Section 26 NDA Electronic Data Analysis Training.
• CDER has provided guidance to industry for sponsors to send case report form tabulations and
individual animal line listings as datasets. To help Center review staff use these electronic
datasets, the Office of Information Technology, in conjunction with review staff, has developed
NDA Electronic Data Analysis Training (NEDAT).
Having data in a common electronic environment will allow the FDA to regulate
products quickly, eliminating difficulties with accessing, searching through and finding
data in paper forms.
Different product areas are in different stages of electronic submission requirements, and
changes will come in stages to each area. That is why it is essential for companies to
learn the details and standards for each type of electronic submission. Already the Center
for Drug Evaluation and Research has set a deadline for all submissions to arrive in
eCTD form.
While electronic submissions help the agency speed reviews and share information, they
also help companies. Using the eCTD costs less for companies than paper submissions,
freeing up resources that allow drugmakers to focus on interpreting clinical data instead
of handling that data.
In this book, you will learn the benefits of switching to eCTD and the best practices for
the new format, as well as the specifications, standards and checklists for creating an
eCTD protocol in your company.
When the FDA held a public meeting on electronic submissions in December 2006,
several speakers noted challenges in switching to an electronic system, such as a current
lack of trained labor and standardized procedures. This book will help you navigate the
many FDA-issued documents to find the most valuable information so your company an
make a smooth transition to electronic submissions.
The book begins with a tutorial of seven PowerPoint presentations giving an overview of
the FDA’s eCTD guidance document and how it will be implemented. The presentations
also provide a comprehensive discussion on preparing each of the five modules of an
eCTD.
Next, there are two industry guidances. The first focuses on efficacy questions in
preparing eCTD for the registration of pharmaceuticals in human use. The answers reflect
a consensus from the members of the International Conference on Harmonisation of
Technical Requirements for Registration of Pharmaceuticals in Human Use (ICH).
The FDA suggests it is most beneficial to begin eCTD-based submissions with an initial
submission of an application and then following up with the appropriate center before
making eCTD-based submissions of other applications. This guidance covers each
pharmaceutical submission type, except for applications for combination products. The
guidance also suggests how to electronically submit master files, advertising materials
and promotional labeling.
The next part of the book, Section Four, covers specifications, standards, definitions and
checklists for creating and maintaining and eCTD protocol in the company. One
document provides specifications for creating eCTD backbone files for all five modules
in connection with industry guidances, as well as how to manage electronic study tagging
files.
Backbone files come in extensible markup language (XML) to replace the usual portable
document format (PDF) table of contents, because XML has more power to display data
and information, creating greater efficiency for the files. The book discusses how to
transform the backbone from XML to HTML. Without eCTD backbone files, the agency
will not be able to adequately manage or review submissions.
The eCTD backbone files include items such as the document title, subject matter,
relationships to other documents, revision information, the document’s location and
submission information included in the document. However, the eCTD backbone files do
not have enough information on the subject matter of certain documents, such as study
report documents, to support some regulatory business rules. That information is
provided in backbone study tagging files.
A PowerPoint presentation explains how to deal with two common study tagging file
problems – using a maximum of 256 characters and computer displays that cannot
display lengthy path and file names.
Another presentation in this section provides practical advice and pitfalls to avoid for
submitting an electronic document, including referencing all files in the XML backbones
and using standard XML components.
This section also includes a sample form for requesting a change to the ICH eCTD
specification, which can be used to fix a “bug” or to meet new requirements. In addition,
there is a document describing the parts of the registration application common to all
regions and some of the lifestyle requirements for products, and another establishing the
change control process for the eCTD specification.
The section also provides the specifications for submitting documents in PDF and for
transmitting electronic submissions using eCTD specifications either electronically or on
physical media. It also contains a document detailing where to place the integrated
summaries of safety and effectiveness in applications submitted in eCTD format.
Part Five of the book deals with training and preparing your company for switching to
submissions in eCTD form. The first part covers new drug application electronic data
analysis training, created by the FDA’s Office of Information Technology along with
review staff. The training covers a guidance from the Center for Drug Evaluation and
Research (CDER) for sponsors to send case report form tabulations and individual animal
line listings as data sets.
Although the FDA may not be prepared to make a full switch to electronic document
formats right away, it is clearly trying to forge a path ahead to reach its ultimate goal of
all-electronic submissions. The agency has detailed its specifications, checklists,
definitions and objectives. With these tools and other industry documents, your company
can keep up with every detail and request in the process of switching to electronic
document formats.
Part 1
Tutorial
SECTION 1.0
This tutorial will provide an overview of FDA's eCTD guidance document and a comprehensive
discussion on preparing the five modules of an eCTD. Emphasis will be placed on ensuring the
successful submission of an application and facilitating the review process.
eCTD Module 1
● This presentation provides information on:
o Archiving regional documents
o Application management
o Special regulatory programs
o The legal and regulatory framework for the application/submission
eCTD: Module 1
Bronwyn Collier, Associate Director for Regulatory Affairs
Office of Drug Evalaution III
Center for Drug Evaluation and Research
FDA
April 2005
Module 1: Topics
• Purpose
• Impact on review process
• Module 1 table of contents
2
Module 1: Purpose
• Archive regional documents
• Application management
– Status
– Business
– Special regulatory programs
– Provides the legal and regulatory framework
for the application/submission
3
Impact on Review Process
• Facilitates document processing
– Identification
– Division assignment
• Review assignment
• Guides response
• Satisfies some regulatory requirements
4
TOC Mapping
CFR Citation eCTD/STF Heading
NUMBER TITLE MODULE NUMBER TITLE
312.7(d) Charging for and 1 1.12.2 Request to
commercialization Charge
of investigational
drugs
312.10 Waivers 1 1.12.5 Request for a
waiver
7
Module 1 TOC
• 1.3 Administrative information
– 1.3.1 Contact/sponsor/applicant information
• 1.3.1.1 Change of address or corporate name
• 1.3.1.2 Change in contact/agent
• 1.3.1.3 Change in sponsor
• 1.3.1.4 Transfer of obligation
• 1.3.1.5 Change in ownership of an application
– 1.3.2 Field copy certification
– 1.3.3 Debarment certification
– 1.3.4 Financial certification and disclosure
8
Module 1 TOC
– 1.3.5 Patent and exclusivity
• 1.3.5.1 Patent information
– FDA form 3542a
– FDA form 3542
• 1.3.5.2 Patent Certifications
• 1.3.5.3 Exclusivity request
– 1.4 References
• 1.4.1 Letter of authorization
• 1.4.2 Statement of right of reference
• 1.4.3 List of authorized persons to incorporate by
reference
• 1.4.4 Cross reference to other applications and
9
previously submitted information
Module 1 TOC
• 1.5 Application status
– 1.5.1 IND Withdrawal request
– 1.5.2 Inactivation request
– 1.5.3 Reactivation request
– 1.5.4 Reinstatement request
– 1.5.5 Withdrawal of an unapproved application
– 1.5.6 Withdrawal of listed drug
– 1.5.7 Request for withdrawal of application approval
– 1.5.8 Other correspondence re withdrawal or
suspension of approval
10
Module 1 TOC
• 1.6 Meetings
– 1.6.1 Meeting request
– 1.6.2 Meeting background materials
– 1.6.3 Correspondence regarding meetings
• 1.7 Fast track
– 1.7.1 Fast track designation request
– 1.7.2 Fast track designation withdrawal
request
– 1.7.3 Rolling review request
– Correspondence re Fast Track/Rolling Review
– Correspondence re CMA Pilot 1
– Correspondence re CMA Pilot 2 11
Module 1 TOC
• 1.8 Special protocol assessment request
– 1.8.1 Clinical study
– 1.8.2 Carcinogenicity study
– 1.8.3 Stability study
12
Module 1 TOC
• 1.9 pediatric administrative information
– 1.9.1 Request for deferral
– 1.9.2 Request for waiver
– 1.9.3 Request for pediatric exclusivity
determination
– 1.9.4 Proposed pediatric study request and
amendments
– 1.9.5 Proposal for written agreement
– 1.9.6 Other correspondence regarding
pediatric exclusivity or study plans
13
Module 1 TOC
• 1.10 Dispute resolution
– 1.10.1 Request for dispute resolution
– 1.10.2 Correspondence related to dispute
resolution
• 1.11 Information amendment (info not
covered under modules 2-5
– 1.11.1 Quality information amendment
– 1.11.2 Safety information amendment
– 1.11.3 Efficacy information amendment
14
Module 1 TOC
• 1.12 Other correspondence
– 1.12.1 Pre IND correspondence
– 1.12.2 Request to charge
– 1.12.3 Notification of charging under treatment IND
– 1.12.4 Request for comments and advice on an IND
– 1.12.5 Request for a waiver
– 1.12.6 Exemption from informed consent for
emergency research
– 1.12.7 Public disclosure statement for emergency
care research
– 1.12.8 Correspondence regarding emergency care
research
15
Module 1 TOC
– 1.12.9 Notification of discontinuation of clinical trial
– 1.12.10 Generic drug enforcement act statement
– 1.12.11 Basis for submission statement
– 1.12.13 Comparison of generic drug and reference
listed drug
– 1.12.14 Request for waiver for in vivo studies
– 1.12.15 Environmental assessment
– 1.12.16 Request for waiver of in vivo bioavailability
studies
– 1.12.17 Field alert reports
16
Module 1 TOC
• 1.13 Annual report
– 1.13.1 Summary for nonclinical studies
– 1.13.2 Summary of clinical pharmacology
information
– 1.13.3 Summary of safety information
– 1.13.4 Summary of labeling changes
– 1.13.5 Summary of manufacturing changes
– 1.13.6 Summary of microbiological changes
17
Module 1 TOC
– 1.13.7 Summary of other significant new information
– 1.13.8 Individual study information
– 1.13.9 General Investigational plan
– 1.13.10 Foreign marketing history
– 1.13.11 Distribution data
– 1.13.12 Status of postmarketing study commitments
– 1.13.13 Status of other postmarketing studies
– 1.13.14 Log of outstanding regulatory business
18
Module 1 TOC
• 1.14 labeling
– 1.14.1 Draft labeling
• 1.14.1.1 Draft carton and container labels
• 1.14.1.2 Annotated draft labeling text
• 1.14.1.3 Draft labeling text
• 1.14.1.4 Label comprehension studies
• 1.14.1.5 Labeling history
19
Module 1 TOC
– 1.14.2 Final labeling
• 1.14.2.1 Final carton and container labels
• 1.14.2.2 Final package insert (package inserts,
patient information, Medication guides)
• 1.14.2.3 Final labeling text
– 1.14.3 Listed Drug labeling
• 1.14.3.1 Annotated comparison with listed drug
• 1.14.3.2 Approved labeling text for listed drug
• 1.14.3.3 Labeling text for reference listed drug
20
Module 1 TOC
– 1.14.4 Investigational drug labeling
• 1.14.1.1 Investigator’s brochure
• 1.14.1.2 Investigational drug Labeling
– 1.14.5 Foreign labeling
– 1.15 Promotional material
– 1.16 Risk management plans
21
Summary
• Module 1 sets the regulatory and legal
framework for applications and
subsequent submissions
• Match information to appropriate heading
22
SECTION 1.2
esub@cder.fda.gov
Overview
• Available Guidances
– Traditional Electronic Submissions
– Electronic Submissions using eCTD
Specifications
• eCTD Guidance
– Changes from eNDA Guidance
– Continuation of eNDA Guidance
• Submissions 101 References
esub@cder.fda.gov
Electronic Submission Guidances
Traditional Electronic Submission
esub@cder.fda.gov
Electronic Submission Guidances
Using eCTD Specifications
esub@cder.fda.gov
Electronic Submissions Using eCTD
Specifications
• Guidance Published August, 2003
• eCTD Specifications
– FDA eCTD Table of Contents Headings and Hierarchy
– FDA Module 1 Specification
– FDA Modules 2 to 5 Specification
– Study Tagging File Specification
• Specifications Available On-Line
http://www.fda.gov/cder/regulatory/ersr/default.htm
• Current eNDA/eANDA Guidances remain available
as an alternative to the eCTD
esub@cder.fda.gov
eCTD Changes
esub@cder.fda.gov
What doesn’t change
esub@cder.fda.gov
Implementing the Guidance
esub@cder.fda.gov
Submissions 101
esub@cder.fda.gov
Just say no…
esub@cder.fda.gov
SECTION 1.3
esub@cder.fda.gov
Remember!
esub@cder.fda.gov
Have a Pre-Meeting to Discuss the
Electronic Submission
esub@cder.fda.gov
Contact Electronic Submission
Coordinator
esub@cder.fda.gov
Submitting Electronic Submissions
• CDER: ODEI - ODEV
– ALL electronic submissions for original applications,
supplements, and amendments, must be sent to the Central
Document Room
• CDER: ODEVI
– All electronic submission to the ODEVI document room
• CDER: OGD
– All electronic submission to the OGD document room
• Send only ONE copy of the electronic submission
• Use the correct electronic media and choose type
appropriate to size of submission
• Place the electronic media in the first volume
esub@cder.fda.gov
Submitting Electronic Submissions
Continued…
• eCTD
– Should not include any paper
• If Part 11 compliant electronic signatures are available
otherwise only documents requiring original signatures
– Include all required eCTD files
– Include all required forms, letters, and
certifications
– Be sure ALL files submitted are referenced in XML
backbone
– Do not use Node extensions
esub@cder.fda.gov
Top 10 eCTD Issues for Success
10. Files Referenced in the XML Backbone(s)
9. eCTD Submissions Include Module 1
8. Application Numbers are 6 Digits
7. Sequence Numbers are 4 Digits
6. Unneeded Node Extensions are Removed
5. MD5 Checksum are Correct
4. Documents Conform to eCTD Granularity
3. XML must be Standard Components
2. PDF Hyperlinks/Bookmarks are Correct
1. PDF Documents include TOCs
esub@cder.fda.gov
10. All Files Referenced in the XML
Backbone(s)
– Unreferenced Files Result from
• Missing/Mislocated Directory references in
xlink:href
• “Extra” files
• Failing to Repeat Complete Directory Structure on
each media component in a set
– Unreferenced Files cannot be located by
reviewers
– Are complex directories structures really
needed ?
esub@cder.fda.gov
9. All eCTD Submissions Include
Module 1
esub@cder.fda.gov
8. All Application Numbers are 6 Digits
– Application-number values must be 6 digits -
• No Alpha Characters
• No “-” “,” or other punctuation
• No spaces
• Six Numbers – pad left “0” if 5 digits are given
– Application number is key - ties all
submissions together as an application
esub@cder.fda.gov
7. All Sequence Numbers are 4 Digits
– Sequence-number values must be 4 digits
• No Alpha Characters
• No “-” “,” or other punctuation
• No spaces
– Sequence number is key and relates all
submission components together
– Sequence numbers need not be
received/submitted in “sequence”
esub@cder.fda.gov
6. All Unneeded Node Extensions are
Removed
– Node Extensions are Unwanted
• ICH and FDA do not recommend NEs
• At best they are ignored; at worst they defeat
the standard headings
– Node Extensions are Unneeded
• Leaf Title can be used to differentiate
between documents at the same level
esub@cder.fda.gov
5. All MD5 Checksums are Correct
esub@cder.fda.gov
4. All Documents Conform to eCTD
Granularity
Avoid “combining” documents at higher parent
leaf level (allowed by Module 3)
• Tempting - small initial savings in combining
• Large cost in life cycle complexity
• “Legacy” Study Reports make for life cycle
issues down the road
esub@cder.fda.gov
3. All XML must be Standard
Components
UTIL Folder
– 3 Standard DTDs
• 3 Standard Styles Sheets in UTIL folder
• Custom components create issues in FDA
Processes – Defeat standards efforts
– Avoid GIFs, custom CSS, custom DTDs,
custom elements with standard DTDs
esub@cder.fda.gov
2. All PDF HyperLinks & Bookmarks
are Correct
– Validate all Hyperlinks and Bookmarks
– Incorrect Targets Unnerve Reviewers
– Reviewer Thinks: “What else is wrong with
the submission?”
esub@cder.fda.gov
1. All PDF Documents Include TOCs
For each Document -
– If a paper document needs a TOC, a PDF
document needs a hyperlinked TOC
– No change from eNDA - both bookmarks and
hyperlinks
– Cross Document Links still work in an eCTD
– All 4 RTFs to date have had errors in
bookmarks and TOC hyperlinks
esub@cder.fda.gov
Provide Bookmarks
with Intuitive Names
• Good • Bad
esub@cder.fda.gov
Bookmarks
esub@cder.fda.gov
Book Mark Issue Example
esub@cder.fda.gov
Ensuring a Effective Submission
esub@cder.fda.gov
References
esub@cder.fda.gov
SECTION 1.4
Module 4
Nonclinical
Study Reports
4
4.1 T of C
Module 4: Safety
4.2 Study reports
4.2.1 Pharmacology
4.2.2 Pharmacokinetics
4.2.3 Toxicology
4.3 Literature references
4.2.1 Pharmacology
4.2.1.1 Primary pharmacodynamics
4.2.1.2 Secondary pharmacodynamics
4.2.1.3 Safety pharmacology
4.2.1.4 Pharmacodynamic drug interactions
4.2.1.1 Primary Pharmacodynamics
• Study report [identification number] and related
information
• Legacy study report
• Synopsis
• Study report body
• Protocol and amendments
• Signatures of principal or coordinating
investigator(s)
• Audit certifications and reports
4.2.1.1 Primary Pharmacodynamics
• Documentation of statistical methods and interim
analysis plans
• Documentation of inter laboratory standardization
methods of quality assurance procedures if used
• Publications based on the study
• Important publications referenced in the report
• Compliance and/or drug concentration data
• Individual subject data listings
4.2.1.1 Primary Pharmacodynamics
• Data tabulation
– Data tabulation datasets
– Data definitions
• Data listing datasets
– Data listing datasets
– Data definitions
• Analysis datasets
– Analysis datasets
– Analysis programs
– Data definitions
• IND safety reports
4.2.1.2 Secondary Pharmacodynamics
• Study report [identification number] and
related information
• See Primary pharmacodynamics Study report
and related information for headings
Folder Structure of Module 4
Granularity: Module 4 -- Safety
4.2 Study Reports
• 4.2.1 Pharmacology
• 4.2.2 Pharmacokinetics
• 4.2.3 Toxicology
• 4.3 Literature references
Continuing Education
Questions & Answers (?)
Questions & Answers (?)– CTD
• M4: The CTD — General Questions and Answers (October
2003)
• … one in a series of guidances that provide recommendations for
applicants preparing the Common Technical Document for the
Registration of Pharmaceuticals for Human Use ( CTD) for
submission to the U. S. Food and Drug Administration ( FDA).
• … provides answers to questions that have arisen since the
finalization of the harmonized CTD guidance documents in
November 2000.
• … addresses general questions about the CTD.
• Other question and answer ( Q & A) guidances … quality, safety,
and efficacy.
• The questions and answers provided here reflect the consensus of
the ICH parties.
Questions & Answers (?)–
CTD/Safety
Continuing Education
www.fda.gov
The Latest News
sort by date
Questions & Answers (?) – CTDs & eCTDs
Your Final Exam
• Q10 Integrated Summary of Safety and
Effectiveness
• Does the CTD section on safety in Module
2 replace the section under 21 CFR 314.50(
d)( 5)( v)-( vi) calling for integrated
summary of safety and effectiveness ( ISS/
ISE)?
Questions & Answers (?) – CTDs & eCTDs
Your Final Exam – Answer
• Study Reports
• Data
esub@cder.fda.gov
Why Module 5?
Advantage for the Reviewer
• Provides Framework for clinical
documents submitted during drug
development (IND); e.g. protocols,
protocol amendments, IND safety
reports
• One section contains all information to
perform in-depth clinical pharmacology
and clinical/statistical BLA/NDA review
esub@cder.fda.gov
Advantage to Reviewer: Examples
• NDA Amendments
esub@cder.fda.gov
Organization
esub@cder.fda.gov
5.2 Tabular Listing of All Clinical Studies
esub@cder.fda.gov
Study No. Title Treatment Duration Treated Location
PK
Studies
AA-001 [Title] Placebo 1 dose 10 5.3.3.1
1 mg 10
5 mg 10
10 mg 10
AA-002 [Title2] Placebo 2 weeks 10 5.3.3.1
1 mg q d 20
5 mg q d 20
PD
Studies
AB-001 [Title 3] Placebo 1 week 10 5.3.4.2
5 mg qd 15
esub@cder.fda.gov
5.3 Clinical Study Reports
and Related Information
• Biopharmaceutic, Pharmacokinetic,
Pharmacodynamic Studies (5.3.1, 5.3.2,
5.3.3, 5.3.4)
esub@cder.fda.gov
5.3.1 5.3.2 5.3.3
Human PD
• Healthy Subject PD and PK/PD
esub@cder.fda.gov
5.3.5 5.3.6
esub@cder.fda.gov
All of these go in 5.3
• New Protocols (IND) including Treatment
Protocols
• Protocol Amendments
• New Investigators; Investigator’s
Qualifications
• IND Safety Report
• Compliance with Informed Consent
• Integrated Summaries of Efficacy and Safety
• Postmarketing Periodic Adverse Drug
Experience Reports
esub@cder.fda.gov
Also in 5.3
• Case Report Tabulations
• Case Report Forms
esub@cder.fda.gov
5.4 Literature References
esub@cder.fda.gov
Study Reports
• Headings are Organized according to ICH
E3 document and report is submitted in
multiple files (*different from previous
guidance*)
esub@cder.fda.gov
Study Tagging File (STF)
esub@cder.fda.gov
Case Report Forms
esub@cder.fda.gov
Study Data
File Formats:
• SAS Transport (Version 5)
Organization
• Datasets go in same section in the TOC
as its corresponding study report
esub@cder.fda.gov
Study Data: Folder Structure
esub@cder.fda.gov
FAQ
esub@cder.fda.gov
Summary
• Module 5 – permits comprehensive
clinical pharmacology, clinical, statistical
reviews
• Majority of IND/BLA/NDA clinical
content in section 5.3
• A study report now comes in multiple
files (E3) *different from the past*
• Datasets and CRF’s organized by
study, but still XPT and PDF,
respectively.
esub@cder.fda.gov
SECTION 1.6
DTD
<!ELEMENT date (#PCDATA)>
<!ELEMENT to (#PCDATA)>
<!ATTLIST to ID #REQUIRED>
XML Memo
<!ELEMENT memo (date, to, from, cc*, topic, sub-topic?, lead-para, body+)>
<!ELEMENT date (#PCDATA)
<!ELEMENT to (#PCDATA)
<!ATTLIST to ID #REQUIRED> …
MEMO
Date:
To: + one or more
From:
[CC:] * zero or more
Topic: ? zero or one
[Sub-topic:]
Lead paragraph
Body
Body
eCTD Required Elements
• http://www.ich.org
Prequel 2: ICH and FDA
CTD Introduction
2.2
Nonclinical Clinical
Overview Overview
Quality 2.4 2.5
Overall
Summary Nonclinical Written C
2.3 Clinical
And Tabulated l
Summary
Summaries i 2.7
2.6 n
ICH Harmonised Tripartite Guideline
Organisation of the Common Technical
Document for the Registration of
Pharmaceuticals for Human Use M4
• Module 2. Common Technical Document
Summaries
• Module 2 should begin with a general
introduction to the pharmaceutical,
– pharmacologic class
– mode of action
– proposed clinical use.
• In general, the Introduction should not
exceed one page.
Module 2 -- Summaries
• Module 2 should contain 7 sections in the
following order :
– CTD Table of Contents
– CTD Introduction
– Quality Overall Summary
– Nonclinical Overview
– Clinical Overview
– Nonclinical Written and Tabulated Summaries
– Clinical Summary
• 312. -- IND
• 314. -- NDA
Regulation Guidance
Mapping Summaries: 312 -- IND
(3) Introductory statement and general
investigational plan.
– (i) A brief introductory statement giving the name of
the drug and all active ingredients, the drug’s
pharmacological class, the structural formula of the
drug (if known), the formulation of the dosage form(s)
to be used, the route of administration, and the broad
objectives and planned duration of the proposed
clinical investigation(s).
CFR eCTD
314.50(c)(2)(ii) to Summaries… A.N. Use the appropriate
(ix) sections
314.50(d)(7) Pediatric use section A.N. Use appropriate
sections
314.60 Amendments to an A. N. Use appropriate
unapproved application sections
314.70 and 314.71 Supplements and other A.N. Use appropriate
changes to approved sections
applications
314.96 Amendments to an A.N Use appropriate
unapproved application sections
A.N. – As Needed
Part 2
Guidances
SECTION 2
December 2004
ICH
Revision 3
TABLE OF CONTENTS
I. INTRODUCTION .................................................................................................................1
II. BACKGROUND ....................................................................................................................2
III. QUESTIONS AND ANSWERS............................................................................................2
Contains Nonbinding Recommendations
This guidance represents the Food and Drug Administration's (FDA's) current thinking on this topic. It
does not create or confer any rights for or on any person and does not operate to bind FDA or the public.
You can use an alternative approach if that approach satisfies the requirements of the applicable statutes
and regulations. If you want to discuss an alternative approach, contact the FDA staff responsible for
implementing this guidance. If you cannot identify the appropriate FDA staff, call the appropriate
number listed on the title page of this guidance.
I. INTRODUCTION
This is one in a series of guidances that provide recommendations for applicants preparing the
Common Technical Document for the Registration of Pharmaceuticals for Human Use (CTD) for
submission to the U.S. Food and Drug Administration (FDA). This guidance provides answers
to questions that have arisen since the finalization of the harmonized CTD guidance documents
in November 2000. This guidance specifically addresses questions related to efficacy. Other
question and answer (Q &A) guidances are under development to address general questions as
well as questions related to quality and safety. The questions and answers provided here reflect
the consensus of the ICH parties.
FDA's guidance documents, including this guidance, do not establish legally enforceable
responsibilities. Instead, guidances describe the Agency's current thinking on a topic and should
be viewed only as recommendations, unless specific regulatory or statutory requirements are
cited. The use of the word should in Agency guidances means that something is suggested or
recommended, but not required.
1
This guidance was developed within the M4 CTD-Efficacy Implementation Working Group of the International
Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH)
and has been subject to consultation by the regulatory parties, in accordance with the ICH process. This document
has been endorsed by the ICH Steering Committee at Step 4 of the ICH process, June 10, 2004. At Step 4 of the
process, the final draft is recommended for adoption to the regulatory bodies of the European Union, Japan, and the
United States .
1
Contains Nonbinding Recommendations
II. BACKGROUND
The guidance for industry issued in November 2000 on preparing the CTD was divided into four
separate documents (1) M4: Organization of the CTD, (2) M4: The CTD — Quality, (3) M4:
The CTD — Efficacy, and (4) M4: The CTD — Safety. Since implementation of these
guidances, a number of questions regarding the various CTD documents have been submitted to
the various ICH regions. The ICH has developed a process for responding to questions
submitted to the ICH Web site.
Q1: Clinical study reports contained in Module 5 are cited in the Clinical Overview and/or
the Clinical Summary in Module 2. Each clinical study report may be given a unique
short name when cited. Does the method of citing and naming have to be uniform
throughout all modules?
A1: We recommend that each study have a unique short identifier that is used consistently
throughout the application. The applicant can select the identifier. The full title of the
study is provided in the Tabular Listing of All Clinical Studies (Section 5.2)
Q2: Definitions/Terminology
In Module 5 of the CTD, is it necessary to have a section number for each clinical
study report in a certain section, or is it enough just to mention the title:
5.3.5 Report of Efficacy….
5.3.5.1 Study Reports….
5.3.5.1.1 Placebo Controlled….
Study XXX
2
Contains Nonbinding Recommendations
Q4: How many pages should a Clinical Summary be for an application that contains
multiple indications?
A4: The estimated size of this document is 50-400 pages, assuming one indication.
Applications that include multiple indications will be larger, reflecting the submission of
multiple efficacy sections.
The Guideline provides “This section should also cross-reference important evidence
from Section 2, such as data that supports the dosage and administration section of the
labeling.” However, this Guideline also provides a Section, “2.7.3.4. Analysis of
Clinical Information Relevant to Recommended Dose.” Please specify how to
differentiate the two sections “2.7.3.3” and “2.7.3.4”.
A5: Section 2.7.3.3 summarizes the data across all studies that characterize efficacy of the
drug; Section 2.7.3.4 provides an integrated summary of the dose-response or blood
concentration-response relationships of effectiveness. In both cases, supportive data from
Section 2.7.2 can also be incorporated.
A6: That table should refer to all subjects exposed to at least one dose of the drug product.
Appropriate subsets of subjects relevant to the proposed indications should also be
identified and considered.
A7: Summaries of any bridging studies using clinical endpoints (i.e., certain studies intended
to evaluate the ability to extrapolate certain types of foreign clinical data to the new
region (see ICH E5)) should be included in Section 2.7.3.2. Where appropriate, such
information should also be described in the summarization of safety data as related to
intrinsic and extrinsic ethnic factors (ICH E5), in Sections 2.7.4.5.1 and 2.7.4.5.2.
Finally, some applications might include in Section 5.3.5.3 a detailed analysis of
bridging, considering formal bridging studies, other relevant clinical studies, and other
3
Contains Nonbinding Recommendations
In Module 5, 5.2 is denoted as the ‘Tabular Listing of all Clinical Studies’. Is this
section for a summary listing of all clinical studies in the submission, or it is for the
listing of the individual study reports? In other words, should the listings from the
appendices of the individual study reports be included here, rather than as an appendix
to the CSR, or are these only listings that summarize all studies?
A9: The tabular listing described in section 5.2 is a listing of all clinical studies in the
submission.
Does the CTD section on safety in Module 2 replace the section under 21 CFR
314.50(d)(5)(v)-(vi) calling for integrated summary of safety and effectiveness
(ISS/ISE)?
A10: The ISS/ISE are critical components of the safety and effectiveness submission and are
expected to be submitted in the application in accordance with the regulation. FDA’s
guidance Format and Content of Clinical and Statistical Sections of Application gives
advice on how to construct these summaries. Note that, despite the name, these are
integrated analyses of all relevant data, not summaries.
The Clinical Safety sections of the CTD follow approximately the outline of the sections
of the ISS/ISE, although they are somewhat modified by experience with ICH E-3
(Structure and Content of Clinical Study Reports). The CTD Clinical Overview and
Summary in Module 2 will not usually contain the level of detail expected for an ISS. It
may contain the level of detail needed for an ISE, but this would need to be determined
on a case-by-case basis.
4
Contains Nonbinding Recommendations
If the requirements of 21 CFR 314.50 can be met for a particular application by what is in
the CTD Module 2 summary, the CTD Module 2 section would fulfill the need for an
ISS/ISE. In some cases, it will be convenient to write much of what is needed in the
CTD Module 2 with appropriate appendices in Module 5. In other cases, the ISS/ISE
would be summarized in Module 2, with detailed reports in Module 5.
Any questions about these matters can be raised with the reviewing division.
The microbiology data will include both in vitro and in vivo studies. Where should the
microbiology summary, overview, and study reports be included?
A11: The microbiology data from both in vitro and in vivo studies should be included with the
Efficacy information. The summary information should be provided in the appropriate
section 2.7 Clinical Summary and the reports should be filed in section 5.3.5.4 Other
Study Reports.
In addition, the microbiology information can be described in the Nonclinical sections as
appropriate.
A12: Since variation is a term from the EU regulations, the answer should be provided by the
EMEA.
Q13: Integrated Analysis of Efficacy (ISE) Section 2.7 – Clinical Summary – Statistical
Listings
What approach should applicants take for the formatting and presentation of their
integrated analyses when they have large amounts of statistical output to present
(several thousands of pages)?
A13: As stated in section Reports of Analyses From More Than One Study 5.3.5.3, where the
details of the analysis are too extensive to be reported in a summary document (for
example, section Clinical Summary 2.7), they should be presented in a separate report.
Such report should be placed in section 5.3.5.3.
5
Contains Nonbinding Recommendations
It is stated in the CTD that the section should be indicated in cross strings. What is
meant here: The section number, or the section number and section name? (The
section name is in many cases too long to indicate in a cross string.)
A14: Providing the section header in addition to the section number improves the clarity of the
reference, particularly for the uninitiated reader. To reduce the length of the cross string
while maintaining the ease of use, it is recommended to include only the section number
in the cross string and write the text so the reader will also know the section content. For
example, “…as seen in the population PK study 101 (5.3.3.5)” helps the reader to find the
referenced study report under the Population PK Study Reports section. The text “…no
safety problems were noted in the uncontrolled pneumonia study 101A (5.3.5.2)” helps
the reader find the referenced study report under the section Study Reports of
Uncontrolled Clinical Studies for the Pneumonia indication.
Section 2.5 Clinical Overview and section 2.5.5 Overview of Safety both refer to an
assessment of the limitations of the safety database but give few details on how to
describe them. How should these limitations be described? In addition, there is no
specific reference to any postmarketing steps the applicant can take to remedy those
limitations. Where should a discussion of any postmarketing pharmacovigilance and
other postmarketing study plans go?
A15: A fuller discussion of how to describe in the CTD the limitations of the safety database
and the potential implications for the safety of the drug when marketed is as follows:
• Nonclinical toxicology and safety pharmacology concerns, such as those arising from
reproductive / developmental toxicity, carcinogenicity, hepatic injury, central nervous
system injury, or effects on cardiac repolarization that are not fully resolved by
available human data, or that arise from incomplete testing.
6
Contains Nonbinding Recommendations
• Identified adverse events and potential adverse events that require further
characterization or evaluation with respect to frequency and/or seriousness in the
general population or in specific subgroups.
• Important potential risks (e.g., known risks of pharmacologically related drugs) that
require further evaluation.
When submitting one dossier for multiple indications, how should the applicant
present them in the clinical part of the registration dossier, for example sections 2.5
Clinical Overview, 2.7.3 Summary of Clinical Efficacy, and 5.3.5 Reports of Efficacy
and Safety Studies?
A16: One section 2.5 Clinical Overview is recommended for multiple indications to be
registered along with development rationale and cross-referencing to the corresponding
2.7.3 and 5.3.5 sections; the “benefit/risk” conclusions should support corresponding
claimed indications.
For section 2.7.3 Summary of Clinical Efficacy, in the case of more than one indication,
the following organization is recommended as applicable. The current CTD numbering
should be retained with identification of the indication, for example:
2.7.3. UTI Summary of Clinical Efficacy
2.7.3.1. UTI Background
2.7.3.2. UTI Summary of Results of individual studies
2.7.3.3. UTI comparison and analysis
2.7.3.3.1. UTI study population
2.7.3.3.2. UTI Comparison of efficacy results
2.7.3. Pneumonia Summary of Clinical Efficacy
2.7.3.1. Pneumonia Background
Other sections follow the same organization where applicable.
7
Contains Nonbinding Recommendations
For section 5.3.5 Reports of Efficacy and Safety Studies, in case of more than one
indication, the following organization is recommended as applicable. The current CTD
numbering should be retained with identification of the indications, for example:
5.3.5.UTI
5.3.5.1. UTI Controlled studies
5.3.5.2. UTI Uncontrolled studies
5.3.5. Pneumonia
5.3.5.1. Pneumonia Controlled studies
5.3.5.2. Pneumonia Uncontrolled studies
Other sections follow the same organization, where applicable.
The CTD guidance for Section Overall Safety Evaluation Plan and Narratives of
Safety Studies 2.7.4.1.1 states that narrative descriptions for studies that contributed
both efficacy and safety should be included in Section Summary of Results of
Individual Studies 2.7.3.2 and only referenced in the safety section. Please clarify
whether the narrative to be included in 2.7.3.2 should include the safety results as well
as “enough detail to allow the reviewer to understand the exposure… and how safety
data were collected” or whether the results should be included in Section 2.7.4.1.1.
A17: In general, safety results should be described in section 2.7.4.1.1, because section
Summary of Clinical Efficacy 2.7.3 is devoted to efficacy. To avoid the need to describe
the same study twice, section 2.7.3.2 asks for a reasonably complete description of
studies pertinent to both safety and efficacy, including, in study narratives, information
about the extent of exposure of study subjects to the test drug and how safety data were
collected. This approach is confirmed in section 2.7.4.1.1, which notes that narratives for
studies contributing both safety and efficacy data should be included in section 2.7.3.2.
As noted in section Background and Overview of Clinical Efficacy 2.7.3.1, however, any
results of these studies that are pertinent to evaluation of safety should be discussed in
section Summary of Clinical Safety 2.7.4.
Q18: According to ICH E3 Structure and Content of Clinical Study Reports, the case report
forms should be located in Appendix 16.3, the individual patient data listings in
Appendix 16.4, and the publications and literature references in Appendices 16.1.11
and 16.1.12 respectively. The CTD organization provides locations for case report
forms and individual patient data listings in Module 5.3.7 and for literature references
in Module 5.4.
Can clarity be provided as to where these items should actually be placed in CTD and
the eCTD submissions?
A18: For paper submissions, case report forms and individual patient data listings should be
located in Module 5.3.7, identified by study.
8
Contains Nonbinding Recommendations
For eCTD, PDF files for case report forms and individual patient data listings should be
organized by study in the folder for Module 5.3.7. However, in the index.xml file, the
leaf elements for the case report forms and individual patient data listings should be
included under the same heading as other study report files with additional information
included with any accompanying study tagging file. In addition, a repeat of the leaf
element can be placed under the heading 5.3.7 Case Report Forms and Individual Patient
Data Listings. Datasets, if required by the region, should be organized according to
regional guidance.
For paper submissions, publications and literature references should be located in Module
5.4.
For eCTD, the files for publications and literature references should be located in the
folder for Module 5.4. However, in the index.xml file, the leaf elements for the
publications and literature references should be included under the same heading as other
study report files with additional information included with any accompanying study
tagging file. In addition, a repeat of the leaf element should be placed under the heading
for 5.4 Literature References.
9
SECTION 3
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1. TITLE PAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2. SYNOPSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
5. ETHICS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
5.1 Independent Ethics Committee (IEC) or Institutional Review Board (IRB) . . . . . 5
5.2 Ethical Conduct of the Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
5.3 Patient Information and Consent . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
7. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
8. STUDY OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
9. INVESTIGATIONAL PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
9.1 Overall Study Design and Plan: Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
9.2 Discussion of Study Design, Including the Choice of Control Groups . . . . . . . . . 7
9.3 Selection of Study Population . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
9.3.1 Inclusion Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
9.3.2 Exclusion Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
9.3.3 Removal of Patients From Therapy or Assessment . . . . . . . . . . . . . . . . . 9
9.4 Treatments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
9.4.1 Treatments Administered . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
9.4.2 Identity of Investigational Products(s) . . . . . . . . . . . . . . . . . . . . . . . . . . 10
9.4.3 Method of Assigning Patients to Treatment Groups . . . . . . . . . . . . . . . 10
9.4.4 Selection of Doses in the Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
9.4.5 Selection and Timing of Dose for Each Patient . . . . . . . . . . . . . . . . . . . 11
9.4.6 Blinding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
9.4.7 Prior and Concomitant Therapy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
9.4.8 Treatment Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
9.5 Efficacy and Safety Variables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
9.5.1 Efficacy and Safety Measurements Assessed and Flow Chart . . . . . . . . . 12
9.5.2 Appropriateness of Measurements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
9.5.3 Primary Efficacy Variable(s) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
i
9.5.4 Drug Concentration Measurements . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
9.6 Data Quality Assurance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
9.7 Statistical Methods Planned in the Protocol and Determination of Sample Size 15
9.7.2 Statistical and Analytical Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
9.7.2 Determination of Sample Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
9.8 Changes in the Conduct of the Study or Planned Analyses . . . . . . . . . . . . . . . . 16
ii
12.3.1.2 Other Serious Adverse Events . . . . . . . . . . . . . . . . . . . . 31
12.3.1.3 Other Significant Adverse Events . . . . . . . . . . . . . . . . . . 31
12.3.2 Narratives of Deaths, Other Serious Adverse Events, and Certain Other
Significant Adverse Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
12.3.3 Analysis and Discussion of Deaths, Other Serious Adverse Events, and
Other Significant Adverse Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
12.4 Clinical Laboratory Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
12.4.1 Listing of Individual Laboratory Measurements by Patient (Appendix
16.2.8) and Each Abnormal Laboratory Value (see section 14.3.4) . . . . 32
12.4.2 Evaluation of Each Laboratory Parameter . . . . . . . . . . . . . . . . . . . . . . . 33
12.4.2.1 Laboratory Values Over Time . . . . . . . . . . . . . . . . . . . . 33
12.4.2.2 Individual Patient Changes . . . . . . . . . . . . . . . . . . . . . . . 34
12.4.2.3. Individual Clinically Significant Abnormalities . . . . . . . . 34
12.5. Vital Signs, Physical Findings, and Other Observations Related to Safety . . . . . 35
12.6 Safety Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
14. TABLES, FIGURES, AND GRAPHS REFERRED TO BUT NOT INCLUDED IN THE
TEXT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
14.1 Demographic Data Summary figures and tables. . . . . . . . . . . . . . . . . . . . . . . . 36
14.2 Efficacy Data Summary figures and tables. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
14.3 Safety Data Summary figures and tables. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
14.3.1 Displays of Adverse Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
14.3.2 Listings of Deaths, Other Serious and Significant Adverse Events . . . . 36
14.3.3 Narratives of Deaths, Other Serious and Certain Other Significant Adverse
Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
14.3.4 Abnormal Laboratory Value Listing (each patient) . . . . . . . . . . . . . . . . 36
16. APPENDICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
16.1 Study Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
16.1.1 Protocol and protocol amendments. . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
16.1.2 Sample case report form (unique pages only). . . . . . . . . . . . . . . . . . . . 37
16.1.3 List of IEC's or IRB's (plus the name of the committee chair if required by
the regulatory authority) and representative written information for patient
and sample consent forms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
16.1.4 List and description of investigators and other important participants in the
study, including brief (one page) CV's or equivalent summaries of training
and experience relevant to the performance of the clinical study.
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
16.1.5 Signatures of principal or coordinating investigator(s) or sponsor's
iii
responsible medical officer, depending on the regulatory authority's
requirement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
16.1.6 Listing of patients receiving test drug(s)/investigational product(s) from
specific batches, where more than one batch was used. . . . . . . . . . . . . . 37
16.1.7 Randomization scheme and codes (patient identification and treatment
assigned). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
16.1.8 Audit certificates (if available). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
16.1.9 Documentation of statistical methods. . . . . . . . . . . . . . . . . . . . . . . . . . . 37
16.1.10Documentation of inter-laboratory standardization methods and quality
assurance procedures if used. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
16.1.11Publications based on the study. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.1.12Important publications referenced in the report. . . . . . . . . . . . . . . . . . . 38
16.2 Patient Data Listings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.2.1 Discontinued patients. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.2.2 Protocol deviations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.2.3 Patients excluded from the efficacy analysis. . . . . . . . . . . . . . . . . . . . . . 38
16.2.4 Demographic data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.2.5 Compliance and/or drug concentration data (if available). . . . . . . . . . . . 38
16.2.6 Individual efficacy response data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.2.7 Adverse event listings (each patient). . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.2.8 Listing of individual laboratory measurements by patient, when required by
regulatory authorities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.3. Case Report Forms (CRF's) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.3.1 CRF's for deaths, other serious adverse events, and withdrawals for
adverse events. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.3.2 Other CRF's submitted. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
16.4 Individual Patient Data Listings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
SYNOPSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Annex I
iv
LISTING OF PATIENTS AND OBSERVATIONS EXCLUDED FROM EFFICACY
ANALYSIS (EXAMPLE) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Annex VI
v
GUIDELINE FOR INDUSTRY 1
INTRODUCTION
The objective of this guideline is to facilitate the compilation of a single core clinical study report
acceptable to all regulatory authorities of the ICH regions. The regulatory authority-specific
additions will consist of modules to be considered as appendices, available upon request according
to regional regulatory requirements.
The clinical study report described in this guideline is an “integrated” full report of an individual
study of any therapeutic, prophylactic, or diagnostic agent (referred to herein as drug or
treatment) conducted in patients. The clinical and statistical description, presentations, and
analyses are integrated into a single report, incorporating tables and figures into the main text of
the report or at the end of the text, with appendices containing such information as the protocol,
sample case report forms, investigator-related information, information related to the test
drugs/investigational products including active control/comparators, technical statistical
documentation, related publications, patient data listings, and technical statistical details such as
derivations, computations, analyses,and computer output. The integrated full report of a study
should not be derived by simply joining a separate clinical and statistical report. Although this
guideline is mainly aimed at efficacy and safety trials, the basic principles and structure described
can be applied to other kinds of trials, such as clinical pharmacology studies. Depending on the
nature and importance of such studies, a less detailed report might be appropriate.
The guideline is intended to assist sponsors in the development of a report that is complete, free
from ambiguity, well organized, and easy to review. The report should provide a clear explanation
1
This guideline was developed within the Expert Working Group (Efficacy) of the International Conference on
Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH) and has been
subject to consultation by the regulatory parties, in accordance with the ICH process. This document has been endorsed
by the ICH Steering Committee at Step 4 of the ICH process, November 29, 1995. At Step 4 of the process, the final
draft is recommended for adoption to the regulatory bodies of the European Union, Japan and the USA. This guideline
was published in the Federal Register on July 17, 1996 (61 FR 37320) and is applicable to drug and biological
products. Although this guideline does not create or confer any rights for or on any person and does not operate to bind
FDA or the industry, it does represent the Agency’s current thinking on structure and content of clincial study reports.
For additional copies of this guideline, contact the Drug Information Branch, HFD-210, CDER, FDA, 5600 Fishers
Lane, Rockville, MD 20857 (Phone: 301-827-4573) or the Manufacturers Assistance and Communication Staff (HFM-
42), CBER, FDA, 1401 Rockville Pike, Rockville, MD 20852-1448. Send one self-addressed adhesive label to assist
the offices in processing your request. An electronic version of this guidance is also available via Internet using the
World Wide Web (WWW) (connect to the CDER Home Page at WWW.FDA.GOV/CDER and go to the “Regulatory
Guidance” section).
of how the critical design features of the study were chosen and enough information on the plan,
methods, and conduct of the study so that there is no ambiguity in how the study was carried out.
The report with its appendices should also provide enough individual patient data, including the
demographic and baseline data, and details of analytical methods, to allow replication of the
critical analyses when authorities wish to do so. It is also particularly important that all analyses,
tables, and figures carry, in text or as part of the table, clear identification of the set of patients
from which they were generated.
Depending on the regulatory authority's review policy, abbreviated reports using summarized data
or with some sections deleted may be acceptable for uncontrolled studies or other studies not
designed to establish efficacy, for seriously flawed or aborted studies, or for controlled studies
that examine conditions clearly unrelated to those for which a claim is made. A controlled safety
study, however, should be reported in full. If an abbreviated report is provided, a full description
of safety aspects should be included in all cases. If an abbreviated report is submitted, there should
be enough detail of design and results to allow the regulatory authority to determine whether a
full report is needed. If there is any question regarding whether the reports are needed, it may be
useful to consult the regulatory authority.
In presenting the detailed description of how the study was carried out, it may be possible simply
to restate the description in the initial protocol. Often, however, it is possible to present the
methodology of the study more concisely in a separate document. In each section describing the
design and conduct of the study, it is particularly important to clarify features of the study that are
not well-described in the protocol and identify ways in which the study as conducted differed from
the protocol, and to discuss the statistical methods and analyses used to account for these
deviations from the planned protocol.
The full integrated report of the individual study should include the most detailed discussion of
individual adverse events or laboratory abnormalities, but these should usually be reexamined as
part of an overall safety analysis of all available data in any application.
The report should describe demographic and other potentially predictive characteristics of the
study population and, where the study is large enough to permit this, present data for
demographic (e.g., age, sex, race, weight) and other (e.g., renal or hepatic function) subgroups so
that possible differences in efficacy or safety can be identified. Usually, however, subgroup
responses should be examined in the larger data base used in the overall analysis.
The data listings requested as part of the report (usually in an appendix) are those needed to
support critical analyses. Data listings that are part of the report should be readily usable by the
reviewer. Thus, although it may be desirable to include many variables in a single listing to limit
size, this should not be at the expense of clarity. An excess of data should not be allowed to lead
to, for example, overuse of symbols instead of words or easily understood abbreviations, or to
too-small displays. In this case, it is preferable to produce several listings.
2
Data should be presented in the report at different levels of detail: Overall summary figures and
tables for important demographic, efficacy, and safety variables may be placed in the text to
illustrate important points; other summary figures, tables, and listings for demographic, efficacy,
and safety variables should be provided in section 14; individual patient data for specified groups
of patients should be provided as listings in Appendix 16.2; and all individual patient data
(archival listings requested only in the United States) should be provided in Appendix 16.4.
In any table, figure, or data listing, estimated or derived values, if used, should be identified in a
conspicuous fashion. Detailed explanations should be provided as to how such values were
estimated or derived and what underlying assumptions were made.
The guidance provided below is detailed and is intended to notify the applicant of virtually all of
the information that should routinely be provided so that postsubmission requests for further data
clarification and analyses can be reduced as much as possible. Nonetheless, specific requirements
for data presentation and/or analysis may depend on specific situations, may evolve over time,
may vary from drug class to drug class, may differ among regions, and cannot be described in
general terms. It is, therefore, important to refer to specific clinical guidelines and to discuss data
presentation and analyses with the reviewing authority, whenever possible. Detailed written
guidance on statistical approaches is available from some authorities.
Each report should consider all of the topics described (unless clearly not relevant) although the
specific sequence and grouping of topics may be changed if alternatives are more logical for a
particular study. Some data in the appendices are specific requirements of individual regulatory
authorities and should be submitted as appropriate. The numbering should then be adapted
accordingly.
In the case of very large trials, some of the provisions of this guideline may be impractical or
inappropriate. When planning and when reporting such trials, contact with regulatory authorities
to discuss an appropriate report format is encouraged.
The provisions of this guideline should be used in conjunction with other ICH guidelines.
1. TITLE PAGE
Study title.
Indication studied.
If not apparent from the title, a brief (one to two sentences) description giving design
3
(parallel, cross-over, blinding, randomized) comparison (placebo, active, dose/response),
duration, dose, and patient population.
Study initiation date (first patient enrolled, or any other verifiable definition).
Name of company/sponsor signatory (the person responsible for the study report within
the company/sponsor). The name, telephone number, and fax number of the
company/sponsor contact persons for questions arising during review of the study report
should be indicated on this page or in the letter of application.
Statement indicating whether the study was performed in compliance with good clinical
practice (GCP), including the archiving of essential documents.
Date of the report (identify any earlier reports from the same study by title and date).
2. SYNOPSIS
A brief synopsis (usually limited to three pages) that summarizes the study should be provided
(see Annex I of the guideline for an example of a synopsis format used in Europe). The synopsis
should include numerical data to illustrate results, not just text or p-values.
4
The page number or other locating information of each section, including summary tables,
figures, and graphs.
A list and the locations of appendices, tabulations, and any case report forms provided.
A list of the abbreviations, and lists and definitions of specialized or unusual terms or
measurement units used in the report should be provided. Abbreviated terms should be spelled out
and the abbreviation indicated in parentheses at first appearance in the text.
5. ETHICS
It should be confirmed that the study and any amendments were reviewed by an IEC or
IRB. A list of all IEC's or IRB's consulted should be given in Appendix 16.1.3 and, if
required by the regulatory authority, thename of the committee Chair should be provided.
It should be confirmed that the study was conducted in accordance with the ethical
principles that have their origins in the Declaration of Helsinki.
How and when informed consent was obtained in relation to patient enrollment (e.g., at
allocation, prescreening) should be described.
Representative written information for the patient (if any) and a sample of the patient
consent form used should be provided in Appendix 16.1.3.
The administrative structure of the study (e.g., principal investigator, coordinating investigator,
steering committee, administration, monitoring and evaluation committees, institutions,
statistician, central laboratory facilities, contract research organization (C.R.O.), clinical trial
supply management) should be described briefly in the body of the report.
There should be provided in Appendix 16.1.4 a list of the investigators with their affiliations, their
role in the study, and their qualifications (curriculum vitae or equivalent). A similar list for other
persons whose participation materially affected the conduct of the study should also be provided
in Appendix 16.1.4. In the case of large trials with many investigators, the above information may
5
be abbreviated to consist of general statements of qualifications for persons carrying out particular
roles in the study with only the name, degree, and institutional affiliation and roles of each
investigator or other participant.
A. Investigators.
B. Any other person carrying out observations of primary or other major efficacy
variables, such as a nurse, physician's assistant, clinical psychologist, clinical pharmacist,
or house staff physician. It is not necessary to include in this list a person with only an
occasional role, e.g., an on-call physician who dealt with a possible adverse effect or a
temporary substitute for any of the above.
7. INTRODUCTION
The introduction should contain a brief statement (maximum: one page) placing the study in the
context of the development of the test drug/investigational product, relating the critical features of
the study (e.g., rationale and aims, target population, treatment, duration, primary endpoints) to
that development. Any guidelines that were followed in the development of the protocol or any
other agreements/meetings between the sponsor/company and regulatory authorities that are
relevant to the particular study should be identified or described.
8. STUDY OBJECTIVES
9. INVESTIGATIONAL PLAN
The overall study plan and design (configuration) of the study (e.g., parallel, cross-over)
should be described briefly but clearly, using charts and diagrams as needed. If other
6
studies used a very similar protocol, it may be useful to note this and describe any
important differences. The actual protocol and any changes should be included as
Appendix 16.1.1 and a sample case report form (unique pages only; i.e., it is not necessary
to include identical pages from forms for different evaluations or visits) as Appendix
16.1.2. If any of the information in this section comes from sources other than the
protocol, these should be identified.
The specific control chosen and the study design used should be discussed, as necessary.
Examples of design issues meriting discussion follow.
Generally, the control (comparison) groups that are recognized are placebo concurrent
control, no treatment concurrent control, active treatment concurrent control, dose
comparison concurrent control, and historical control. In addition to the type of control,
other critical design features that may need discussion are use of a cross-over design and
selection of patients with particular prior history, such as response or nonresponse to a
specific drug or member of a drug class. If randomization was not used, it is important to
explain how other techniques, if any, guarded against systematic selection bias.
7
Known or potential problems associated with the study design or control group chosen
should be discussed in light of the specific disease and therapies being studied. For a
cross-over design, for example, there should be consideration, among other things, of the
likelihood of spontaneous change in the disease and of carry-over effects of treatment
during the study.
Other specific features of the design may also deserve discussion, including presence or
absence of washout periods and the duration of the treatment period, especially for a
chronic illness. The rationale for dose and dose-interval selection should be explained, if it
is not obvious. For example, once daily dosing with a short half-life drug whose effect is
closely related in time to blood level is not usually effective; if the study design uses such
dosing, this should be explained, e.g., by pointing to pharmacodynamic evidence that
effect is prolonged compared to blood levels. The procedures used to seek evidence of
“escape” from drug effect at the end of the dose-interval, such as measurements of effect
just before dosing, should be described. Similarly, in a parallel design dose-response study,
the choice of doses should be explained.
The patient population and the selection criteria used to enter the patients into the
8
study should be described, and the suitability of the population for the purposes of
the study discussed. Specific diagnostic criteria used, as well as specific
disease(e.g., disease of a particular severity or duration, results of a particular test
or rating scale(s) or physical examination, particular features of clinical history,
such as failure or success on prior therapy, or other potential prognostic factors
and any age, sex, or ethnic factors) should be presented.
Screening criteria and any additional criteria for randomization or entry into the
test drug/investigational product treatment part of the trial should be described. If
there is reason to believe that there were additional entry criteria, not defined in the
protocol, the implications of these should be discussed. For example, some
investigators may have excluded or entered into other studies patients who were
particularly ill or who had particular baseline characteristics.
The criteria for exclusion at entry into the study should be specified and the
rationale provided (e.g., safety concerns, administrative reasons, or lack of
suitability for the trial). The impact of exclusions on the generalizability of the
study should be discussed in section 13 of the study report or in an overview of
safety and efficacy.
9.4 Treatments
9
The source of placebos and active control/comparator product(s) should be
provided. Any modification of comparator product(s) from their usual commercial
state should be noted, and the steps taken to assure that their bioavailability was
unaltered should be described.
The specific methods used to assign patients to treatment groups, e.g., centralized
allocation, allocation within sites, adaptive allocation (that is, assignment on the
basis of earlier assignment or outcome) should be described in the text of the
report, including any stratification or blocking procedures. Any unusual features
should be explained.
The doses or dose ranges used in the study should be given for all treatments and
the basis for choosing them described (e.g., prior experience in humans, animal
data).
Procedures for selecting each patient's dose of test drug/ investigational product
and active control/comparator should be described. These procedures can vary
from simple random assignment to a selected fixed drug/dose regimen, to use of a
specified titration procedure, or to more elaborate response-determined selection
procedures, e.g., where dose is titrated upward at intervals until intolerance or
10
some specified endpoint is achieved. Procedures for back-titration, if any, should
also be described.
The timing (time of day, interval) of dosing and the relation of dosing to meals
should be described and, if timing was not specified, this should be noted.
Any specific instructions to patients about when or how to take the dose(s) should
be described.
9.4.6 Blinding
If blinding was considered unnecessary to reduce bias for some or all of the
observations, this should be explained; e.g., use of a random-zero
sphygmomanometer eliminates possible observer bias in reading blood pressure
and Holter tapes are often read by automated systems that are presumably immune
to observer bias. If blinding was considered desirable but not feasible, the reasons
and implications should be discussed. Sometimes blinding is attempted but is
known to be imperfect because of obvious drug effects in at least some patients
(dry mouth, bradycardia, fever, injection site reactions, changes in laboratory data).
Such problems or potential problems should be identified and, if there were any
attempts to assess the magnitude of the problem or manage it (e.g., by having
endpoint measurements carried out by people shielded from information that might
reveal treatment assignment), they should be described.
Which drugs or procedures were allowed before and during the study, whether and
11
how their use was recorded, and any other specific rules and procedures related to
permitted or prohibited concomitant therapy should be described. How allowed
concomitant therapy might affect the outcome due either to drug-drug interaction
or to direct effects on the study endpoints should be discussed, and how the
independent effects of concomitant and study therapies could be ascertained
should be explained.
The specific efficacy and safety variables to be assessed and laboratory tests to be
conducted, their schedule (days of study, time of day, relation to meals, and the
timing of critical measures in relation to test drug administration, e.g., just prior to
next dose, 2 hours after dose), the methods for measuring them, and the persons
responsible for the measurements should be described. If there were changes in
personnel carrying out critical measurements, these should be reported.
It is usually helpful to display graphically in a flow chart (see Annex III of the
guideline) the frequency and timing of efficacy and safety measurements; visit
numbers and times should be shown, or, alternatively, times alone can be used
(visit numbers alone are more difficult to interpret). Any specific instructions (e.g.,
guidance or use of a diary) to the patients should also be noted.
If anyone other than the investigator was responsible for evaluation of clinical
outcomes (e.g., the sponsor or an external committee to review X-rays or ECG's
or to determine whether the patient had a stroke, acute infarction, or sudden
death), the person or group should be identified. The procedures used, including
means of maintaining blindness and centralizing readings and measurements,
12
should be described fully.
Any rating of adverse events by the investigator, sponsor, or external group (e.g.,
rating by severity or likelihood of drug causation) should be described. The criteria
for such ratings, if any, should be given and the parties responsible for the ratings
should be clearly identified. If efficacy or safety was to be assessed in terms of
categorical ratings or numerical scores, the criteria used for point assignment
should be provided (e.g., definitions of point scores). For multicenter studies, how
methods were standardized should be indicated.
If any of the efficacy or safety assessments was not standard, i.e., widely used and
generally recognized as reliable, accurate, and relevant (able to discriminate
between effective and ineffective agents), its reliability, accuracy, and relevance
should be documented. It may be helpful to describe alternatives considered but
rejected.
If the protocol did not identify the primary variables, the study report should
explain how these critical variables were selected (e.g., by reference to
publications, guidelines, or previous actions by regulatory authorities) and when
they were identified (i.e., before or after the study was completed and unblinded).
If an efficacy threshold was defined in the protocol, this should be described.
13
9.5.4 Drug Concentration Measurements
Any drug concentrations to be measured and the sample collection times and
periods in relation to the timing of drug administration should be described. Any
relation of drug administration and sampling to ingestion of food, posture, and the
possible effects of concomitant medication/alcohol/ caffeine/nicotine should also be
addressed. The biological sample measured, the handling of samples and the
method of measurement used should be described, referring to published and/or
internal assay validation documentation for methodological details. Where other
factors are believed important in assessing pharmacokinetics (e.g., soluble
circulating receptors, renal or hepatic function), the timing and plans to measure
these factors should also be specified.
The quality assurance and quality control systems implemented to assure the quality of the
data should be described in brief. If none were used, this should be stated. Documentation
of inter-laboratory standardization methods and quality assurance procedures, if used,
should be provided under Appendix 16.1.10.
Any steps taken at the investigation site or centrally to ensure the use of standard
terminology and the collection of accurate, consistent, complete, and reliable data, such as
training sessions, monitoring of investigators by sponsor personnel, instruction manuals,
data verification, cross-checking, use of a central laboratory for certain tests, centralized
ECG reading, or data audits, should be described. It should be noted whether investigator
meetings or other steps were taken to prepare investigators and standardize performance.
The statistical analyses planned in the protocol and any changes made before
outcome results were available should be described. In this section, emphasis
should be on which analyses, comparisons, and statistical tests were planned, not
on which ones were actually used. If critical measurements were made more than
once, the particular measurements (e.g., average of several measurements over the
entire study, values at particular times, values only from study completers, or last
on-therapy value) planned as the basis for comparison of test drug/investigational
product and control should be specified. Similarly, if more than one analytical
14
approach is plausible, e.g., changes from baseline response, slope analysis,
life-table analysis, the planned approach should be identified. Also, whether the
primary analysis is to include adjustment for covariates should be specified.
If there were any planned reasons for excluding from analysis patients for whom
data are available, these should be described. If there were any subgroups whose
results were to be examined separately, these should be identified. If categorical
responses (global scales, severity scores, responses of a certain size) were to be
used in analyzing responses, they should be clearly defined.
Planned monitoring of the results of the study should be described. If there was a
data monitoring committee, either within or outside the sponsor's control, its
composition and operating procedures should be described and procedures to
maintain study blinding should be given. The frequency and nature of any planned
interim analysis, any specified circumstances in which the study would be
terminated, and any statistical adjustments to be employed because of interim
analyses should be described.
The planned sample size and the basis for it, such as statistical considerations or
practical limitations, should be provided. Methods for sample size calculation
should be given together with their derivations or source of reference. Estimates
used in the calculations should be given, and explanations should be provided as to
how they were obtained. For a study intended to show a difference between
treatments, the difference the study is designed to detect should be specified. For a
positive control study intended to show that a new therapy is at least as effective
as the standard therapy, the sample size determination should specify the difference
between treatments that would be considered unacceptably large and, therefore,
the difference the study is designed to be able to exclude.
Any change in the conduct of the study or planned analyses (e.g., dropping a treatment
group, changing the entry criteria or drug dosages, adjusting the sample size) instituted
after the start of the study should be described. The time(s) and reason(s) for the
change(s), the procedure used to decide on the change(s), the person(s) or group(s)
responsible for the change(s) and the nature and content of the data available (and to
whom they were available) when the change was made should also be described, whether
the change was documented as a formal protocol amendment or not. Personnel changes
need not be included. Any possible implications of the change(s) for the interpretation of
the study should be discussed briefly in this section and more fully in other appropriate
sections of the report. In every section of the report, a clear distinction between conditions
15
(procedures) planned in the protocol and amendments or additions should be made. In
general, changes in planned analyses made prior to breaking the blind have limited
implications for study interpretation. It is therefore particularly critical that the timing of
changes relative to blind breaking and availability of outcome results be well characterized.
There should be a clear accounting of all patients who entered the study, using figures or
tables in the text of the report. The numbers of patients who were randomized and who
entered and completed each phase of the study (or each week/month of the study) should
be provided, as well as the reasons for all postrandomization discontinuations, grouped by
treatment and by major reason (e.g., lost to followup, adverse event, poor compliance). It
may also be relevant to provide the number of patients screened for inclusion and a
breakdown of the reasons for excluding patients during screening, if this could help clarify
the appropriate patient population for eventual drug use. A flow chart is often helpful (see
Annexes IVa and IVb for examples). Whether patients are followed for the duration of the
study, even if drug is discontinued, should be made clear.
In Appendix 16.2.1, there should also be a listing of all patients discontinued from the
study after enrollment, broken down by center and treatment group, giving a patient
identifier, the specific reason for discontinuation, the treatment (drug and dose),
cumulative dose (where appropriate), and the duration of treatment before
discontinuation. Whether or not the blind for the patient was broken at the time of
discontinuation should be noted. It may also be useful to include other information, such
as critical demographic data (e.g., age, sex, race), concomitant medication, and the major
response variable(s) at termination. See Annex V for an example of such a listing.
All important deviations related to study inclusion or exclusion criteria, conduct of the
trial, patient managements or patient assessment should be described.
In the body of the text, protocol deviations should be appropriately summarized by center
and grouped into different categories, such as:
Those who entered the study even though they did not satisfy the entry criteria.
Those who developed withdrawal criteria during the study but were not
withdrawn.
16
Those who received an excluded concomitant treatment.
In Appendix 16.2.2, individual patients with these protocol deviations should be listed,
broken down by center for multicenter studies.
Exactly which patients were included in each efficacy analysis should be precisely defined,
e.g., all patients receiving any test drugs/investigational products, all patients with any
efficacy observation or with a certain minimum number of observations, only patients
completing the trial, all patients with an observation during a particular time window, or
only patients with a specified degree of compliance. It should be clear, if not defined in the
study protocol, when (relative to study unblinding) and how inclusion/exclusion criteria
for the data sets analyzed were developed. Generally, even if the applicant's proposed
primary analysis is based on a reduced subset of the patients with data, there should also
be, for any trial intended to establish efficacy, an additional analysis using all randomized
(or otherwise entered) patients with any on-treatment data.
There should be a tabular listing of all patients, visits, and observations excluded from the
efficacy analysis provided in Appendix 16.2.3 (see Annex VI for an example). The reasons
for exclusions should also be analyzed for the whole treatment group over time (see
Annex VII for an example).
Group data for the critical demographic and baseline characteristics of the patients, as well
as other factors arising during the study that could affect response, should be presented in
this section and comparability of the treatment groups for all relevant characteristics
should be displayed by use of tables or graphs in section 14.1. The data for the patient
sample included in the “all patients with data” analysis should be given first. This may be
followed by data on other groups used in principal analyses, such as the “per-protocol”
analysis or other analyses, e.g., groups defined by compliance, concomitant
disease/therapy, or demographic/baseline characteristics. When such groups are used, data
for the complementary excluded group should also be shown. In a multicenter study,
where appropriate, comparability should be assessed by center, and centers should be
compared.
A diagram showing the relationship between the entire sample and any other analysis
groups should be provided.
The critical variables will depend on the specific nature of the disease and on the protocol
17
but will usually include:
Demographic variables:
- Age
- Sex
- Race
Disease factors:
- Specific entry criteria (if not uniform), duration, stage and severity of disease,
and other clinical classifications and subgroupings in common usage or of known
prognostic significance.
- Baseline values for critical clinical measurements carried out during the study or
identified as important indicators of prognosis or response to therapy.
- Concomitant illness at trial initiation, such as renal disease, diabetes, heart failure.
- Relevant previous illness.
- Relevant previous treatment for illness treated in the study.
- Concomitant treatment maintained, even if the dose was changed during the
study, including oral contraceptive and hormone replacement therapy; treatments
stopped at entry into the study period (or changed at study initiation).
Other factors that might affect response to therapy (e.g., weight, renin status,
antibody levels, metabolic status).
Other possibly relevant variables (e.g., smoking, alcohol intake, special diets) and,
for women, menstrual status and date of last menstrual period, if pertinent for the
study.
In addition to tables and graphs giving group data for these baseline variables, relevant
individual patient demographic and baseline data, including laboratory values, and all
concomitant medication for all individual patients randomized (broken down by treatment
and by center for multicenter studies) should be presented in by-patient tabular listings in
Appendix 16.2.4. Although some regulatory authorities will require all baseline data to be
presented elsewhere in tabular listings, the Appendix to the study report should be limited
to only the most relevant data, generally the variables listed above.
Any measurements of compliance of individual patients with the treatment regimen under
study and drug concentrations in body fluids should be summarized, analyzed by treatment
group and time interval, and tabulated in Appendix 16.2.5.
18
11.4.1 Analysis of Efficacy
Treatment groups should be compared for all critical measures of efficacy (primary
and secondary endpoints; any pharmacodynamic endpoints studied), as well as
benefit/risk assessment(s) in each patient where these are utilized. In general, the
results of all analyses contemplated in the protocol and an analysis including all
patients with on-study data should be performed in studies intended to establish
efficacy. The analysis should show the size (point estimate) of the difference
between the treatments, the associated confidence interval, and, where utilized, the
results of hypothesis testing.
In many cases, efficacy and safety endpoints are difficult to distinguish (e.g., deaths
in a fatal disease study). Many of the principles addressed below should be adopted
for critical safety measures as well.
The statistical analysis used should be described for clinical and statistical
reviewers in the text of the report, with detailed documentation of statistical
methods (see Annex IX) presented in Appendix 16.1.9. Important features of the
analysis, including the particular methods used, adjustments made for demographic
or baseline measurements or concomitant therapy, handling of dropouts and
missing data, adjustments for multiple comparisons, special analyses of multicenter
studies, and adjustments for interim analyses, should be discussed. Any changes in
19
the analysis made after blind-breaking should be identified.
There are several factors that may affect dropout rates. These include the
duration of the study, the nature of the disease, the efficacy and toxicity of
the drug under study, and other factors that are not therapy-related.
Ignoring the patients who dropped out of the study and drawing
conclusions based only on patients who completed the study can be
misleading. A large number of dropouts, however, even if included in an
analysis, may introduce bias, particularly if there are more early dropouts in
one treatment group or the reasons for dropping out are treatment or
outcome related. Although the effects of early dropouts, and sometimes
even the direction of bias, can be difficult to determine, possible effects
should be explored as fully as possible. It may be helpful to examine the
observed cases at various times or, if dropouts were very frequent, to
concentrate on analyses at times when most of the patients were still under
observation and when the full effect of the drug was realized. It may also
be helpful to examine modeling approaches to the evaluation of such
incomplete data sets.
The results of a clinical trial should be assessed not only for the subset of
patients who completed the study, but also for the entire patient population
as randomized or at least for all those with any on-study measurements.
20
Several factors should be considered and compared for the treatment
groups in analyzing the effects of dropouts: The reasons for the dropouts,
the time to dropout, and the proportion of dropouts among treatment
groups at various time points.
Procedures for dealing with missing data, e.g., use of estimated or derived
data, should be described. Detailed explanation should be provided as to
how such estimations or derivations were done and what underlying
assumptions were made.
21
11.4.2.5 Multiple Comparisons/Multiplicity
22
hypotheses worth examining in other studies or be helpful in refining
labeling information, patient selection, or dose selection. Where there is a
prior hypothesis of a differential effect in a particular subgroup, this
hypothesis and its assessment should be part of the planned statistical
analysis.
In addition to tables and graphs representing group data, individual response data
and other relevant study information should be presented in tables. Some
regulatory authorities may require all individual data in archival case report
tabulations. What needs to be included in the report will vary from study to study
and from one drug class to another, and the applicant must decide, if possible after
consultation with the regulatory authority, what to include in an Appendix to the
study report. The study report should indicate what material is included as an
Appendix, what is in the more extensive archival case report tabulations, if
required by the regulatory authority, and what is available on request.
23
developed as well. For example, if there are many measurements reported,
tabulations of the most critical measurements for each patient (e.g., the blood
pressure value at certain visits might be more important than others) will be useful
in providing an overview of each individual's results in a study, with each patient's
response summarized on a single line or small number of lines.
When the dose in each patient can vary, the actual doses received by patients
should be shown and individual patient's doses should be tabulated. Although
studies not designed as dose-response studies may have limited ability to
contribute dose-response information, the available data should be examined for
whatever information they can yield. In examining the dose response, it may be
helpful to calculate dose as mg/kg body weight or milligram per square meter
(mg/m2) body surface.
Any apparent relationship between response and concomitant therapy and between
response and past and/or concurrent illness should be described.
While individual patient data ordinarily can be displayed in tabular listings, it has
on occasion been helpful to construct individual patient profiles in other formats,
such as graphic displays. These might, for example, show the value of a particular
parameter(s) over time, the drug dose over the same period, and the times of
particular events (e.g., an adverse event or change in concomitant therapy). Where
group mean data represent the principal analyses, this kind of “case report extract”
may offer little advantage; it may be helpful, however, if overall evaluation of
individual responses is a critical part of the analysis.
24
statistical approaches, and results of exploratory analyses.
Analysis of safety-related data can be considered at three levels. First, the extent of exposure
(dose, duration, number of patients) should be examined to determine the degree to which safety
can be assessed from the study. Second, the more common adverse events and laboratory test
changes should be identified, classified in some reasonable way, compared for treatment groups,
and analyzed, as appropriate, for factors that may affect the frequency of adverse reactions/events,
such as time dependence, relation to demographic characteristics, relation to dose or drug
concentration. Finally, serious adverse events and other significant adverse events should be
identified, usually by close examination of patients who left the study prematurely because of an
adverse event, whether or not identified as drug related, or who died.
The ICH Guideline entitled “Clinical Safety Data Management: Definitions and Standards for
Expedited Reporting” defines serious adverse events as follows: “A serious adverse event
(experience) or reaction is any untoward medical occurrence that at any dose: results in death, is
life-threatening, requires inpatient hospitalization or prolongation of existing hospitalization,
results in persistent or significant disability/incapacity, or is a congenital anomaly/birth defect.”
For the purpose of this guideline, “other significant adverse events” are marked hematological and
other laboratory abnormalities and any adverse events that led to an intervention, including
withdrawal of drug treatment, dose reduction, or significant additional concomitant therapy.
In the following sections, three kinds of analysis and display are called for:
1. Summarized data, often using tables and graphical presentations presented in the main
body of the report;
2. Listings of individual patient data; and
3. Narrative statements of events of particular interest.
In all tabulations and analyses, events associated with both test drug and control treatment should
be displayed.
The extent of exposure to test drugs/investigational products (and to active control and
placebo) should be characterized according to the number of patients exposed, the
duration of exposure, and the dose to which they were exposed.
25
month, more than 1 month to 6 months. The numbers exposed to test
drug(s)/investigational product(s) for the various durations should also be broken
down into age, sex, and racial subgroups, and any other pertinent subgroups, such
as groups defined by disease (if more than one is represented), disease severity, or
concurrent illness.
Dose: The mean or median dose used and the number of patients exposed to
specified daily dose levels should be given; the daily dose levels used could be the
maximum dose for each patient, the dose with longest exposure for each patient,
or the mean daily dose. It is often useful to provide combined dose-duration
information, such as the numbers exposed for a given duration (e.g., at least 1
month) to the most common dose, the highest dose, or the maximum
recommended dose. In some cases, cumulative dose might be pertinent. Dosage
may be given as the actual daily dose or on a mg/kg or mg/m<SUP>2 basis, as
appropriate. The number of patients exposed to various doses should be broken
down into age, sex, racial, and any other pertinent subgroups.
It is assumed that all patients entered into treatment who received at least one dose of the
treatment are included in the safety analysis; if not, an explanation should be provided.
The overall adverse event experience in the study should be described in a brief
narrative, supported by the following more detailed tabulations and analyses. In
these tabulations and analyses, events associated with both the test drug and
control treatment should be displayed.
All adverse events occurring after initiation of study treatments (including events
likely to be related to the underlying disease or likely to represent concomitant
illness, unless there is a prior agreement with the regulatory authority to consider
specified events as disease related) should be displayed in summary tables (section
14.3.1). The tables should include changes in vital signs and any laboratory
changes that were considered serious adverse events or other significant adverse
events.
26
In most cases, it will also be useful to identify in such tables “treatment emergent
signs and symptoms” (TESS: events not seen at baseline and events that worsened
even if present at baseline).
The tables should list each adverse event, the number of patients in each treatment
group in whom the event occurred, and the rate of occurrence. When treatments
are cyclical, e.g., cancer chemotherapy, it may also be helpful to list results
separately for each cycle. Adverse events should be grouped by body system. Each
event may then be divided into defined severity categories (e.g., mild, moderate,
severe) if these were used. The tables may also divide the adverse events into those
considered at least possibly related to drug use and those considered not related,
or use another causality scheme (e.g., unrelated or possibly, probably, or definitely
related). Even when such a causality assessment is used, the tables should include
all adverse events, whether or not considered drug related, including events
thought to represent intercurrent illnesses. Subsequent analyses of the study or of
the overall safety data base may help to distinguish between adverse events that
are, or are not, considered drug related. So that it is possible to analyze and
evaluate the data in these tables, it is important to identify each patient having each
adverse event. An example of such a tabular presentation is shown below.
Body
System A
N14
N15
N16
Event 2
27
1
NR = not related; related coud be expanded, e.g., as definite, probable, possible.
2
Patient identification number.
In presenting adverse events, it is important both to display the original terms used
by the investigator and to attempt to group related events (i.e., events that
probably represent the same phenomenon), so that the true occurrence rate is not
obscured. One way to do this is with a standard adverse reaction/events dictionary.
The basic display of adverse event rates described in section 12.2.2 (and located in
section 14.3.1) of the report should be used to compare rates in treatment and
control groups. For this analysis, it may be helpful to combine the event severity
categories and the causality categories, leading to a simpler side-by-side
comparison of treatment groups. In addition, although this is usually best done in
an integrated analysis of safety, if study size and design permit, it may be useful to
examine the more common adverse events that seem to be drug related for
relationship to dosage and mg/kg or mg/m<SUP>2 dose; dose regimen; duration
of treatment; total dose; demographic characteristics such as age, sex, race; other
baseline features such as renal status, efficacy outcomes, and drug concentration. It
may also be useful to examine time of onset and duration of adverse events. A
variety of additional analyses may be suggested by the study results or by the
pharmacology of the test drug/investigational product.
Under certain circumstances, life table or similar analyses may be more informative
than reporting of crude adverse event rates. When treatments are cyclical, e.g.,
cancer chemotherapy, it may also be helpful to analyze results separately for each
cycle.
All adverse events for each patient, including the same event on several occasions,
28
should be listed in Appendix 16.2.7, giving both preferred term and the original
term used by the investigator. The listing should be by investigator and by
treatment group and should include:
Patient identifier.
Seriousness (serious/nonserious).
Date of onset or date of clinic visit at which the event was discovered.
Timing of onset of the adverse event in relation to the last dose of the test
drug/investigational product (when applicable).
Study treatment at the time of event or the most recent study treatment
taken.
29
Any abbreviations and codes should be clearly explained at the beginning of the
listing or, preferably, on each page.
12.3. Deaths, Other Serious Adverse Events, and Other Significant Adverse Events
Deaths, other serious adverse events, and other significant adverse events deserve special
attention.
12.3.1 Listing of Deaths, Other Serious Adverse Events, and Other Significant
Adverse Events
Listings, containing the same information as called for in section 12.2.4, should be
provided for the following events.
12.3.1.1 Deaths
All deaths during the study, including the post-treatment followup period,
and deaths that resulted from a process that began during the study, should
be listed by patient in section 14.3.2.
All serious adverse events (other than death but including the serious
adverse events temporally associated with or preceding the deaths) should
be listed in section 14.3.2. The listing should include laboratory
abnormalities, abnormal vital signs, and abnormal physical observations
that were considered serious adverse events.
12.3.2 Narratives of Deaths, Other Serious Adverse Events, and Certain Other
Significant Adverse Events
There should be a brief narrative describing each death, other serious adverse
event, and other significant adverse event that is judged to be of special interest
because of clinical importance. These narratives can be placed either in the text of
the report or in section 14.3.3, depending on their number. Events that were
30
clearly unrelated to the test drug/investigational product may be omitted or
described very briefly. In general, the narrative should describe the following: The
nature and intensity of event; the clinical course leading up to event, with an
indication of timing relevant to test drug/investigational product administration;
relevant laboratory measurements; whether the drug was stopped, and when;
countermeasures; post-mortem findings; investigator's opinion on causality and
sponsor's opinion on causality, if appropriate.
Patient identifier.
Disease being treated (this is not required if it is the same for all patients)
with duration (of current episode) of illness.
12.3.3 Analysis and Discussion of Deaths, Other Serious Adverse Events, and
Other Significant Adverse Events
The significance of the deaths, other serious adverse events, and other significant
adverse events leading to withdrawal, dose reduction, or institution of concomitant
therapy should be assessed with respect to the safety of the test
drug/investigational product. Particular attention should be paid to whether any of
these events may represent a previously unsuspected important adverse effect of
the test drug/investigational product. For serious adverse events that appear of
particular importance, it maybe useful to use life table or similar analyses to show
their relation to time on test drug/investigational product and to assess their risk
over time.
31
When required by regulatory authorities, the results of all safety-related laboratory
tests should be available in tabular listings, using a display similar to the following,
where each row represents a patient visit at which a laboratory study was done,
with patients grouped by investigator (if more than one) and treatment group, and
columns include critical demographic data, drug dose data, and the results of the
laboratory tests. Because not all tests can be displayed in a single table, they should
be grouped logically (e.g., hematological tests, liver chemistries, electrolytes,
urinalysis). Abnormal values should be identified, e.g., by underlining or
bracketing. These listings should be submitted as part of the registration/marketing
application, when this is required, or may be available on request.
Laboratory Tests
#1 T0 70 70 kg 400 mg V1 † V5 V9
T1 V2 V6 V10
T2 V3 V7 V11
T3 V4 V8 V12
For all regulatory authorities, there should be a by-patient listing of all abnormal
laboratory values in section 14.3.4, using the format described above. For
laboratory abnormalities of special interest (abnormal laboratory values of potential
clinical importance), it may also be useful to provide additional data, such as
normal values before and after the abnormal value, and values of related laboratory
tests. In some cases, it may be desirable to exclude certain abnormal values from
further analysis. For example, single, nonreplicated, small abnormalities of some
tests (e.g., uric acid or electrolytes) or occasional low values of some tests (e.g.,
transaminase, alkaline phosphatase, or BUN) can probably be defined as clinically
insignificant and excluded. Any such decisions should be clearly explained,
however, and the complete list of values provided (or available to authorities on
request) should identify every abnormal value.
32
The necessary evaluation of laboratory values will in part be determined by the
results seen, but, in general, the following analyses should be provided. For each
analysis, comparison of the treatment and control groups should be carried out, as
appropriate and compatible with study size. In addition, normal laboratory ranges
should be given for each analysis.
For each parameter at each time over the course of the study (e.g., at each
visit) the following should be described: The group mean or median values,
the range of values, and the number of patients with abnormal values or
with abnormal values that are of a certain size (e.g., twice the upper limit of
normal or five times the upper limit; choices should be explained). Graphs
may be used.
33
for treatment and control groups. Alternatively, the display could
show baseline and most extreme on-treatment value. These displays
identify outliersreadily (it is useful to include patient identifiers for
the outliers).
12.5. Vital Signs, Physical Findings, and Other Observations Related to Safety
Vital signs, other physical findings, and other observations related to safety should be
analyzed and presented in a way similar to laboratory variables. If there is evidence of a
drug effect, any dose-response or drug-concentration-response relationship or relationship
to patient variables (e.g., disease, demographics, concomitant therapy) should be identified
and the clinical relevance of the observation described. Particular attention should be given
to changes not evaluated as efficacy variables and to those considered to be adverse
events.
34
The efficacy and safety results of the study and the relationship of risks and benefits should be
briefly summarized and discussed, referring to the tables, figures, and sections above as needed.
The presentation should not simply repeat the description of results nor introduce new results.
The discussion and conclusions should clearly identify any new or unexpected findings, comment
on their significance, and discuss any potential problems such as inconsistencies between related
measures. The clinical relevance and importance of the results should also be discussed in the light
of other existing data. Any specific benefits or special precautions required for individual subjects
or at-risk groups and any implications for the conduct of future studies should be identified.
Alternatively, such discussions may be reserved for summaries of safety and efficacy referring to
the entire dossier (integrated summaries).
Figures should be used to visually summarize the important results, or to clarify results that are
not easily understood from tables.
Important demographic, efficacy, and safety data should be presented in summary figures or tables
in the text of the report. However, if these become obtrusive because of size or number they
should be presented here, cross-referenced to the text, along with supportive, or additional,
figures, tables, or listings.
The following information may be presented in this section of the core clinical study report:
14.3.3 Narratives of Deaths, Other Serious and Certain Other Significant Adverse
Events
A list of articles from the literature pertinent to the evaluation of the study should be provided.
35
Copies of important publications should be attached in an Appendix (Appendices 16.1.11 and
16.1.12). References should be given in accordance with the internationally accepted standards of
the 1979 Vancouver Declaration on “Uniform Requirements for Manuscripts Submitted to
Biomedical Journals” or the system used in “Chemical Abstracts.”
16. APPENDICES
This section should be prefaced by a full list of all Appendices available for the study report.
Where permitted by the regulatory authority, some of the following Appendices need not be
submitted with the report but need to be provided only on request.
The applicant should therefore clearly indicate those Appendices that are submitted with the
report.
N.B.: In order to have Appendices available on request, they should be finalized by the time of
filing of the submission.
16.1.3 List of IEC's or IRB's (plus the name of the committee chair if required by
the regulatory authority) and representative written information for patient and
sample consent forms.
16.1.4 List and description of investigators and other important participants in the
study, including brief (one page) CV's or equivalent summaries of training and
experience relevant to the performance of the clinical study.
36
16.1.9 Documentation of statistical methods.
16.3.1 CRF's for deaths, other serious adverse events, and withdrawals for
adverse events.
37
ANNEX I
SYNOPSIS
Volume:
Name of Finished Product:
Page:
Title of Study:
Investigators:
Study centre(s):
Publication (reference)
Objectives:
Methodology:
Duration of treatment:
I-1
Name of Sponsor/Company: Individual Study Table (For National Authority
Referring to Part Use Only)
of the Dossier
Volume:
Name of Finished Product:
Page:
Safety:
Statistical methods:
SUMMARY - CONCLUSIONS
EFFICACY RESULTS :
SAFETY RESULTS:
CONCLUSION:
I-2
ANNEX II
PRINCIPAL OR COORDINATING
INVESTIGATOR(S) SIGNATURE(S)
OR SPONSOR ’S RESPONSIBLE MEDICAL OFFICER
_______________
STUDY TITLE: ..............................................................................
...
I have read this report and confirm that to the best of my knowledge it accurately
describes the conduct and results of the study
INVESTIGATOR:______________________ SIGNATURE(S)____________
OR SPONSOR’S RESPONSIBLE
MEDICAL OFFICER
AFFILIATION:________________________ ______________________
_______________________
DATE:______________________________
II-1
ANNEX IIIa
STUDY DESIGN AND SCHEDULE OF ASSESSMENTS
TREATMENT A B C
PERIOD
B1 B2 C1 C2
TEST DRUG/
INVESTIGATIONAL PRODUCT TEST DRUG/
A INVESTIGATIONAL
PRODUCT A
5 mg 10 mg 5 mg 10 mg
Run-in
5 mg 10 mg 5 mg 10 mg
Weeks -2(-3) 0 3 6 9 12
Visit 1 2 3 4 5 6
Exercise test 24 h x1 x2 x x x x
Medical history x
Physical examination x x
ECG x x
Lab. invest. x x
Adverse events x x x x x
IIIa-1
ANNEX IIIb
Study Week -2 -1 0 1 2 3 4 5 6 8
Informed x
Consent
History x
Physical x x
Exam.
Effectiveness
primary x x x x x x x x x x
variable
secondary x x x x x x x
variable
Safety
Adverse x x x x x x x x x x
events
Lab. tests x x x x x x
Body weight x x x x
IIIb-1
ANNEX IVa
Disposition of Patients
N = 1,724
PATIENTS RECEIVING
DOUBLE-BLINDED MEDICATION
N = 340 N= N= N= N=
REGIMEN A REGIMEN B REGIMEN C REGIMEN D REGIMEN E
N = 281 N = 59 N= N= N= N= N= N= N= N=
COMPLETED WITHDRAWN COMPLETED WITHDRAWN COMPLETED WITHDRAWN COMPLETED WITHDRAWN COMPLETED WITHDRAWN
STUDY STUDY STUDY STUDY STUDY
ADVERSE EVENT (20) ADVERSE EVENT (19) ADVERSE EVENT (26) ADVERSE EVENT (24) ADVERSE EVENT (42)
UNSAT. RESPONSE UNSAT. RESPONSE UNSAT. RESPONSE UNSAT. RESPONSE UNSAT. RESPONSE
EFFICACY (1) EFFICACY (2) EFFICACY (1) EFFICACY (1) EFFICACY (0)
FAILURE TO RETURN (6) FAILURE TO RETURN (8) FAILURE TO RETURN (7) FAILURE TO RETURN (6) FAILURE TO RETURN (6)
OTHER MED. EVENT (5) OTHER MED. EVENT (8) OTHER MED. EVENT (4) OTHER MED. EVENT (8) OTHER MED. EVENT (14)
OTHER NONMED. EVENT (5) OTHER NONMED. EVENT (4) OTHER NONMED. EVENT (6) OTHER NONMED. EVENT (7) OTHER NONMED. EVENT (1)
PROTOCOL VIOLATION (10) PROTOCOL VIOLATION (10) PROTOCOL VIOLATION (3) PROTOCOL VIOLATION (6) PROTOCOL VIOLATION (14)
PATENT REQUEST (12) PATENT REQUEST (10) PATENT REQUEST (25) PATENT REQUEST (27) PATENT REQUEST (15)
N = 1,361
PATIENTS COMPLETING STUDY
IVa-1
ANNEX IVb
DISPOSITION OF PATIENTS
N = 2670
PATIENTS SCREENED
N = 17320
N = 938
PATIENTS RANDOMIZED
Screening Failures
Reasons:
____________ (300)
____________ (271)
____________
N =8
DID NOT RECEIVE
ANY MEDICATION
Reasons: N = 1724
____________ (2) PATIENTS RECEIVING
____________ (4)
DOUBLE-BLIND
____________ (2) MEDICATION
N= N= N=
REGIMEN A REGIMEN B REGIMEN C
N= N= N= N= N= N=
COMPLETED WITHDRAWN COMPLETED WITHDRAWN COMPLETED WITHDRAWN
IVb-1
ANNEX V
STUDY #
(Data Set Identification)
LISTING OF PATIENTS WHO DISCONTINUED THERAPY
Centre.:
Concomitant Reason for
Treatment Patient# Sex Age Last Visit Duration Dose Medication Discontin.
Therapy
failure
Active Control/
Comparator
Placebo
*
The specific reaction leading to discontinuation
V-1
ANNEX VI
STUDY #
(Data Set Identification)
Center.:
Active Control/Comparator
Placebo
Reference Tables
Summary:
VI-1
ANNEX VII
STUDY #
(Data Set Identification)
Week
Reason ___1___ ___2___ ___4___ ___8___
VII-1
ANNEX VIII
A. Statistical Considerations
Details of the statistical analysis performed on each primary efficacy variable should be presented
in Appendix 16.1.9. Details reported should include at least the following information:
(a) The statistical model underlying the analysis. This should be presented precisely
and completely, using references if necessary.
(b) A statement of the clinical claim tested in precise statistical terms, e.g., in terms of
null and alternative hypotheses.
(c) The statistical methods applied to estimate effects, construct confidence intervals,
etc. Literature references should be included where appropriate.
(d) The assumptions underlying the statistical methods. It should be shown, insofar as
statistically reasonable, that the data satisfy crucial assumptions, especially when necessary
to confirm the validity of an inference. When extensive statistical analyses have been
performed by the applicant, it is essential to consider the extent to which the analyses were
planned prior to the availability of data and, if they were not, how bias was avoided in
choosing the particular analysis used as a basis for conclusions. This is particularly
important in the case of any subgroup analyses, because if such analyses are not
preplanned they will ordinarily not provide an adequate basis for definitive conclusions.
(i) In the event data transformation was performed, a rationale for the choice
of data transformation along with interpretation of the estimates of treatment
effects based on transformed data should be provided.
(e) The test statistic, the sampling distribution of the test statistic under the null
hypothesis, the value of the test statistic, significance level (i.e., p-value), and intermediate
summary data, in a format that enables the regulatory authority's statistical reviewer to
verify the results of the analysis quickly and easily. The p-values should be designated as
one or two tailed. The rationale for using a one-tailed test should be provided.
VIII-1
For example, the documentation of a two-sample t-test should consist of the value of the
t-statistic, the associated degrees of freedom, the p-value, the two sample sizes, mean and
variance for each of the samples, and the pooled estimate of variance. The documentation
of multicenter studies analyzed by analysis of variance techniques should include, at a
minimum, an analysis of variance table with terms for centers, treatments, their interaction,
error, and total. For crossover designs, the documentation should include information
regarding sequences, patients within sequences, baselines at the start of each period,
washouts and length of washouts, dropouts during each period, treatments, periods,
treatment by period interaction, error, and total. For each source of variation, aside from
the total, the table should contain the degrees of freedom, the sum of squares, the mean
square, the appropriate F-test, the p-value, and the expected mean square.
Intermediate summary data should display the demographic data and response data,
averaged or otherwise summarized, for each center-by-treatment combination (or other
design characteristic such as sequence) at each observation time.
In the report of each controlled clinical study, there should be data listings (tabulations) of patient
data utilized by the sponsor for statistical analyses and tables supporting conclusions and major
findings. These data listings are necessary for the regulatory authority's statistical review, and the
sponsor may be asked to supply these patient data listings in a computer-readable form.
VIII-2
Part 3
Submissions
SECTION 4
esub@cder.fda.gov
Overview
• Available Guidances
– Traditional Electronic Submissions
– Electronic Submissions using eCTD
Specifications
• eCTD Guidance
– Changes from eNDA Guidance
– Continuation of eNDA Guidance
• Submissions 101 References
esub@cder.fda.gov
Electronic Submission Guidances
Traditional Electronic Submission
esub@cder.fda.gov
Electronic Submission Guidances
Using eCTD Specifications
esub@cder.fda.gov
Electronic Submissions Using eCTD
Specifications
• Guidance Published August, 2003
• eCTD Specifications
– FDA eCTD Table of Contents Headings and Hierarchy
– FDA Module 1 Specification
– FDA Modules 2 to 5 Specification
– Study Tagging File Specification
• Specifications Available On-Line
http://www.fda.gov/cder/regulatory/ersr/default.htm
• Current eNDA/eANDA Guidances remain available
as an alternative to the eCTD
esub@cder.fda.gov
eCTD Changes
esub@cder.fda.gov
What doesn’t change
esub@cder.fda.gov
Implementing the Guidance
esub@cder.fda.gov
Submissions 101
esub@cder.fda.gov
Just say no…
esub@cder.fda.gov
SECTION 5
and/or
April 2006
Electronic Submissions
Revision 1
Contains Nonbinding Recommendations
TABLE OF CONTENTS
I. INTRODUCTION............................................................................................................. 1
II. GENERAL ISSUES .......................................................................................................... 2
A. Scope ............................................................................................................................................... 2
B. Guidance on the Content of Applications and Related Submissions ........................................ 2
C. ICH eCTD Specification................................................................................................................ 3
D. Document Granularity and Table of Contents Headings........................................................... 3
E. Electronic Submissions.................................................................................................................. 4
F. Document Information for Previous Submissions ...................................................................... 4
G. Referencing Previously Submitted Documents ........................................................................... 5
H. Refuse to File .................................................................................................................................. 5
I. Submission of Paper Copies.......................................................................................................... 6
J. Scanned Documents ....................................................................................................................... 6
K. The FDA District Office Copy ...................................................................................................... 6
L. Electronic Signatures..................................................................................................................... 6
M. Number of Copies of Electronic Files........................................................................................... 6
N. Naming Electronic Files ................................................................................................................ 6
O. Naming Folders .............................................................................................................................. 7
P. File Formats.................................................................................................................................... 7
Q. PDF Bookmarks and Hypertext Links......................................................................................... 8
R. Sending Electronic Submissions ................................................................................................... 8
S. Technical Problems or Questions ................................................................................................. 8
III. ORGANIZING THE MAIN SUBMISSION FOLDER................................................. 8
A. Module 1 Administrative Information and Prescribing Information Folder........................... 9
1. eCTD backbone document information files.................................................................................... 9
2. Cover letter (optional) ..................................................................................................................... 9
3. Labeling ......................................................................................................................................... 10
4. Advertisements and promotional material..................................................................................... 10
5. Marketing annual reports .............................................................................................................. 11
6. Information amendments ............................................................................................................... 11
B. Module 2 Summary Folder ......................................................................................................... 11
C. Module 3 Quality Folder ............................................................................................................. 12
D. Module 4 Safety Folder ............................................................................................................... 12
1. Study reports .................................................................................................................................. 12
2. Literature references...................................................................................................................... 13
3. Datasets ......................................................................................................................................... 13
i
Contains Nonbinding Recommendations
Technical specifications associated with this guidance will be provided as stand alone documents. They
will be updated periodically. To ensure that you have the most recent versions, check the appropriate
center's guidance Web page. For CBER, this Web site is http://www.fda.gov/cber/esub/esub.htm. For
CDER, this Web site is http://www.fda.gov/cder/regulatory/ersr/ectd.htm.
ii
Contains Nonbinding Recommendations
This guidance represents the Food and Drug Administration's (FDA's) current thinking on this topic. It
does not create or confer any rights for or on any person and does not operate to bind FDA or the public.
An alternative approach may be used if such approach satisfies the requirements of the applicable statutes
and regulations. If you want to discuss an alternative approach, contact the FDA staff responsible for
implementing this guidance. If you cannot identify the appropriate FDA staff, call the appropriate
number listed on the title page of this guidance.
I. INTRODUCTION
This is one in a series of guidance documents intended to assist applicants making regulatory
submissions to the FDA in electronic format using the electronic common technical document
(eCTD) specifications. This guidance discusses issues related to the electronic submission of
applications for human pharmaceutical products2 and related submissions, including abbreviated
new drug applications (ANDAs), biologics license applications (BLAs), investigational new drug
applications (INDs), new drug application (NDAs), master files (e.g., drug master files),
advertising material, and promotional labeling.3 At this time, this does not include applications
supporting combination products.
We have revised this guidance, which was first published in October 2005, to correct the names
of the eCTD backbone and U.S. Regional backbone files referenced in section IV.A.
1
This guidance has been developed by the Center for Drug Evaluation and Research (CDER) and the Center for
Biologics Evaluation and Research (CBER).
2
Human pharmaceutical products include those products that meet the definition of drug under the Food, Drug and
Cosmetic Act, including those that are chemically synthesized and those derived from living sources (biologic
products).
3
Agency guidance documents on electronic submissions will be updated regularly to reflect the evolving nature of
the technology and the experience of those using this technology.
Paperwork Reduction Act of 1995: This guidance contains information collection provisions that are subject to
review by the Office of Management and Budget (OMB) under the Paperwork Reduction Act of 1995 (44 U.S.C.
3501-3520). The collections of information in this guidance have been approved under OMB Control Nos. 0910-
0014, 0910-0001, and 0910-0338.
1
Contains Nonbinding Recommendations
The goals of the guidance are to enhance the receipt, processing, and review of electronic
submissions to the FDA. Specifically, this guidance makes recommendations regarding the use
of the eCTD backbone files developed through the International Conference on Harmonisation
(ICH) to facilitate efficient submission handling. In addition, the guidance provides more
specificity than in previous guidances for electronic submissions with regard to the organization
of individual submissions. Finally, the guidance harmonizes the organization and formatting of
electronic submissions for multiple submission types.
This guidance refers to a series of technical specifications associated with the guidance. They
are being provided as stand alone documents to make them more accessible to the user. The
associated specifications will be updated periodically. To ensure that you have the most
recent versions, check the appropriate center's guidance Web page.
FDA's guidance documents, including this guidance, do not establish legally enforceable
responsibilities. Instead, guidances describe the Agency's current thinking on a topic and should
be viewed only as recommendations, unless specific regulatory or statutory requirements are
cited. The use of the word should in Agency guidances means that something is suggested or
recommended, but not required.
This portion of the guidance makes recommendations on general organizational issues related to
the electronic submission of applications for human pharmaceutical products using the cCTD
specifications. The requirements for the content of such applications are described in our
regulations in chapter 21 of the Code of Federal Regulations (CFR). Additional
recommendations on the contents of applications are provided in Agency guidances, which are
available on the Agency Web page.
A. Scope
This document provides general guidance on how to organize application information for
electronic submission to the Agency using the eCTD specifications. Guidance on the information
to be included in the technical sections of applications and submissions is described in a series of
guidance documents based on the International Conference on Harmonisation of Technical
Requirements for Registration of Pharmaceuticals for Human Use (ICH) common technical
2
Contains Nonbinding Recommendations
document (CTD): M4: Organization of the CTD, M4Q: The CTD – Quality; M4S – The CTD
Safety; and M4E: The CTD – Efficacy.
The recommendations made here on how to organize application information are based on the
ICH CTD and the electronic CTD (eCTD), which was developed by the ICH M2 expert working
group. Although the CTD and the eCTD were designed for marketing applications, they could
apply equally to other submission types, including INDs, master files, advertising material, and
promotional labeling.4 Details on the specification for the ICH eCTD can be found in the
guidance document M2 eCTD: Electronic Common Technical Document Specification.
A table of contents is defined by headings arranged in a hierarchical fashion. See the associated
specification, Comprehensive Table of Contents Headings and Hierarchy for the comprehensive
listing of headings and hierarchy Because this is a comprehensive listing, not all headings are
applicable to all submissions or submission types. All of the information you need to submit is
covered by these headings. If you think other headings are needed, you should contact our
electronic submission coordinators prior to using any other headings (see section II.S of this
guidance). Reviewers will not be able to access documents associated with headings not listed
in the “Comprehensive Table of Contents Headings and Hierarchy.”
Unless otherwise specified, documents should be organized so that the subject matter of the
document is specifically associated with the lowest heading in the table of contents hierarchy.
For example, if you look at the associated document “Comprehensive Table of Contents
Headings and Hierarchy,” the headings “Meeting request” and “Meeting background material”
are the lowest headings in the “Meeting” hierarchy. Therefore, the meeting request and meeting
background material would be in two separate documents — the meeting request in one
document and the meeting background material in another document.
A document can be associated with more than one heading. However, the actual electronic file
would only be provided once. The eCTD specifications provide details on how to refer to an
electronic file.
4
Advertising and promotional labeling provided with marketing applications.
5
Some documents are provided in more than one file because a file containing everything would be too large. See
specifications for the size limitations for a file.
3
Contains Nonbinding Recommendations
E. Electronic Submissions
Under our regulations (21 CFR 11.2(b)(2)), applicants and sponsors are expected to contact us
for details on how to proceed with electronic submissions. These details are usually provided in
guidance documents. For example, we are already receiving marketing application submissions
for human pharmaceutical products in electronic format based on details provided in the
guidances for industry Providing Regulatory Submissions in Electronic Format – NDAs,
Providing Regulatory Submissions in Electronic Format – ANDAs, Providing Regulatory
Submissions to the Center for Biologics Evaluation and Research (CBER) in Electronic Format
– Biologics Marketing Applications, and Providing Regulatory Submissions in Electronic
Format – General Considerations.6 However, we recommend that you begin submitting eCTD
backbone files as described in this guidance because we believe that having the information in
the eCTD backbone files will result in greater efficiency in the future. In time, the other
guidances may be withdrawn because they may no longer be needed.
When we are ready to receive a particular submission type in electronic format only, we usually
identify it in public docket 92S-0251. Under 21 CFR part 11, you then have the option of
providing that submission type in electronic format according to FDA guidance so that the
Agency may adequately process, archive, and review the files.
Once you begin to submit a specific application in electronic format based on this guidance,
subsequent submissions to the application, including amendments and supplements, should
include eCTD backbone files. Without the eCTD backbone files, we will not be able to
adequately manage, process, archive, or review the submissions. If you choose to submit an
original application using the eCTD backbone files, you should obtain an application number in
advance by contacting the appropriate center. You may obtain the number at any time and the
numbers will not be reused.
We believe it is most beneficial to begin your eCTD-based submissions with the initial
submission of an application. Contact the appropriate center first if you wish to make eCTD-
based submissions to pending applications. You should avoid the submission of any paper
documents when you follow the recommendations in this document. The maximum benefit will
be derived once an application is in electronic format. This is particularly true for the IND,
where submissions are provided over a long period of time. You should submit the electronic
information for all files in the eCTD backbone files following the specifications associated with
this guidance.
If you decide to submit a specific application in electronic format based on this guidance, you do
not have to provide eCTD backbone files for the previous submissions to the application. For
example, if you submitted an original application in 2001 and now submit an amendment to the
application using the eCTD backbone files, you do not have to go back and submit the document
information for the files submitted in 2001.
6
This includes mixed electronic and paper submissions.
4
Contains Nonbinding Recommendations
If a document was submitted in electronic format with the eCTD backbone files, you should not
submit additional copies when referencing the previously submitted document. Instead, you
should include the information by reference by providing in the text of the document (1) the
application or master file number, (2) the date of submission (e.g., letter date), (3) the document
name, and (4) the page number of the referenced document along with a hypertext link to the
location of the information (see section II.Q of this guidance). If a document replaces or appends
a document previously submitted with an eCTD backbone file, then you should include this
information in the appropriate eCTD backbone file. The details on how to include this
information in the eCTD backbone file are provided in the associated specifications for eCTD
backbone files.
If a document was previously submitted in either paper or electronic format without the proper
eCTD backbone files, you should reference the document as with any paper submission. In the
text of the document, you should include (1) the application or master file number, (2) the date of
submission (e.g., letter date), (3) the document name, (4) the page number, and (5) the
submission identification (e.g., submission serial number, volume number, electronic folder, and
file name) of the referenced document. In such cases, providing an electronic copy of the
previously submitted documents can increase the utility of the submission. These documents,
like all documents in the submission, should be appropriately described in the eCTD backbone
files. These files are considered new in the eCTD backbone files.
When referring to documents that are part of other applications, please remember to include the
appropriate letters of authorization with the submission (e.g., 21 CFR 314.420(d)).
H. Refuse to File
We may refuse to file an application or supplement under our regulations (e.g., 21 CFR 314.101
and 601.2) if the submission is illegible, uninterpretable, or otherwise clearly inadequate,
including having incompatible formats or inadequate organization. These regulations apply to
both paper and electronic submissions. The absence of electronic datasets in an acceptable
format to permit review and analysis may be considered inadequate, resulting in a refuse-to-file
decision.8 Following the recommendations in this guidance document will help ensure that your
electronic application meets the requirements of FDA regulations and can be archived,
processed, and reviewed within specified time frames using our tools.
7
Previously submitted documents include previously submitted information by reference for master files, market
applications, and investigational applications discussed under 21 CFR 312.23(a)(11)(b), 314.50(g)(1), 314.420(b),
and 601.51(a).
8
See more on this in CBER's SOPP 8404.
5
Contains Nonbinding Recommendations
When providing applications in electronic format using the eCTD backbone files, paper copies of
the application, including review copies and desk copies, are not required and should not be sent.
J. Scanned Documents
Scanned documents submitted electronically as images are not as useful for review as documents
that are text based. Image-based documents are more difficult to read and cannot be
electronically searched. It takes longer to print image-based documents, and they occupy more
storage space than text-based documents. For these reasons, we strongly urge that you provide
text-based documents, rather than image files, whenever possible. We understand that certain
documents may only be available as image files. Handwritten documents and documents that
were generated independent from the company, such as journal publications, may be available
only in paper. Documents that may only be available in paper can be scanned and submitted in
electronic format as image-based files. However, we expect documents such as study reports
recently generated by the company or recently generated as the result of the company's request to
be available as text-based documents. We understand that legacy study reports, those generated
years ago, may only be available in paper. For these reports, especially those for pivotal studies,
you may want to consider converting these documents from image files to text-based files.
Optical Character Recognition that has been validated is an option.
FDA District offices have access to documents submitted in electronic format. Therefore, when
sending submissions in electronic format, you need not provide any documentation to the FDA
Office of Regulatory Affairs District Office.
L. Electronic Signatures
Documents required by regulations to be submitted with an original signature (e.g., FDA form
356h, FDA form 1571) should be submitted with electronic signatures that follow the controls
described under 21 CFR part 11.
You should send a single copy of the electronic portions of a submission to the appropriate
central document room facility. Copies should not be sent directly to the reviewer or review
division. Electronic documents that bypass the controls for electronic files described in 21 CFR
11 are not considered official documents for review.
To function properly, the eCTD backbone files must have specific names (e.g., index.xml,
us-regional.xml). For other files without a specified name, you should provide a name that is
indicative of the contents (e.g., protocol-101). The file name should allow a reviewer to infer
6
Contains Nonbinding Recommendations
some concept of the file's contents relative to other files. The file name should be less than or
equal to 64 characters including the appropriate file extension. You should use only letters
(lower case), numbers, or hyphens in the name. You should not use blank spaces. When naming
files, it is important to remember that — to avoid truncation — the length of the entire path of
the file should not exceed 230 characters.
O. Naming Folders
The terms folder and subfolder are used in this guidance and are intended to be synonymous with
directory and subdirectory. The main submission, regional administrative folders, and certain
subfolders should have specific names for proper and efficient processing of the submission.
Recommendations regarding naming the main submission folders and regional administrative
folders can be found in section III, below. Other specific folder names can be found in the
specifications associated with this guidance. You can use only letters (lower case), numbers, or
hyphens in the name. You should not use blank spaces. The length of the folder name should not
exceed 64 characters. When naming folders, it is important to remember that the length of the
entire path should not exceed 230 characters. You should not include empty folders in the
submission.
P. File Formats
We recommend that you send electronic documents in the file formats specified in this guidance.
We will not be able to manage, process, archive, or review documents provided in other file
formats.
In the future, we may consider other electronic file formats for use with electronic submissions,
or we may consider the use of the current formats with other electronic submissions. We intend
to publish guidance to advise on the use of file formats for specific types of submissions for use
in the future.
7
Contains Nonbinding Recommendations
For documents with a table of contents, provide bookmarks and hypertext links for each item
listed in the table of contents including tables, figures, publications, references, and associated
appendices. These bookmarks and hypertext links are essential for efficient navigation through
documents. You should make the bookmark hierarchy identical to the table of contents.
Navigation efficiency is also improved by providing hypertext links throughout the body of the
document to supporting annotations, related sections, references, appendices, tables, or figures
that are not located on the same page.
It is possible to link to other documents in a submission using relative paths when creating
hypertext linking. Absolute links that reference specific drives and root directories are not
functional once the submission is loaded onto the document repository. For example, the link
path ../../../123456/0001/.. will work, but the link c:\123456\0001\… will not work. However,
you should keep in mind that some documents may be subsequently replaced or appended,
possibly rendering the link obsolete, so linking should be used cautiously.
When creating bookmarks and hypertext links, choose the magnification setting Inherit Zoom so
that the destination page displays at the same magnification level that the reviewer is using for
the rest of the document.
All submissions provided in electronic format must be sent to the appropriate central document
room facility for processing to maintain the integrity of the submission as required under 21 CFR
part 11. Electronic documents sent directly to division document rooms or to reviewers bypass
the controls established for the receipt and archiving of documents and are not considered
official documents for review. See the associated specifications for more information, including
electronic transmission.
If you have any questions on technical issues related to providing electronic submissions
according to the recommendations in this guidance, contact the electronic submission
coordinator at esub@cder.fda.gov. Specific technical issues related to submissions to CBER
should be sent to esubprep@cber.fda.gov. Specific questions pertaining to content should be
directed to the appropriate review division or office.
All documents in the electronic submission should be placed in a main submission folder using a
four-digit sequence number for the application with the original submission for an application
designated 0000. You should assign numbers for each submission to the same application with
consecutive numbers. For example, the folder for the 3rd submission to an application, whether it
8
Contains Nonbinding Recommendations
We recommend that you use subfolders to organize files in a submission, including for each
module m1, m2, m3, m4, and m5, respectively. There is a subfolder util to organize eCTD
technical files in the submission. Place these subfolders in the sequence number folder (e.g.,
folder named 0000 for the initial submission to an application). Do not include empty subfolders.
The following sections provide guidance for organizing the folders and files in the m1, m2, m3,
m4, m5, and util folders. In addition, you can find instructions on preparing the submission of an
electronic application to CBER at http://www.fda.gov/cber/esub/esub.htm.
Module 1 contains administrative and labeling documents. The organization of the documents in
module 1 is the same for all applications and related submissions. The subject matter for each
document should be assigned to the lowest level of the hierarchy outlined in the associated
document “Comprehensive Table of Contents Headings and Hierarchy.” Note that some
headings apply only to specific applications or specific submissions. You should create a folder
named us and place it in the folder named m1. The documents for module 1 should be placed in
the us folder including the us-regional.xml file pertaining to the eCTD backbone files for module
1. Below are some additional details on providing specific types of documents.
The details on creating this file are in the associated document “eCTD Backbone Files
Specification for Module 1.”
If you decide to include a cover letter, we recommend you include the following information:
9
Contains Nonbinding Recommendations
3. Labeling
a. Labeling history
You can provide a history summarizing labeling changes as a single PDF file. The
following information will help us confirm changes made to the labeling:
b. Content of labeling
c. Labeling samples
Each labeling sample (e.g., carton labels, container labels, package inserts) should
be provided as individual PDF files. The samples should (1) include all panels, if
applicable; (2) be provided in their actual size; and (3) reflect the actual color
proposed for use.
Each promotional piece should be provided as an individual PDF file. In cases when
promotional writing or images cover more than one page (e.g., a brochure spread), the reviewer
should be able to view the entire layout at one time. For three-dimensional objects, you should
provide a digital image of the object in sufficient detail to allow us to review the promotional
10
Contains Nonbinding Recommendations
material. In addition, you should provide information adequate to determine the size of the object
(e.g., point size, dimensions). A dimensional piece shown flat, such as a flattened carton, can
also be submitted.
If you choose to include cover letters with your submissions of advertising and promotional
material, they should be provided as individual PDF files and indicate for the reviewer any
additional important information, such as which materials need priority reviews.
If references are provided, each reference should be submitted as an individual PDF file and
placed in the appropriate module based on subject matter. If possible, you should highlight the
sections of the full reference that you refer to in the promotional materials. When a reference is
used to support a claim in proposed promotional materials voluntarily submitted for advisory
opinion or Agency comment, you should provide a hypertext link to the page of the reference or
labeling that contains the supporting information.
For promotional materials submitted as part of the postmarketing reporting requirements, you
may choose to provide hypertext links to references or labeling. References improve the
efficiency of a review.
In the postmarketing study commitments files, you should include a bookmark for each study
described.
6. Information amendments
You should include documents that are provided in information amendments in the appropriate
module using the appropriate headings to describe the subject matter. In the unusual case when
information amendments do not fit appropriately under any heading in the CTD, you should
place the documents in module 1 under the heading “information amendment: Information not
covered under modules 2 to 5.” You should provide a separate PDF file for each subject
covered. Documents that apply to more than one module should be placed under the heading
“Multiple module information amendments.”
You should place the documents for module 2 in the m2 folder. The subject matter for each
document should be specific for the lowest level of the hierarchy outlined in the associated
document “Comprehensive Table of Contents Headings and Hierarchy.” Each document should
be provided as an individual PDF file. The subfolders described in the M2 eCTD: Electronic
Common Technical Document Specification are not necessary for the review of the submission.
If you choose to use the additional subfolder, we will maintain the subfolder structure so links
will function properly.
11
Contains Nonbinding Recommendations
The organization of the module 3 folder is the same for all applications and related submissions.
You should place the documents for module 3 in the m3 folder. The subject matter for each
document should be specific for the lowest level of the hierarchy outlined in the associated
document “Comprehensive Table of Contents Headings and Hierarchy.” Each document should
be provided as an individual PDF file. The subfolders described in the M2 eCTD: Electronic
Common Technical Document Specification are not necessary for the review of the submission.
If you choose to use the additional subfolder, we will maintain the subfolder structure used so
links will function properly.
You should provide the files pertaining to Key Literature References (CTD section 3.3) as
individual PDF files. The filenames should be short and meaningful.
The organization of the module 4 folder is the same for all applications and related submissions.
You should place the documents for module 4 in the m4 folder. The subject matter for each
document should be specific for the lowest level of the hierarchy outlined in the associated
document “Comprehensive Table of Contents Headings and Hierarchy.” The headings for study
reports should also be specific for the lowest level of the hierarchy. Each document should be
provided as an individual PDF file. The subfolders described in the M2 eCTD: Electronic
Common Technical Document Specification are not necessary for the review of the submission.
If you choose to use the additional subfolder, we will maintain the subfolder structure so links
will function properly.
1. Study reports
Typically, a single document should be provided for each study report included in this module.
However, if you provide the study reports as multiple documents, you should confine the subject
matter of each document to a single item in the following list.
• Synopsis
• Study report body
• Protocol and amendments
• Signatures of principal or coordinating investigator(s)
• Audit certificates and reports
• Documentation of statistical methods and interim analysis plans
• Documentation of interlaboratory standardization methods of quality assurance
procedures if used
• Publications based on the study
• Important publications referenced in the report
• Compliance and/or drug concentration data
• Individual subject data listings
— Data tabulations
- Data tabulations datasets
12
Contains Nonbinding Recommendations
- Data definitions
— Data listing
- Data listing datasets
- Data definitions
— Analysis datasets
- Analysis datasets
- Analysis programs
- Data definitions
— IND safety reports
In the following examples, you should provide the study reports as separate documents
When providing a study report, you should include the study tagging file (STF) described in the
associated document “The eCTD Backbone File Specifcation for Study Tagging Files.”
2. Literature references
You should provide each literature reference as an individual PDF file. The filenames should be
short and meaningful.
3. Datasets
See the associated document “Study Data Specifications” for details on providing datasets and
related files (e.g., data definition file, program files)
The organization of the module 5 folder is the same for all applications and related submissions.
You should place the documents for module 5 in the m5 folder. The subject matter for each
document should be specific for the lowest level of the hierarchy outlined in the associated
document “Comprehensive Table of Contents Headings and Hierarchy.” One exception is that
legacy study reports can be provided as a single document. Each document should be provided as
an individual PDF file. The subfolders described in the guidance M2 eCTD: Electronic Common
Technical Document Specification are not necessary for the review of the submission. If you
13
Contains Nonbinding Recommendations
choose to use the additional subfolder, we will maintain the subfolder structure so links will
function properly.
You should provide the tabular listing of all clinical studies as a single PDF file.
2. Study reports
Typically, clinical study reports are provided as more than one document based on the ICH E3
guidance document when providing a study.9 In addition, if you have provided a document in a
previous submission (e.g., protocol), you should provide a reference to the protocol rather than
resubmitting the protocol. In cases when a legacy report has already been prepared as a single
electronic document, you can provide the entire study report, other than the case report forms
(CRFs) and individual data listings, as a single document. The individual documents that should
be included in a study report are listed below:
• Synopsis10 (E3 2)
• Study report (E3 1, 3 to 15)
• Protocol and amendments (E3 16.1.1)
• Sample case report forms (E3 16.1.2)
• List of IECs or IRBs (E3 16.1.3) and consent forms
• List and description of investigators (E3 16.1.4) and sites
• Signatures of principal or coordinating investigator(s) or sponsor’s responsible
medical officer (E3 16.1.5)
• Listing of patients receiving test drug(s) from specified batch (E3 16.1.6)
• Randomizations scheme (E3 16.1.7)
• Audit certificates (E3 16.1.8) and reports
• Documentation of statistical methods (E3 16.1.9) and interim analysis plans
• Documentation of interlaboratory standardization methods of quality assurance
procedures if used (E3 16.1.10)
• Publications based on the study (E3 16.1.11)
• Important publications referenced in the report (E3 16.1.12)
• Discontinued patients (E3 16.2.1)
• Protocol deviations (E3 16.2.2)
• Patients excluded from the efficacy studies (E3 16.2.3)
• Demographic data (E3 16.2.4)
• Compliance and/or drug concentration data (E3 16.2.5)
• Individual efficacy response data (E3 16.2.6)
• Adverse event listings (E3 16.2.7)
• Listing of individual laboratory measurements by patient (E3 16.2.8)
9
When providing a study report, you should include the study tagging file (STF) described in the associated
document “The eCTD Backbone File Specification for Study Tagging Files.”
10
The synopsis should be provided as a document separate from the study report.
14
Contains Nonbinding Recommendations
You should provide an individual subject’s complete CRF as a single PDF file. If a paper CRF
was used in the clinical trial, the electronic CRF should be a scanned image of the paper CRF
including all original entries with all modifications, addenda, corrections, comments,
annotations, and any extemporaneous additions. If electronic data capture was used in the
clinical trial, you should submit a PDF-generated form or other PDF representation of the
information (e.g., subject profile).
You should use the subject’s unique identifier as the title of the document and the file name.
These names are used to assist reviewers in finding the CRF for an individual subject. Each CRF
must have bookmarks as part of the comprehensive table of contents required under
21 CFR 314.50(b). We recommend bookmarks for each CRF domain and study visit to help the
reviewer navigate the CRFs. For addenda and corrections, making a hypertext link from the
amended item to the corrected page or addendum is a useful way to avoid confusion. Bookmarks
for these items should be displayed at the bottom of the hierarchy.
4. Datasets
See the associated document “Study Data Specifications” for details on providing datasets and
related files (e.g., data definition files, program files). For subject profiles, you should use the
subject’s unique identifier in the title of the document and the file name.
To facilitate electronic submissions, we have divided the postmarketing periodic adverse drug
experience report into three parts: (1) individual case safety reports (ICSRs), (2) ICSR
attachments, if applicable, and (3) descriptive information. The descriptive information includes
15
Contains Nonbinding Recommendations
the narrative summary and analysis of the information in the report (i.e., periodic ICSRs and
ICSR attachments), an analysis of the 15-day alert reports submitted during the reporting interval
(i.e., expedited ICSRs and ICSR attachments), and the history of actions taken since the last
report because of adverse drug experiences (e.g., labeling changes, studies initiated) as described
in 21 CFR 314.80(c)(2)(ii)(a) and (c) and 600.80(c)(2)(ii)(A) and (C)). You should supply the
descriptive information as an individual PDF file. You should provide bookmarks for each of the
sections and subsections of this report. ICSR and ICSR attachments should be provided as
described in the guidance for industry Providing Regulatory Submissions in Electronic Format
— Postmarketing Periodic Adverse Drug Experience Reports.
6. Literature references
You should provide each literature reference as an individual PDF file. The filenames should be
short and meaningful.
You should create two folders, dtd and style and place them in the util folder.
You should place the document type definition (DTD) that you used to create the eCTD
backbone file (index.xml), the DTD you used to create the FDA Regional eCTD backbone file
(us-regional.xml), and the DTD used for the STF in the folder named dtd. You should use the
most recent DTD.11
B. Style Folder
You should use the most recent stylesheet. See the guidance for industry M2 eCTD: Electronic
Common Technical Document Specification.
11
See the FDA Web site at http://www.fda.gov/cder/regulatory/ersr/.
16
Part 4
Technical Requirements
SECTION 6
1
Comprehensive Table of Contents Headings and Hierarchy
2
Comprehensive Table of Contents Headings and Hierarchy
3
Comprehensive Table of Contents Headings and Hierarchy
4
Comprehensive Table of Contents Headings and Hierarchy
5
Comprehensive Table of Contents Headings and Hierarchy
6
Comprehensive Table of Contents Headings and Hierarchy
7
Comprehensive Table of Contents Headings and Hierarchy
8
Comprehensive Table of Contents Headings and Hierarchy
9
Comprehensive Table of Contents Headings and Hierarchy
10
Comprehensive Table of Contents Headings and Hierarchy
11
Comprehensive Table of Contents Headings and Hierarchy
12
Comprehensive Table of Contents Headings and Hierarchy
13
Comprehensive Table of Contents Headings and Hierarchy
14
Comprehensive Table of Contents Headings and Hierarchy
15
Comprehensive Table of Contents Headings and Hierarchy
16
Comprehensive Table of Contents Headings and Hierarchy
contract research
organization.
17
Comprehensive Table of Contents Headings and Hierarchy
18
Comprehensive Table of Contents Headings and Hierarchy
to (iv) sections
314.50(d)(5)(v) An integrated summary 5 5.3.4 Reports of analysis of
of efficacy data from more than
one study [Use
appropriate sections in
integrated summary of
efficacy STF]
314.50(d)(5)(vi)( An integrated summary 5 5.3.4 Reports of analysis of
a) of safety data from more than
one study [Use
appropriate sections in
integrated summary of
safety STF]
314.50(d)(5)(vi)( Safety Update 5 5.3.5 Reports of analysis of
b) data from more than
one study [Use
appropriate sections in
integrated summary of
safety STF]
314.50(d)(5)(vii) Potential for abuse 5 5.3 Use appropriate
sections
314.50(d)(5)(viii An integrated summary 2 2.5 Use appropriate
) of the benefits and risks sections
314.50(d)(5)(ix) Statement of 5 5.3 *List of IECs or IRBs
compliance with and consent forms
informed consent [under specific study]
314.50(d)(5)(x) Transfer of obligations 1 1.3.1.4 Transfer of obligation
to CRO
314.50(d)(5)(xi) Audited studies 5 5.3 *Audit certificates and
reports [under specific
study]
314.50(d)(6)(i) Description of 5 5.3 *Documentation of
and (ii) statistical analysis statistical methods and
interim analysis plans
[under specific study]
314.50(d)(7) Pediatric use section 2 and 5 As needed Use appropriate
sections
314.50(e)(2)(i) Analytical methods 3 As needed Use appropriate
sections
314.50(e)(2)(ii) Copies of the labeling 1 1.14 Use appropriate
and all labeling for the sections
drug product
314.50(f)(1) Case report tabulations 5 5.3 *Case report
tabulations [use the
appropriate sections
under the specific
19
Comprehensive Table of Contents Headings and Hierarchy
study]
314.50(f)(2) Case report forms 5 5.3 *Case report forms
[under the appropriate
site and specific study]
314.50(g)(1) Written statement of 1 1.4.1 Letter of authorization
authorization for
references
314.50(g)(1) Reference to 1 1.4.4 Cross reference to other
information previously applications and
submitted by sponsor information previously
submitted in paper
314.50(g)(1) Statement of right of 1 1.4.2 Statement of right of
reference reference
314.50(h) Patent Information 1 1.3.5.1 Patent Information
314.53(b) (Form FDA 3542a and
FDA form 3542)
314.50(i) Patent certification 1 1.3.5.2 Patent certifications
314.52(b)
314.50(j) Claimed exclusivity 1 1.3.5.3 Exclusivity claim
314.50(k) Financial certification 1 1.3.4 Financial certification
and disclosure and disclosure
statement
PREA Pediatric studies: 1 1.9.1 Request for waiver of
waiver of pediatric pediatric studies
study requirements
PREA Pediatric studies: 1 1.9.2 Request for deferral of
deferrals of pediatric pediatric studies
study requirements
314.60 Amendment to an 3 As needed Use appropriate
unapproved sections
application: Chemistry
314.60 Amendment to an 1 1.11.1 Quality information
unapproved amendment (only for
application: Chemistry information not
(information not covered under Module
covered under Module 3)
3)
314.60 Amendment to an 4 As needed Use appropriate
unapproved sections
application: Toxicology
314.60 Amendment to an 1 1.11.2 Safety information
unapproved amendment (only for
application: Toxicology information not
(information not covered under Module
covered under Module 4)
4)
20
Comprehensive Table of Contents Headings and Hierarchy
21
Comprehensive Table of Contents Headings and Hierarchy
manufacturing and
controls
314.81(b)(2)(v) Annual Report: 4 As needed Use appropriate
Nonclinical laboratory sections
studies
314.81(b)(2)(vi) Annual Report: 5 As needed Use appropriate
Clinical data sections
314.81(b)(2)(vii) Annual Report: Status 1 1.13.12 Status report of
report of clinical and clinical and nonclinical
nonclinical toxicology toxicology
postmarketing study postmarketing study
commitments commitments
314.81(b)(2)(viii Status report of other 1 1.13.13 Status of other
) (chemistry, postmarketing study
manufacturing, commitments
controls) postmarketing
study commitments
314.81(b)(2)(ix) Annual Report: Log of 1 1.13.14 Log of outstanding
outstanding regulatory regulatory business
business
314.81(b)(3)(i) Advertising and 1 1.15 Promotional material
promotional labeling
314.81(b)(3)(i) Transmittal of 1 1.1.5 Advertisements and
Advertisements and promotional labeling
Promotional Labeling transmittal: FDA form
2253
314.90 Waivers 1 1.12.5 Request for a waiver
314.102 Communications: 1 1.6.1 Meeting request
Meetings
314.102 Communications: 1 1.6.2 Meeting background
Meetings materials
314.102 Communications: 1 1.6.3 Correspondence
Meetings regarding meetings
314.103(c) Scientific and medical 1 1.10.1 Request for dispute
disputes resolution
314.103(c) Scientific and medical 1 1.10.2 Correspondence related
disputes to dispute resolution
314.150(c) Request for withdrawal 1 1.5.7 Request for withdrawal
of approval of application approval
314.150(b) Withdrawal or 1 1.5.7 Other correspondence
suspension of approval regarding status of
by the FDA application or product
314.420(a) Drug master files 1, 2, 3, As Needed Use appropriate
4, 5 sections
314.420(b) Incorporating DMF 1 1.4.1 Letter of Authorization
information by
22
Comprehensive Table of Contents Headings and Hierarchy
reference
314.420(d) List of authorized 1 1.4.3 List of authorized
persons to incorporate persons to incorporate
by reference by reference
314.550 Subpart H: Promotional 1 1.15 Promotional material
materials
314.640 Subpart I: Promotional 1 1.15 Promotional material
materials
ANDA
CFR Citation/Source CTD /*STF Heading
NUMBER TITLE Module NUMBER TITLE
314.94(a)(1) Application form 1 1.2 Application form: FDA
form 356h
GDEA Debarment 1 1.3.3 Debarment
Certification Certification
314.94(a)(2) Table of Contents N/A N/A N/A
314.94(a)(3) Basis for abbreviated 1 1.11.11 Basis for submission
new drug application statement
submission
314.94(a)(4) Conditions for use 1 1.11.11 Basis for submission
statement
314.94(a)(5) Active ingredient 1 1.11.12 Comparison of generic
drug and reference
listed drug
314.94(a)(6) Route of 1 1.11.12 Comparison of generic
administration, dosage drug and reference
form and strength listed drug
314.94(a)(7) Bioequilvance 5 5.3 Use appropriate
sections
314.94(8)(i) Listed drug labeling 1 1.14.3.2 Approved labeling text
for listed drug
314.94(8)(ii) Copies of proposed 1 1.14 Use appropriate
labeling sections
314.94(8)(iii) Statement of proposed 1 1.14.3.1 Annotated comparison
labeling with listed drug
314.94(8)(iv) Comparison of 1 1.14.3.1 Annotated comparison
approved and proposed with listed drug
labeling
314.94(9) Chemistry, 3 As needed Use appropriate
manufacturing and sections
control
314.94(11) Reference to 1 1.4.4 Cross reference to other
information previously applications
submitted by sponsor
314.94(12) Patent certification 1 1.3.5.2 Patent certification
314.95 Notice of certification 1 1.3.5.3 Certification of non-
23
Comprehensive Table of Contents Headings and Hierarchy
24
SECTION 7
Conformance
Review Checklist
For NDAs
I. INTRODUCTION................................................................................................... 3
I. INTRODUCTION
II. GENERAL ISSUES
A. Refuse to File
B. The Archival Copy
If portions of the NDA archival copy are submitted in paper and electronic
format, the index (commonly referred to as the table of contents) for the
submission must include the location of the paper documents by volume number
and electronic files by file and folder name(s) so the index is comprehensive.
G. Review Aids
Provide all review aid files on floppy disks or CDROMs and secure them in a
standard binder marked clearly on the outside REVIEW AIDS – NOT FOR
ARCHIVE. Include the review aids in the appropriate technical section of the
review copy.
All documents and datasets for the electronic archival copy should be placed in a main
folder using the NDA number (e.g., N123456) as the folder name.
A. Folders
Inside the main folder, all of the documents and datasets should be organized by
the NDA items described on page 2 of FDA form 356h.
B. Cover Letter
You should provide a cover letter as a PDF file named cover.pdf inside the main
folder. The cover letter should include the following:
• Description of the submission including appropriate regulatory
information.
• Description of which portions of the submission are presented only
in paper, only in electronic format, or in both paper and electronic
format.
3
• Description of the electronic submission including the type and number of
electronic media used (e.g., three CDROMs), and the approximate size of the
submission (e.g., 2 gigabytes). Include the format used for DLT tapes.
• Statement that the submission is virus free with a description of the software
(name, version, and company) used to check the files for viruses.
• The points of contact for the application.
C. 356h Form
You should provide FDA form 356h as a PDF file named 356h.pdf inside the main
folder. On page 2 of the form, you should note next to each item if the documents for the
item are in paper format, electronic format, or both paper and electronic format.
4
772
The first level of detail simply lists the items in the NDA as shown on page 2 of FDA
form 356h. This level of the comprehensive table of contents should be a single page and
should be provided as a single PDF file. The file containing the table of contents for the
original NDA should be named ndatoc.pdf. The file containing the table of contents for
an amendment should be named amendtoc.pdf. The file containing the table of contents
for a supplement should be named suppltoc.pdf.
The second level of detail contains the table of contents for each item (e.g., labeling, CMC,
CRTs; see specific item for details). Provide the appropriate bookmarks and hyperlinks for
each document or dataset listed to the appropriate file.
The third level of detail is the table of contents for each document or dataset. For each
document, provide bookmarks for each entry in the document's table of contents to the
appropriate location. For datasets, provide a data definition table as a key to the elements
being used in the datasets.
A hypertext link should be provided from the first-level table of contents to the
corresponding tables of contents for each item. These links are essential for establishing
a comprehensive table of contents for the electronic submission.
Some items, such as item 3 (the submission summary) and items 13 to 18, are single
documents and do not have their own table of contents. In such cases, the hypertext link
from the first level table of contents should go directly to the document.
5
Example: Table Of Contents For NDA 123456 (n/a = not available)
Item Description Paper archive copy Electronic archive
volume number copy folder
1 Table of contents (Index) 1 main folder
2 Labeling n/a Labeling
3 Summary n/a Summary
4 Chemistry 1-4 n/a
5 Nonclinical pharmacology and 5-10 Pharmtox
toxicology
6 Human pharmacokinetics and n/a Hpbio
bioavailability/bioequivalence
7 Clinical microbiology n/a Micro
8 Clinical n/a Clinstat
9 Safety update report n/a n/a
10 Statistical n/a Clinstat
11 Case report tabulations n/a Crt
12 Case report forms n/a Crf
13 Patent information n/a Other
14 Patent certification 1 Other
15 Establishment description n/a n/a
16 Debarment certification 1 Other
17 Field copy certification 1 Other
18 User fee cover sheet 1 Other
19 Other n/a Other
B. Item 2: Labeling
1. Folder
You should place all documents for this item in a single folder named labeling.
2. Table of contents
3. Labeling history
4. Labeling text
Document Information fields should contain the following information: (use only
lower case letters).
6
• Title: brand name
• Subject: generic name
• Author: applicant, applicant's label code
• Keywords: NDA number (in form of 123456), approval status (draft,
approved, cbe for changes being effected or annual for annual report),
date of labeling in the form of ddmmmyyyy. For draft, changes being
effected, and annual report changes, use the date of submission. For
approved labeling, use the date of approval.
An example of the Document Information field for draft labeling text is provided
below. Each item of the keyword field should be separated by a comma.
5. Package insert
6. Carton labeling
7. Container labeling
8. Other
C. Item 3: Summary
1. Folder
2. Table of contents
3. Summary document
4. Bookmarks and hypertext linking
D. Item 4: Chemistry, Manufacturing, and Control (CMC)
1. Folders
2. Table of contents
You must provide a table of contents listing all files provided in the CMC item as
a PDF file named cmctoc.pdf. This table of contents is considered part of the
comprehensive table of contents required in 314.50(b).
7
3. Drug substance
4. Drug product
5. Investigational formulations
6. Environmental assessment
7. Methods validation
8. Batch records
9. Publications
10. Bookmarks and hypertext links
For all documents with a table of contents, you must provide bookmarks for each
item in the document’s table of contents including all tables, figures, publications,
and appendices. These bookmarks serve as part of the comprehensive table of
contents for the submission and, therefore, are required under 314.50(b).
11. Full text index
An index of the full text and the Document Information fields of all documents in
this section should be provided. Name the index definition file cmcindex.pdx.
Place all associated index files in a folder named cmcindex. Place the
cmcindex.pdx definition file and the cmcindex subfolder in the main cmc folder.
Associate the cmctoc.pdf file with the index file so that whenever the table of
contents file is opened, the associated index is automatically added to the
available index list.
2. Table of contents
You must provide a table of contents listing all study reports (including study
report numbers), publications, and the summary provided in the pharmtox section
as a PDF file named pharmtoc.pdf. If datasets are provided for a study, you
should note this in the table of contents. This table of contents is considered part
of the comprehensive table of contents required in 314.50(b).
3. Summary document
4. Study reports
8
Because files 50 MB or larger are technically more difficult to handle, study
reports that are larger than 50 MB should be divided into two PDF files with the
individual animal line listings for the study provided as a separate file.
5. Publications
6. Bookmarks and hypertext links
For all documents with a table of contents, you must provide bookmarks for each
item in the document’s table of contents including all tables, figures, publication,
and appendices including datasets, if applicable. If datasets are provided with the
study, you should include a bookmark to the appropriate data definition file
(define.pdf). These bookmarks and hypertext links serve as part of the
comprehensive table of contents for the submission and, therefore, are required
under 314.50(b).
7. Full text index
8. Animal line listings as datasets
a. Format of the datasets
You should provide each dataset as a SAS transport file. Dataset files should be
organized so their size is less than 25 MB per file. The files should not be
compressed. Each dataset should be saved as an individual file.
b. Organization of data
All datasets for an individual study should be placed in a folder identified by the
study name and all these dataset folders placed in a single folder called datasets.
The datasets folder should be placed in the pharmtox folder.
c. Documentation of the datasets
d. Dataset table of contents
e. General considerations for datasets
F. Item 6: Human Pharmacology and Bioavailability/Bioequivalence
1. Folders
2. Table of contents
You must provide a table of contents listing all study reports (including study report
numbers), publications, and the summaries provided for the hpbio section as a PDF file
named hpbiotoc.pdf and place it in the hpbio folder. If datasets are provided for a study,
you should note this in the table of contents. This table of contents is considered part of
the comprehensive table of contents required in 314.50(b
3. Summary
9
4. Study reports
5. Datasets
6. Publications
7. Bookmarks and hypertext links
For all documents with a table of contents, you must provide bookmarks for each
item in the document’s table of contents including all tables, figures, publications,
and appendices including datasets, if applicable. These bookmarks serve as part
of the comprehensive table of contents for the submission and, therefore, are
required under 314.50(b). If datasets are provided with the study, you should
include a bookmark to the appropriate data definition file (define.pdf).
8. Full text index
G. Item 7: Clinical Microbiology
1. Folders
2. Table of contents
You must provide a table of contents listing all reports and publications for this
section as a PDF file named microtoc.pdf. If datasets are provided for a study,
you should note this in the table of contents. Place this file in the micro folder.
This table of contents is considered part of the comprehensive table of contents
(314.50(b)).
3. Summary document
4. Study reports
5. Datasets
6. Publications
7. Bookmarks and hypertext links
As part of a comprehensive table of contents for the submission, you must provide
bookmarks for each item in the document’s table of contents including all tables,
figures, and appendices including datasets, if applicable (314.125(b)). If datasets
are provided with a report, you should include a bookmark to the appropriate data
definition file (define.pdf).
8. Full text index:
H. Item 8: Clinical
1. Folders
10
778
2. Table of contents
You must provide a table of contents listing all files in this section. Provide the
table of contents as a PDF file; name this file clintoc.pdf and place it in the
clinstat folder. We consider the table of contents to be part of the comprehensive
table of contents (314.50(b)).
3. Study reports
Because files 50 MB or larger are technically more difficult to handle, study
reports that are larger than 50 MB should be divided into two PDF files.
4. Integrated summaries
5. Publications
6. Bookmarks and hypertext links
For all documents with a table of contents, you must provide bookmarks for each
item in the document’s table of contents including all tables, figures, publications,
and appendices including datasets. For datasets, you should include a bookmark
to the appropriate data definition file (define.pdf). These bookmarks serve as part
of the comprehensive table of contents for the submission and, therefore, are
required under 314.50(b).
7. Full text index
I. Item 9: Safety Update
1. Folders
All documents for this section should be placed in a single folder named update
and a single PDF file provided for each document.
2. Table of contents
A table of contents for all files in this section must be provided in the form of a
PDF file as part of the comprehensive table of contents (314.125(b)). The
organization of the table of contents should follow the guidance provided in item
8. Name the PDF file updattoc.pdf and place it in the update folder.
3. Full text index
J. Item 10: Statistical For electronic submissions, item 8 and item 10 are identical.
K. Item 11: Case Report Tabulations (CRTs)
CRTs are item 11 on page 2 of FDA form 356h.
You should provide CRTs in datasets allowing the reviewers to use their own software
for analysis. Each dataset is a single file and, in general, includes a combination of raw
and derived data.
11
In addition to electronic datasets, study data collected for individual patients, organized
by time, can be provided in PDF files. We call this collection of data a patient profile,
and it serves as an adjunct to the electronic datasets. Patient profiles are not meant to be
a replacement for electronic datasets.
1. Format of the datasets
You should provide each dataset as a SAS transport file as described in the
companion guidance, Regulatory Submissions in Electronic Format — General
Considerations (January 1999
Dataset files should be organized so that their size is generally less than 25 MB
per file. The files should not be compressed. Each dataset should be saved as an
individual file.
The data variable names should be no more than 8 characters in length because of
restrictions in our data format. We recommend that you provide a more
descriptive data variable label, up to 32 characters in length.
2. Organization of data
3. Documentation of the datasets
You should include two PDF files, one of the data definition tables (define.pdf)
and one of the annotated case report forms (blankcrf.pdf) to describe the datasets
for each study, specific data analysis (e.g., population PK), and integrated
summaries.
4. Dataset table of contents
The dataset table of contents is also part of the comprehensive table of contents
and must list all studies and integrated summaries that have datasets. You must
provide a hypertext link to the appropriate data definition table file (314.50(b)).
The table of contents should be provided as a PDF file named datatoc.pdf and
placed in the datasets folder.
5. Full text index
6. General considerations for datasets
7. Patient profiles as PDF files
a. Folders
b. Table of contents
You must provide in a PDF file a table of contents listing all patient profiles by
study. Name this file protoc.pdf. This table of contents is considered part of the
comprehensive table of contents (314.50(b)). List the patient identification
numbers by study, site, and treatment assignment and describe the location of the
patient profile with the file name and folder(s). Provide a hypertext link between
the documents listed in the table of contents and the corresponding PDF file and
bookmarks for each item in the table of contents. Place the protoc.pdf file in the
profile folder.
c. Patient profiles
You should provide each individual patient’s complete patient profile as a single
PDF file. Including the patient ID in the file name will help identify the file.
12
d. Bookmarks and hypertext links
e. Full text index
13
study 101 would be placed into a folder named 001, which then would be placed
in a folder named 101.
The Document Information Title field for each file should include the letters crf,
the study number, the site identification, and the patient’s unique ID number. The
unique patient ID number should be composed of elements of the study number,
site number, and patient number, or a functional equivalent. For example, the
CRF for patient 001 in study 2001 at site 003 would have the following in the
Title field: crf, study 2001, site 003, PID 2001-003-001.
4. Bookmarks and hypertext links
Each CRF must have bookmarks as part of the comprehensive table of contents
required under 314.50(b).
5. Full text index
An index of the full text and the Document Information field of all documents in
the crf folder should be provided. Even if all of the CRFs are images, the text in
the Document Information field should be indexed. The index definition file
should be named crfindex.pdx. Place all associated index files in a folder named
crfindex. Place the crfindex.pdx definition file and the crfindex subfolder in the
main crf folder. Associate crftoc.pdf with the index file so that whenever the
table of contents file is opened, the associated index is automatically added to the
available index list.
14
There should be a hypertext link from the submission table of contents directly to
the patinfo.pdf file.
3. Patent information
You should provide the information pertaining to the patent information in a
single PDF file named patinfo.pdf.
N. Item 14: Patent Certification
1. Folder
You should place the document for this section in the folder named other.
2. Table of contents
There should be a hypertext link from the submission table of contents directly to
the patcert.pdf file.
3. Patent certification
You should provide the information pertaining to the patent certification in a
single PDF file named patcert.pdf.
O. Item 15: Establishment Description (CBER only)
Item 15 on page 2 of FDA form 356h applies only to submissions to CBER.
15
The user fee cover sheet should be provided as a single PDF file named
userfee.pdf.
S. Item 19: Other
1. Folder
You should place all additional information for this item in the folder named
other.
2. Table of contents
There should be a hypertext link from the submission table of contents directly to
each file in this item.
3. Other items
You should provide each additional item as a separate PDF file
16
SECTION 8
Revision History
Date Version Summary of Changes
2003-08-13 1.0 Original version
2004-03-01 1.1 Clarifications to the original version
2006-04-13 1.2 Change to Related Sequence Example
2006-12-13 1.3 Change to XML coding for a supplement to an original application
related sequence example
The eCTD Backbone Files Specification for Module 1
TABLE OF CONTENTS
I. START OF THE MODULE 1 ECTD BACKBONE FILE.............................................................................3
This document provides specifications for creating the electronic common technical document
(eCTD) backbone file for Modules 1 for use with the guidance to industry: Providing Regulatory
Submissions in Electronic Format — Human Pharmaceutical Applications and Related
Submissions.
The Module 1 eCTD Backbone File includes information for each file submitted in Module 1.
The file information is provided within an XML element called the leaf element. The leaf
elements are organized using the Module1 headings. The Module 1 headings are named and
organized according to the subject matter of the information contained in the file. The heading
information is provided as an XML element called header in this specification. In addition, the
Module 1 eCTD Backbone File includes administrative information about each submission. The
administrative information is provided in the admin element.
Because the Module 1 eCTD Backbone File may be used in a wide range of applications and
related submission types, a specific submission may not use all of the possible headings
elements. You should include the header needed to organize the files in your submission.
You should name the module 1eCTD Backbone File us-regional.xml and place it in the us folder
that is in the folder named m1 as described in Providing Regulatory Submissions in Electronic
Format — Human Pharmaceutical Applications and Related Submissions. For example, the path
for the us-regional.xml file for sequence number 0006 is 0006/m1/us/us-regional.xml. You
should place a leaf element in the Module 2 to 5 eCTD Backbone File for the us-regional.xml
file. In the corresponding Module 2 to 5 eCTD Backbone File, the operation attribute should
have a value of “new”.
The header of the Module 1 eCTD Backbone File is always the same. It contains machine-
readable information about the following:
Version 1.3 3
The eCTD Backbone Files Specification for Module 1
The elements used to organize files for Module1 are placed within the area represented by the
comment in the example shown above. Information about creating those elements is provided in
other sections of this specification.
Administrative information is contained in the admin element which is contained in the fda-
regional:fda-regional element1. There are three elements contained in the element named
admin:. applicant-info, product-description, and application-information. These elements should
be placed in the order as they are listed above.
<fda-regional:fda-regional>
<admin>
<applicant-info>
</applicant-info>
<product-description>
</product-description>
<applicant-information>
</applicant-information>
</admin>
</fda-regional:fda-regional>
. Applicant-info Element
The application-info elements contains the applicant-info element: company-name, and date-of-
submission.
0. Company-name Element
The sponsor or applicant’s name is in the company-name element. An example of the company-
name element for the “VeryBest Drug Company” with its content is provided:
0. Date-of-submission Element
1
Both the start tag and the end tag of the admin element should be placed between the start and end tags of the:fda-
regional element.
Version 1.3 4
The eCTD Backbone Files Specification for Module 1
An element named date is contained in the date-of-submission element. You should place the
date of submission in the date element. This is sometimes referred to as the "letter date" because
it can be the same as the date on the cover letter. Provide an attribute for the date element named
format. The format has a fixed value of "yyyymmdd" and indicates the content of the date
element is the four-digit year followed by two-digit month followed by two-digit day.
<date-of-submission>
<date format="yyyymmdd">20020208</date>
</date-of-submission >
. Product-description Element
There are two elements contained in the product-description element: application-number, and
prod-name.
0. Application-number Element
The 6 digit application number in placed in the application-number element. You should
provide only the digits, including any leading zeros for the application number without letters or
dashes. An example of the application-number element for NDA 99-999 with its content is
provided:
<application-number>099999</application-number >
You should provide this element with every sequence number submission to the application.
0. Prod-name Element
The prod-name elements contains up to four different types of product name, all of which can
occur in a single submission. Provide an attribute for the prod-name element named type.
Indicate the type of product name you contained in the prod-name element by choosing one of
the four allowed values. The table below lists the available product name types (type attribute
values) with their meaning:
Version 1.3 5
The eCTD Backbone Files Specification for Module 1
You should provide at least one prod-name element with each sequence numbered submission to
the application.
. Application-information Element
The element application-information contains the submission element. You should provide an
attribute for the application-information element named application-type. Indicate the type of
application for this submission in the application-type element by choosing one of the types
allowed. The table below lists the available application types (application-type attribute values)
with their meaning:
0. Submission Element
There are two elements in the submission element: sequence-number, and related-sequence-
number. You should provide a submission-type attribute for the submission element that contains
the value for the type of submission from the following table:
Submission-type Meaning
Attribute Value
“original-application" A complete new application that has never before been submitted
"amendment" All submissions to pending original submission or pending
supplements to approved applications including responses to
information request letters
"resubmission" A complete response to an action letter, or submission of an
application that has been the subject of a withdrawal or a refusal to
file
"presubmission" Information submitted prior to the submission of a complete new
application
"annual-report" Annual Reports to applications
Version 1.3 6
The eCTD Backbone Files Specification for Module 1
Submission-type Meaning
Attribute Value
"establishment- Supplements to the information contained in the establishment
description-supplement" description section for biological products
"efficacy-supplement" Submissions for such changes as a new indication or dosage regimen
for an approved product, a comparative efficacy claim naming
another product, or a significant alteration in the patient population;
e.g., prescription to Over-The-Counter switch
"labeling-supplement" All label change supplements required under 21 CFR 314.70 and 21
CFR 601.12 that do not qualify as efficacy supplements;
"chemistry- Manufacturing and Controls Supplement manufacturing change
manufacturing-controls- supplement submissions as provided in 21 CFR 314.70, 21 CFR
supplement" 314.71, 21 CFR 314.72 and 21 CFR 601.12
"other" Not among those listed above
) Sequence-number Element
You should include the sequence number of the submission in the sequence-number element.
The sequence number should be exactly 4 digits with no spaces between them. You should
provide a sequence-number element with every submission. Note that sequence numbers are
used to differentiate between submissions for the same application and do not necessarily
correspond to the order they are received by the Agency. An example of the first application
sequence number element with its content is provided:
<sequence-number>0000</sequence-number>
) Related-sequence-number Element
When providing an amendment to an earlier submission, you should include the sequence
number of the earlier submission in the related-sequence-number element. The sequence
number should be exactly 4 digits with no spaces between them. If this submission is related to
more than one previous submission, you should provide each previous submission's sequence
number in a separate related-sequence-number element. There is no limit to the number of
related-sequence-number elements. The following is an example of the related sequence
number. An application has the following submissions:
Version 1.3 7
The eCTD Backbone Files Specification for Module 1
Sequence-number Related-sequence-number***
0000
0001 0000
0002 0000
0003
0004 0000
0005 0003
0006 0000
0007 0000 0003
Example XML coding for the original application would look like:
<submission submission-type="original-application">
<sequence-number>0000</sequence-number>
</submission>
Example XML coding for a supplement to an original application would look like:
Example XML coding for a submission element of an amendment that would apply to two or
more original submissions, such as sequence number 0007 above, would look like:
<submission submission-type="chemistry-manufacturing-controls-supplement">
<sequence-number>0007</sequence-number>
<related-sequence-number>0000</related-sequence-number>
<related-sequence-number>0003</related-sequence-number>
</submission>
Information for an individual document is contained in the leaf element, its attributes and its
"title" element. The leaf element is used repeatedly throughout the eCTD backbone files to
provide individual information for each document being submitted. Detailed descriptions of
each part of the leaf element and how to use them are found in the document The eCTD
Version 1.3 8
The eCTD Backbone Files Specification for Module 1
Backbone Files Specifications for Modules 2 through 5. When preparing the us-regional.xml file,
the xlink:href and modified-file leaf attributes should reflect the path relative to the location of
the us-regional.xml file location in the submission. The following is an example of a xlink:href
attribute and its value for the 356h.pdf in module 1 in the same submission:
xlink:href="356h.pdf "
The following is a example of a modified-file leaf attribute and its value in module 1 in an earlier
submission:
modified-file="../../../0001/m1/us/us-regional.xml#id34567
This is the equivalent to the heading elements described in the document The eCTD Backbone
Files Specifications for Modules 2 through 5. This section describes the heading elements
relevant to module 1.
The module 1 heading elements are listed in the following table. Both the start tag and end tag
for each heading element are provided. If there are one or more subheadings for the heading, the
corresponding element end tag will occur on the table row below the last relevant subheading.
The leaf element is included to show where the leaf elements should be placed. The details for
the leaf elements are not shown on this table to keep it clearer. The leaf elements should only
occur where indicated in this table. A heading element may contain any number of leaf elements.
If no documents are submitted for a heading, you should omit the element for that heading in the
eCTD backbone file.
Version 1.3 9
The eCTD Backbone Files Specification for Module 1
Version 1.3 10
The eCTD Backbone Files Specification for Module 1
Version 1.3 11
The eCTD Backbone Files Specification for Module 1
Version 1.3 12
The eCTD Backbone Files Specification for Module 1
Version 1.3 13
The eCTD Backbone Files Specification for Module 1
Version 1.3 14
The eCTD Backbone Files Specification for Module 1
Version 1.3 15
The eCTD Backbone Files Specification for Module 1
Version 1.3 16
The eCTD Backbone Files Specification for Module 1
Version 1.3 17
The eCTD Backbone Files Specification for Module 1
Version 1.3 18
The eCTD Backbone Files Specification for Module 1
Version 1.3 19
The eCTD Backbone Files Specification for Module 1
Version 1.3 20
The eCTD Backbone Files Specification for Module 1
Version 1.3 21
The eCTD Backbone Files Specification for Module 1
Version 1.3 22
The eCTD Backbone Files Specification for Module 1
Version 1.3 23
The eCTD Backbone Files Specification for Module 1
Version 1.3 24
The eCTD Backbone Files Specification for Module 1
Version 1.3 25
The eCTD Backbone Files Specification for Module 1
<!ATTLIST m1-1-forms
%att;
>
<!ELEMENT m1-1-1-fda-form-1571 ((leaf | node-extension)*)>
<!ATTLIST m1-1-1-fda-form-1571
%att;
>
<!ELEMENT m1-1-2-fda-form-356h ((leaf | node-extension)*)>
<!ATTLIST m1-1-2-fda-form-356h
%att;
>
<!ELEMENT m1-1-3-fda-form-3397 ((leaf | node-extension)*)>
<!ATTLIST m1-1-3-fda-form-3397
%att;
>
<!ELEMENT m1-1-4-fda-form-2252 ((leaf | node-extension)*)>
<!ATTLIST m1-1-4-fda-form-2252
%att;
>
<!ELEMENT m1-1-5-fda-form-2253 ((leaf | node-extension)*)>
<!ATTLIST m1-1-5-fda-form-2253
%att;
>
<!ELEMENT m1-1-6-fda-form-2567 ((leaf | node-extension)*)>
<!ATTLIST m1-1-6-fda-form-2567
%att;
>
<!-- ================= COVER LETTERS ============================ -->
<!ELEMENT m1-2-cover-letters ((leaf | node-extension)*)>
<!ATTLIST m1-2-cover-letters
%att;
>
<!-- ================== ADMINISTRATIVE INFORMATION =============== -->
<!ELEMENT m1-3-administrative-information (
m1-3-1-applicant-information*,
m1-3-2-field-copy-certification*,
m1-3-3-debarment-certification*,
m1-3-4-financial-certification-disclosure*,
m1-3-5-patent-exclusivity*)>
<!ATTLIST m1-3-administrative-information
%att;
>
<!ELEMENT m1-3-1-applicant-information (
m1-3-1-1-change-of-address-or-corporate-name*,
m1-3-1-2-change-contact-agent*,
m1-3-1-3-change-in-sponsor*,
Version 1.3 26
The eCTD Backbone Files Specification for Module 1
m1-3-1-4-transfer-obligation*,
m1-3-1-5-change-application-ownership*)>
<!ATTLIST m1-3-1-applicant-information
%att;
>
<!ELEMENT m1-3-1-1-change-of-address-or-corporate-name
((leaf | node-extension)*)>
<!ATTLIST m1-3-1-1-change-of-address-or-corporate-name
%att;
>
<!ELEMENT m1-3-1-2-change-contact-agent ((leaf | node-extension)*)>
<!ATTLIST m1-3-1-2-change-contact-agent
%att;
>
<!ELEMENT m1-3-1-3-change-in-sponsor ((leaf | node-extension)*)>
<!ATTLIST m1-3-1-3-change-in-sponsor
%att;
>
<!ELEMENT m1-3-1-4-transfer-obligation ((leaf | node-extension)*)>
<!ATTLIST m1-3-1-4-transfer-obligation
%att;
>
<!ELEMENT m1-3-1-5-change-application-ownership ((leaf | node-extension)*)>
<!ATTLIST m1-3-1-5-change-application-ownership
%att;
>
<!-- =================== FIELD COPY CERTIFICATION ================= -->
<!ELEMENT m1-3-2-field-copy-certification ((leaf | node-extension)*)>
<!ATTLIST m1-3-2-field-copy-certification
%att;
>
<!-- ================= DEBARMENT CERTIFICATION ================== -->
<!ELEMENT m1-3-3-debarment-certification ((leaf | node-extension)*)>
<!ATTLIST m1-3-3-debarment-certification
%att;
>
<!-- ================== FINANCIAL CERTIFICATION DISCLOSURE ======= -->
<!ELEMENT m1-3-4-financial-certification-disclosure ((leaf | node-extension)*)>
<!ATTLIST m1-3-4-financial-certification-disclosure
%att;
>
<!-- ===================== PATENT EXCLUSIVITIY ====================== --
>
<!ELEMENT m1-3-5-patent-exclusivity (
m1-3-5-1-patent-information*,
m1-3-5-2-patent-certification*,
Version 1.3 27
The eCTD Backbone Files Specification for Module 1
m1-3-5-3-exclusivity-request*)>
<!ATTLIST m1-3-5-patent-exclusivity
%att;
>
<!ELEMENT m1-3-5-1-patent-information ((leaf | node-extension)*)>
<!ATTLIST m1-3-5-1-patent-information
%att;
>
<!ELEMENT m1-3-5-2-patent-certification ((leaf | node-extension)*)>
<!ATTLIST m1-3-5-2-patent-certification
%att;
>
<!ELEMENT m1-3-5-3-exclusivity-request ((leaf | node-extension)*)>
<!ATTLIST m1-3-5-3-exclusivity-request
%att;
>
<!-- ================= REFERENCES =============================== -->
<!ELEMENT m1-4-references (
m1-4-1-letter-authorization*,
m1-4-2-statement-right-reference*,
m1-4-3-list-of-authorized-persons-to-incorporate-by-reference*,
m1-4-4-cross-reference-other-applications*)>
<!ATTLIST m1-4-references
%att;
>
<!ELEMENT m1-4-1-letter-authorization ((leaf | node-extension)*)>
<!ATTLIST m1-4-1-letter-authorization
%att;
>
<!ELEMENT m1-4-2-statement-right-reference ((leaf | node-extension)*)>
<!ATTLIST m1-4-2-statement-right-reference
%att;
>
<!ELEMENT m1-4-3-list-of-authorized-persons-to-incorporate-by-reference
((leaf | node-extension)*)>
<!ATTLIST m1-4-3-list-of-authorized-persons-to-incorporate-by-reference
%att;
>
<!ELEMENT m1-4-4-cross-reference-other-applications ((leaf | node-extension)*)>
<!ATTLIST m1-4-4-cross-reference-other-applications
%att;
>
<!-- ================== APPLICATION STATUS ======================= -->
<!ELEMENT m1-5-application-status (
m1-5-1-withdrawal-request*,
m1-5-2-inactivation-request*,
Version 1.3 28
The eCTD Backbone Files Specification for Module 1
m1-5-3-reactivation-request*,
m1-5-4-reinstatement-request*,
m1-5-5-withdrawal-unapproved-nda*,
m1-5-6-withdrawal-of-listed-drug*,
m1-5-7-request-withdrawal-application-approval*)>
<!ATTLIST m1-5-application-status
%att;
>
<!ELEMENT m1-5-1-withdrawal-request ((leaf | node-extension)*)>
<!ATTLIST m1-5-1-withdrawal-request
%att;
>
<!ELEMENT m1-5-2-inactivation-request ((leaf | node-extension)*)>
<!ATTLIST m1-5-2-inactivation-request
%att;
>
<!ELEMENT m1-5-3-reactivation-request ((leaf | node-extension)*)>
<!ATTLIST m1-5-3-reactivation-request
%att;
>
<!ELEMENT m1-5-4-reinstatement-request ((leaf | node-extension)*)>
<!ATTLIST m1-5-4-reinstatement-request
%att;
>
<!ELEMENT m1-5-5-withdrawal-unapproved-nda ((leaf | node-extension)*)>
<!ATTLIST m1-5-5-withdrawal-unapproved-nda
%att;
>
<!ELEMENT m1-5-6-withdrawal-of-listed-drug ((leaf | node-extension)*)>
<!ATTLIST m1-5-6-withdrawal-of-listed-drug
%att;
>
<!ELEMENT m1-5-7-request-withdrawal-application-approval ((leaf | node-extension)*)>
<!ATTLIST m1-5-7-request-withdrawal-application-approval
%att;
>
<!-- ================== MEETINGS ================================= -->
<!ELEMENT m1-6-meetings (m1-6-1-meeting-request*, m1-6-2-meeting-background-
materials*, m1-6-3-correspondence-regarding-meetings*)>
<!ATTLIST m1-6-meetings
%att;
>
<!ELEMENT m1-6-1-meeting-request ((leaf | node-extension)*)>
<!ATTLIST m1-6-1-meeting-request
%att;
>
Version 1.3 29
The eCTD Backbone Files Specification for Module 1
Version 1.3 30
The eCTD Backbone Files Specification for Module 1
<!ATTLIST m1-8-3-stability-study
%att;
>
<!-- ================== PEDIATRIC ADMINISTRATIVE INFORMATION ===== -->
<!ELEMENT m1-9-pediatric-administrative-information (
m1-9-1-request-waiver-pediatric-studies*,
m1-9-2-request-deferral-pediatric-studies*,
m1-9-3-request-pediatric-exclusivity-determination*,
m1-9-4-proposed-pediatric-study-request-amendments*,
m1-9-5-proposal-written-agreement*,
m1-9-6-other-correspondence-regarding-pediatric-exclusivity-study-plans*)>
<!ATTLIST m1-9-pediatric-administrative-information
%att;
>
<!ELEMENT m1-9-1-request-waiver-pediatric-studies ((leaf | node-extension)*)>
<!ATTLIST m1-9-1-request-waiver-pediatric-studies
%att;
>
<!ELEMENT m1-9-2-request-deferral-pediatric-studies ((leaf | node-extension)*)>
<!ATTLIST m1-9-2-request-deferral-pediatric-studies
%att;
>
<!ELEMENT m1-9-3-request-pediatric-exclusivity-determination
((leaf | node-extension)*)>
<!ATTLIST m1-9-3-request-pediatric-exclusivity-determination
%att;
>
<!ELEMENT m1-9-4-proposed-pediatric-study-request-amendments
((leaf | node-extension)*)>
<!ATTLIST m1-9-4-proposed-pediatric-study-request-amendments
%att;
>
<!ELEMENT m1-9-5-proposal-written-agreement ((leaf | node-extension)*)>
<!ATTLIST m1-9-5-proposal-written-agreement
%att;
>
<!ELEMENT m1-9-6-other-correspondence-regarding-pediatric-exclusivity-study-plans
((leaf | node-extension)*)>
<!ATTLIST m1-9-6-other-correspondence-regarding-pediatric-exclusivity-study-plans
%att;
>
<!-- ================== DISPUTE RESOLUTION ======================= -->
<!ELEMENT m1-10-dispute-resolution (
m1-10-1-request-for-dispute-resolution*,
m1-10-2-correspondence-related-to-dispute-resolution*)>
<!ATTLIST m1-10-dispute-resolution
Version 1.3 31
The eCTD Backbone Files Specification for Module 1
%att;
>
<!ELEMENT m1-10-1-request-for-dispute-resolution ((leaf | node-extension)*)>
<!ATTLIST m1-10-1-request-for-dispute-resolution
%att;
>
<!ELEMENT m1-10-2-correspondence-related-to-dispute-resolution ((leaf | node-extension)*)>
<!ATTLIST m1-10-2-correspondence-related-to-dispute-resolution
%att;
>
<!-- ================ INFORMATION ADMENDMENT =================== -->
<!ELEMENT m1-11-information-amendment (
m1-11-1-quality-information-amendment*,
m1-11-2-safety-information-amendment*,
m1-11-3-efficacy-information-amendment*,
m1-11-4-multiple-module-information-amendments*)>
<!ATTLIST m1-11-information-amendment
%att;
>
<!ELEMENT m1-11-1-quality-information-amendment ((leaf | node-extension)*)>
<!ATTLIST m1-11-1-quality-information-amendment
%att;
>
<!ELEMENT m1-11-2-safety-information-amendment ((leaf | node-extension)*)>
<!ATTLIST m1-11-2-safety-information-amendment
%att;
>
<!ELEMENT m1-11-3-efficacy-information-amendment ((leaf | node-extension)*)>
<!ATTLIST m1-11-3-efficacy-information-amendment
%att;
>
<!ELEMENT m1-11-4-multiple-module-information-amendments
((leaf | node-extension)*)>
<!ATTLIST m1-11-4-multiple-module-information-amendments
%att;
>
<!-- =============== OTHER CORRESPONDENCE ===================== -->
<!ELEMENT m1-12-other-correspondence (
m1-12-1-pre-ind-correspondence*,
m1-12-2-request-charge*,
m1-12-3-notification-charging-under-treatment-ind*,
m1-12-4-request-comments-advice-ind*,
m1-12-5-request-waiver*,
m1-12-6-exemption-informed-consent-emergency-research*,
m1-12-7-public-disclosure-statement-emergency-care-research*,
m1-12-8-correspondence-regarding-emergency-care-research*,
Version 1.3 32
The eCTD Backbone Files Specification for Module 1
m1-12-9-notification-discontinuation-clinical-trial*,
m1-12-10-generic-drug-enforcement-act-statement*,
m1-12-11-basis-submission-statement*,
m1-12-12-comparison-generic-drug-reference-listed-drug*,
m1-12-13-request-waiver-in-vivo-studies*,
m1-12-14-environmental-analysis*,
m1-12-15-request-waiver-in-vivo-bioavailability-studies*,
m1-12-16-field-alert-reports*)>
<!ATTLIST m1-12-other-correspondence
%att;
>
<!ELEMENT m1-12-1-pre-ind-correspondence ((leaf | node-extension)*)>
<!ATTLIST m1-12-1-pre-ind-correspondence
%att;
>
<!ELEMENT m1-12-2-request-charge ((leaf | node-extension)*)>
<!ATTLIST m1-12-2-request-charge
%att;
>
<!ELEMENT m1-12-3-notification-charging-under-treatment-ind
((leaf | node-extension)*)>
<!ATTLIST m1-12-3-notification-charging-under-treatment-ind
%att;
>
<!ELEMENT m1-12-4-request-comments-advice-ind ((leaf | node-extension)*)>
<!ATTLIST m1-12-4-request-comments-advice-ind
%att;
>
<!ELEMENT m1-12-5-request-waiver ((leaf | node-extension)*)>
<!ATTLIST m1-12-5-request-waiver
%att;
>
<!ELEMENT m1-12-6-exemption-informed-consent-emergency-research
((leaf | node-extension)*)>
<!ATTLIST m1-12-6-exemption-informed-consent-emergency-research
%att;
>
<!ELEMENT m1-12-7-public-disclosure-statement-emergency-care-research
((leaf | node-extension)*)>
<!ATTLIST m1-12-7-public-disclosure-statement-emergency-care-research
%att;
>
<!ELEMENT m1-12-8-correspondence-regarding-emergency-care-research
((leaf | node-extension)*)>
<!ATTLIST m1-12-8-correspondence-regarding-emergency-care-research
%att;
Version 1.3 33
The eCTD Backbone Files Specification for Module 1
>
<!ELEMENT m1-12-9-notification-discontinuation-clinical-trial ((leaf | node-extension)*)>
<!ATTLIST m1-12-9-notification-discontinuation-clinical-trial
%att;
>
<!ELEMENT m1-12-10-generic-drug-enforcement-act-statement
((leaf | node-extension)*)>
<!ATTLIST m1-12-10-generic-drug-enforcement-act-statement
%att;
>
<!ELEMENT m1-12-11-basis-submission-statement ((leaf | node-extension)*)>
<!ATTLIST m1-12-11-basis-submission-statement
%att;
>
<!ELEMENT m1-12-12-comparison-generic-drug-reference-listed-drug
((leaf | node-extension)*)>
<!ATTLIST m1-12-12-comparison-generic-drug-reference-listed-drug
%att;
>
<!ELEMENT m1-12-13-request-waiver-in-vivo-studies ((leaf | node-extension)*)>
<!ATTLIST m1-12-13-request-waiver-in-vivo-studies
%att;
>
<!ELEMENT m1-12-14-environmental-analysis ((leaf | node-extension)*)>
<!ATTLIST m1-12-14-environmental-analysis
%att;
>
<!ELEMENT m1-12-15-request-waiver-in-vivo-bioavailability-studies
((leaf | node-extension)*)>
<!ATTLIST m1-12-15-request-waiver-in-vivo-bioavailability-studies
%att;
>
<!ELEMENT m1-12-16-field-alert-reports ((leaf | node-extension)*)>
<!ATTLIST m1-12-16-field-alert-reports
%att;
>
<!-- ================= ANNUAL REPORT ============================ -->
<!ELEMENT m1-13-annual-report (
m1-13-1-summary-nonclinical-studies*,
m1-13-2-summary-clinical-pharmacology-information*,
m1-13-3-summary-safety-information*,
m1-13-4-summary-labeling-changes*,
m1-13-5-summary-manufacturing-changes*,
m1-13-6-summary-microbiological-changes*,
m1-13-7-summary-other-significant-new-information*,
m1-13-8-individual-study-information*,
Version 1.3 34
The eCTD Backbone Files Specification for Module 1
m1-13-9-general-investigational-plan*,
m1-13-10-foreign-marketing-history*,
m1-13-11-distribution-data*,
m1-13-12-status-postmarketing-study-commitments*,
m1-13-13-status-other-postmarketing-studies*,
m1-13-14-log-outstanding-regulatory-business*)>
<!ATTLIST m1-13-annual-report
%att;
>
<!ELEMENT m1-13-1-summary-nonclinical-studies ((leaf | node-extension)*)>
<!ATTLIST m1-13-1-summary-nonclinical-studies
%att;
>
<!ELEMENT m1-13-2-summary-clinical-pharmacology-information
((leaf | node-extension)*)>
<!ATTLIST m1-13-2-summary-clinical-pharmacology-information
%att;
>
<!ELEMENT m1-13-3-summary-safety-information ((leaf | node-extension)*)>
<!ATTLIST m1-13-3-summary-safety-information
%att;
>
<!ELEMENT m1-13-4-summary-labeling-changes ((leaf | node-extension)*)>
<!ATTLIST m1-13-4-summary-labeling-changes
%att;
>
<!ELEMENT m1-13-5-summary-manufacturing-changes ((leaf | node-extension)*)>
<!ATTLIST m1-13-5-summary-manufacturing-changes
%att;
>
<!ELEMENT m1-13-6-summary-microbiological-changes ((leaf | node-extension)*)>
<!ATTLIST m1-13-6-summary-microbiological-changes
%att;
>
<!ELEMENT m1-13-7-summary-other-significant-new-information
((leaf | node-extension)*)>
<!ATTLIST m1-13-7-summary-other-significant-new-information
%att;
>
<!ELEMENT m1-13-8-individual-study-information ((leaf | node-extension)*)>
<!ATTLIST m1-13-8-individual-study-information
%att;
>
<!ELEMENT m1-13-9-general-investigational-plan ((leaf | node-extension)*)>
<!ATTLIST m1-13-9-general-investigational-plan
%att;
Version 1.3 35
The eCTD Backbone Files Specification for Module 1
>
<!ELEMENT m1-13-10-foreign-marketing-history ((leaf | node-extension)*)>
<!ATTLIST m1-13-10-foreign-marketing-history
%att;
>
<!ELEMENT m1-13-11-distribution-data ((leaf | node-extension)*)>
<!ATTLIST m1-13-11-distribution-data
%att;
>
<!ELEMENT m1-13-12-status-postmarketing-study-commitments
((leaf | node-extension)*)>
<!ATTLIST m1-13-12-status-postmarketing-study-commitments
%att;
>
<!ELEMENT m1-13-13-status-other-postmarketing-studies ((leaf | node-extension)*)>
<!ATTLIST m1-13-13-status-other-postmarketing-studies
%att;
>
<!ELEMENT m1-13-14-log-outstanding-regulatory-business ((leaf | node-extension)*)>
<!ATTLIST m1-13-14-log-outstanding-regulatory-business
%att;
>
<!-- ===================== LABELING ================================= --
>
<!ELEMENT m1-14-labeling (
m1-14-1-draft-labeling*,
m1-14-2-final-labeling*,
m1-14-3-listed-drug-labeling*,
m1-14-4-investigational-drug-labeling*,
m1-14-5-foreign-labeling*)>
<!ATTLIST m1-14-labeling
%att;
>
<!ELEMENT m1-14-1-draft-labeling (
m1-14-1-1-draft-carton-container-labels*,
m1-14-1-2-annotated-draft-labeling-text*,
m1-14-1-3-draft-labeling-text*,
m1-14-1-4-label-comprehension-studies*,
m1-14-1-5-labeling-history*)>
<!ATTLIST m1-14-1-draft-labeling
%att;
>
<!ELEMENT m1-14-1-1-draft-carton-container-labels ((leaf | node-extension)*)>
<!ATTLIST m1-14-1-1-draft-carton-container-labels
%att;
>
Version 1.3 36
The eCTD Backbone Files Specification for Module 1
Version 1.3 37
The eCTD Backbone Files Specification for Module 1
Version 1.3 38
SECTION 9
Revision History
Date Version Summary of Changes
2003-08-13 1.0 Original version
2004-03-11 1.1 Clarifications to the original version
The eCTD Backbone File Specification for Modules 2 through 5
This document provides specifications for creating the electronic common technical document
(eCTD) backbone file for modules 2 to 5 of the common technical document (CTD) for use with
the guidance to industry: Providing Regulatory Submissions in Electronic Format — Human
Pharmaceutical Applications and Related Submissions.
The Module 2 to 5 eCTD Backbone File includes information for each file submitted in modules
2 to 5. The file information is provided within an XML element called the leaf element. The leaf
elements are organized using the CTD headings. The CTD headings are named and organized
according to the subject matter of the information contained in the file. The heading information
is provided in an XML element called heading elements.
Because the Module 2 to 5 eCTD Backbone File may be used in a wide range of applications and
related submission types, a specific submission will not use all of the possible heading elements.
You should only include the heading elements needed to organize the files in your submission.
You should name the Module 2 to 5 eCTD Backbone File index.xml and place it in the main
submission folder as described in Providing Regulatory Submissions in Electronic Format —
Human Pharmaceutical Applications and Related Submissions. For example, the path for the
index.xml for sequence number 0006 is ../0006/index.xml.
The header contains the root element, <ectd:ectd> and the last element, </ectd:ectd>1 of the
Module 2 to 5 eCTD Backbone File. This is always the same. The header contains information
about the following:
A sample of the header and the last line of the Module 2 to 5 eCTD Backbone File is provided
below:
1
This is the end tag for the root element.
Version 1.1 3
The eCTD Backbone File Specification for Modules 2 through 5
<!--All the heading elements and content for module 2, 3, 4, and module 5
will be provided after these elements and before the last element closing
tag named </ectd:ectd> -->
</ectd:ectd>
The elements used to organize files for Modules 2 to 5 are placed within the area represented by
the comment in the example shown above. Information about creating those elements is
provided in other sections of this specification.
Information for an individual file is contained in the leaf element, its attributes and its title
element. The leaf element is used repeatedly throughout the eCTD backbone file to provide
individual information for each submitted file.
The table below provides the name of each part of the leaf element and a brief indication of its
purpose:
The following is an example of the leaf element for a file containing the first version of the
tabular listing of all clinical studies provided in module 5.
<leaf >
ID="a1234567"
operation="new"
Version 1.1 4
The eCTD Backbone File Specification for Modules 2 through 5
modified-file=""
checksum="9f52fcd71d726c74faf07c85d46b3363"
checksum-type="md5"
xlink:href="m5/tabular-listing-of-studies.pdf"
<title>Tabular listing of all clinical studies</title>
</leaf>
For the remainder of this section each part of the leaf element is described in detail in its own
subsection.
The purpose of the start tag is to provide a machine-readable indication that file information is
beginning. All the leaf element attributes and the title element are contained between the leaf
start tag and the leaf end tags.
The start tag for the leaf element begins with the "less than" symbol, “<”, and the lower case
word "leaf". This is followed by each of the leaf element attributes and their values. The leaf
element, its attributes and their values are placed between the word “leaf” and the closing
“greater than” symbol of the leaf element start tag.
The leaf element start tag and its matching end tag with all the attribute and element contents are
used for each file being submitted, modified or referenced2 to the Agency for review. The leaf
element is the fundamental block of information for every file and occurs in both the Module 2
to 5 eCTD Backbone File and Module 1 eCTD Backbone File.
The purpose of the leaf element ID attribute is to provide a unique identification for the file
within the submission. This facilitates referencing from other submissions. The leaf element ID
combined with the application number, sequence number and name of the eCTD backbone file
provide a unique ID for the file.
The ID attribute occurs after the word “leaf” and begins with the upper case letters "ID". The
value for the ID attribute is provided in a statement that begins with the equal sign and quotation
mark, (="), followed by the ID attribute value ending with a quotation mark. There should be no
spaces in the ID attribute value statement.
The ID value must start with a letter followed by a combination of letters and numbers to provide
a unique identification of this leaf element within the Module 2 to 5 eCTD Backbone File.
Examples of valid ID attributes:
2
Including previously submitted information. See Guidance to Industry: Providing Regulatory
Submissions in Electronic Format — Human Drug Applications and Related Submissions for
more information.
Version 1.1 5
The eCTD Backbone File Specification for Modules 2 through 5
ID="a1234567"
ID=”id12235”
ID=”pid1234”
You should provide an ID attribute and value for each leaf element that is unique for the
submission.
The purpose of the operation attribute is to provide a machine-readable indication of the effect
this leaf has on a leaf included in previously submitted eCTD backbone files.
You should include an operation attribute for each leaf you are submitting. The value for the
operation attribute is limited to: new, append, replace, and delete. The table below summarizes
the meaning of each modified-file attribute value.
The purpose of the modified-file attribute is to provide the location of leaf that is being modified
(i.e. appended, replaced, or deleted) by the current leaf element. The modified-file attribute
should have a value when the operation attribute has a value of append, replace or delete.
The modified-file attribute for the leaf element begins with the lowercase hyphenated word
"modified-file". The value for the modified-file attribute is provided in a statement that begins
with the equal sign and quotation mark, (="), followed by the modified-file attribute value and
Version 1.1 6
The eCTD Backbone File Specification for Modules 2 through 5
ending with a quotation mark. There should be no spaces in the modified-file attribute's value
statement.
The modified-file leaf attribute should have a value of a relative path and filename with a
bookmark. You should use the relative path and filename for the eCTD backbone file (ie.,
index.xml or us-regional.xml) containing the modified file’s leaf element. You should append
the modified file’s leaf ID value to the relative path and file name as a bookmark. This is
detailed in the next paragraph.
The relative path and filename for a previously submitted leaf will start with two periods and a
slash, “../”, providing a machine readable instruction to move up one level in the directory
structure to where the previous submission folders are located. These characters are followed
with the sequence folder name (four numbers, e.g. 0001) and another slash. This is followed by
the path and filename for the leaf you want to modify. For example, to replace the tabular-listing-
studies.pdf file submitted in Module 5 of the original submission associated with the leaf ID
value id12345, the modified-file attribute value is as follows:
modified-file="../0000/index.xml#id12345 "
The purpose of the checksum attribute is to provide the value of the checksum for the file this
leaf is providing. The checksum is the result of an algorithm that breaks down a file into a
unique128 bit “message digest” or “fingerprint”. The “fingerprint” is used to verify that the file
was transmitted and received without being modified3.
The checksum attribute for the leaf element begins with the lowercase word "checksum". The
value for the checksum attribute is provided in a statement that begins with the equal sign and
quotation mark, (="), followed by the checksum attribute value and ending with a quotation
mark. There should be no spaces in the checksum attribute's value statement. An example of a
checksum attribute and its value is provided:
checksum="e854d3002c02a61fe5cbe92fd97b0018"
You should provide a checksum attribute and value for every leaf element that includes a file.
The checksum-type attribute provides the name of the algorithm used to produce the checksum
value. It should unambiguously identify the algorithm being used.
The checksum-type attribute for the leaf element begins with the lowercase hyphenated word
"checksum-type". The value for the checksum-type attribute is provided in a statement that
begins with the equal sign and quotation mark, (="), followed by the checksum-type attribute
3
Checksum value is also known as the document hash.
Version 1.1 7
The eCTD Backbone File Specification for Modules 2 through 5
value and ending with a quotation mark. There should be no spaces in the checksum-type
attribute's value statement. An example of a checksum-type attribute and its value is provided:
checksum-type="MD5"
You should provide a checksum-type attribute and value for every leaf element that contains a
checksum value.
The purpose of the xlink:href attribute is to provide the machine-readable location and filename
of the file associated with the leaf element. The location is provided as the relative path and
filename of the document. The relative path should be provided relative to the eCTD backbone
file (i.e., index.xml or us-regional.xml) for the leaf.
The xlink:href attribute for the leaf element begins with the lowercase hyphenated word
"xlink:href". The value for the xlink:href attribute is provided in a statement that begins with the
equal sign and quotation mark, (="), followed by the xlink:href attribute value and ending with a
quotation mark. There should be no spaces in the xlink:href attribute's value statement. The
following is an example of a xlink:href attribute and its value for the tabular-listing-studies.pdf in
module 5 in the same submission:
xlink:href="m5/tabular-listing-studies.pdf "
When linking to a file in a previous submission to the application use “../” to signify the level of
the other submissions of an application. The following is an example of a xlink:href attribute and
its value for the tabular-listing-studies.pdf in module 5 submitted in an earlier submission
(sequence number 0001) in the same application:
xlink:href="../0001/m5/tabular-listing-studies.pdf "
Currently, you cannot link to a file submitted to a different application. However, this capability
will be available in the future.
You should provide an xlink:href attribute and its value for every leaf element that provides a
file.
H. xlink:show attribute
The ICH specification has not yet defined a use for the xlink:show attribute and does not need to
be included. If you do include this attribute, you should have the value of "none" or "new" (for
example., xlink:show="none") for the xlink:show attribute.
Version 1.1 8
The eCTD Backbone File Specification for Modules 2 through 5
The purpose of the title element is to provide a title for the file that is meaningful to the human
reader. The title should not include information already provided in the leaf attributes or heading
elements (e.g., module number, table of contents numbers). You can use spaces, upper and lower
case letters and numbers freely.
The title element begins with the "less than" symbol, (<), and the lower case word "title",
followed by the "greater than" symbol, (>). The title content is provided after the greater than
sign. The title element is ended similar to how it is started except a slash is placed between the
less than symbol and the word “title”. An example of a title element and its content is provided:
You should provide a title element and content for every leaf element that provides a file.
The end tag for the leaf element is the same as the start tag except that it contains a "/" symbol
after the "less than" symbol, (</), used to start the tag. It occurs after the title element's end tag
and indicates the end of the file information for the leaf element.
The leaf elements in the eCTD backbone file are organized according to the modules and
headings and subheadings of the CTD. There is a heading element in the Module 2 to 5 eCTD
Backbone File for the CTD headings and many of the subheadings. Each element has a start tag
and an end tag. The element tags start with a "less than" symbol, “<”, and end with a "greater
than" symbol, “>”. The name of the element is inserted between these symbols. The heading
elements are completed with an end tag. The end tag is the same as the start tag except it has a
"slash", “/” after the "less than" symbol, (</). The content for the element (i.e., other heading
elements and leaf elements) occurs between the start tag and the end tag. Leaf elements may be
provided directly within only certain heading elements. In the following example is an isolated
part of the Module 2 to 3 eCTD Backbone File. The heading element m2-common-technical-
document-summaries contains the heading element m2-2-introduction. The heading element m2-
2-introduction contains the leaf element for the CTD-introduction.pdf file.
<m2-common-technical-document-summaries>
<m2-2-introduction>
<leaf >
ID="a1234567"
operation="new"
checksum=" e854d3002c02a61fe5cbe92fd97b0018"
checksum-type="md5"
xlink:href="m2/CTD-introduction.pdf"
version="Version-1">
<title>Introduction to CTD Submission</title>
</leaf>
Version 1.1 9
The eCTD Backbone File Specification for Modules 2 through 5
</m2-2-introduction>
</m2-common-technical-document-summaries>
Some of the heading elements in the eCTD backbone file have attributes associated with them to
help in organizing the file information. Each of heading element attributes begins after the
heading element name with a space followed by the lowercase attribute name. The value for the
attribute is provided in a statement that begins with the equal sign and quotation mark, (="),
followed by the attribute's value and ending with a quotation mark. There should be no spaces in
the attribute's value statement.
Some of the attributes occur for more than one element. You should make sure that the attribute
values each of these elements are coordinated so that they are the same when appropriate. The
table, below, lists each heading element attribute name and the element or elements where it can
occur followed by the same information organized with the heading elements listed and their
associated attributes.
Version 1.1 10
The eCTD Backbone File Specification for Modules 2 through 5
<m3-2-a-2-adventitious-agents-safety-evaluation> manufacturer
substance
dosageform
product-name
<m5-3-5-reports-of-efficacy-and-safety-studies> indication
Each of the heading element attributes for the eCTD backbone file is described in detail in the
section of this appendix associated with the CTD module where the element and its attribute
occur.
The heading elements and heading element attributes for modules 2 through 5 are described
below.
This section describes the heading elements and attribute values relevant to module 2.
1. Heading elements
The module 2 heading elements are summarized in the following table. In some cases, the CTD
may describe more subheadings than appear on this table. Those subheadings should be used as
bookmarks within the individual document. Both the start tag and end tag for each heading
element are provided. If there are one or more subheadings for the heading, the corresponding
element end tag will occur on the table row below the last relevant subheading. The leaf element
is included to show where the leaf elements should be placed. The details for the leaf elements
are not shown on this table to keep it clearer. The leaf elements should only occur where
indicated in this table. A heading element may contain any number of leaf elements. If no
documents are submitted for a heading, you should omit the element for that heading in the
eCTD backbone file.
Module 2 CTD Heading heading element (leaf element abbreviated for clarity)
Module 2: Common Technical <m2-common-technical-document-summaries>
Document (CTD) Summaries
2.2 CTD Introduction <m2-2-introduction>
<leaf>
</leaf>
</m2-2-introduction>
Module 2: Quality Overall Summary <m2-3-quality-overall-summary>
(QOS) <leaf>
</leaf>
</m2-3-quality-overall-summary>
Module 2: Nonclinical Overview <m2-4-nonclinical-overview>
<leaf>
</leaf>
</m2-4-nonclinical-overview>
Module 2: Nonclinical Written and <m2-6-nonclinical-written-and-tabulated-summaries>
Version 1.1 11
The eCTD Backbone File Specification for Modules 2 through 5
Module 2 CTD Heading heading element (leaf element abbreviated for clarity)
Tabulated Summaries (NWTS)
2.6.1 Introduction <m2-6-1-introduction>
<leaf>
</leaf>
</m2-6-1-introduction>
2.6.2 Pharmacology Written <m2-6-2-pharmacology-written-summary>
Summary <leaf>
</leaf>
</m2-6-2-pharmacology-written-summary>
2.6.3 Pharmacology Tabulated <m2-6-3-pharmacology-tabulated-summary>
Summary <leaf>
</leaf>
</m2-6-3-pharmacology-tabulated-summary>
2.6.4 Pharmacokinetics Written <m2-6-4-pharmacokinetics-written-summary>
Summary <leaf>
</leaf>
</m2-6-4-pharmacokinetics-written-summary>
2.6.5 Pharmacokinetics <m2-6-5-pharmacokinetics-tabulated-summary>
Tabulated Summary <leaf>
</leaf>
</m2-6-5-pharmacokinetics-tabulated-summary>
2.6.6 Toxicology Written <m2-6-6-toxicology-written-summary>
Summary <leaf>
</leaf>
</m2-6-6-toxicology-written-summary>
2.6.7 Toxicology Tabulated <m2-6-7-toxicology-tabulated-summary>
Summary <leaf>
</leaf>
</m2-6-7-toxicology-tabulated-summary>
End NWTS </m2-6-nonclinical-written-and-tabulated-summaries>
Module 2: Clinical Overview <m2-5-clinical-overview>
<leaf>
</leaf>
</m2-5-clinical-overview>
Module 2: Clinical Summary (CS) <m2-7-clinical-summary>
2.7.1 Summary of <m2-7-1-summary-of-biopharmaceutic-studies-and-
Biopharmaceutic associated-analytical-methods>
Studies and Associated <leaf>
Analytical Methods </leaf>
</m2-7-1-summary-of-biopharmaceutic-studies-and-
associated-analytical-methods>
2.7.2 Summary of Clinical <m2-7-2-summary-of-clinical-pharmacology-studies>
Pharmacology Studies </m2-7-2-summary-of-clinical-pharmacology-studies>
2.7.3 Summary of Clinical <m2-7-3-summary-of-clinical-efficacy
Efficacy indication="">
Version 1.1 12
The eCTD Backbone File Specification for Modules 2 through 5
Module 2 CTD Heading heading element (leaf element abbreviated for clarity)
<leaf>
</leaf>
</m2-7-3-summary-of-clinical-efficacy>4
2.7.4 Summary of Clinical <m2-7-4-summary-of-clinical-safety>
Safety <leaf>
</leaf>
</m2-7-4-summary-of-clinical-safety>
2.7.5 References <m2-7-5-literature-references>
<leaf>
</leaf>
</m2-7-5-literature-references>
2.7.6 Synopses of Individual <m2-7-6-synopses-of-individual-studies>
Studies <leaf>
</leaf>
</m2-7-6-synopses-of-individual-studies>
End CS </m2-7-clinical-summary>
End CTD Summaries </m2-common-technical-document-summaries>
The heading element for the Summary of Clinical Efficacy heading, <m2-7-3-summary-of-
clinical-efficacy>, has an attribute called indication. The purpose of the indication attribute is to
provide human readable abbreviation of the clinical indication being summarized under this
heading. If there is more than one indication for which a Summary of Clinical Efficacy (SCE) is
being submitted, you should create an additional SCE heading element for each indication. Each
SCE heading element should be the same except for the unique indication attribute value and
leaf content. An example of two indication attributes and their values within two SCE heading
elements is provided:
<m2-common-technical-document-summaries>
<m2-7-clinical-summary>
<m2-7-3-summary-of-clinical-efficacy indication="pneumonia">
<leaf></leaf>5
</m2-7-3-summary-of-clinical-efficacy>
<m2-7-3-summary-of-clinical-efficacy indication="sepsis">
<leaf></leaf>6
</m2-7-3-summary-of-clinical-efficacy>
</m2-7-clinical-summary>
</m2-common-technical-document-summaries>
4
See the description of element attributes after this table
5
Leaf element abbreviated for clarity.
6
Leaf element abbreviated for clarity.
Version 1.1 13
The eCTD Backbone File Specification for Modules 2 through 5
You should provide an indication attribute value for every SCE heading element. There is no
limit to the number of SCE heading elements.
This section includes the heading elements and attribution values relevant to module 3.
The module 3 heading elements are summarized in the following table. In some cases, the CTD
may describe more subheadings than appear on this table. Those subheadings should be used as
bookmarks within the individual document. Both the start tag and end tag for each heading
element are provided. If there are one or more subheadings for the heading, the corresponding
element end tag will occur on the table row below the last relevant subheading. The leaf element
is included to show where the leaf elements should be placed. The details for the leaf elements
are not shown on this table to keep it clearer. The leaf elements should only occur where
indicated in this table. A heading element may contain any number of leaf elements. If no
documents are submitted for a heading, you should omit the element for that heading in the
eCTD backbone file.
7
See the description of element attributes after this table.
Version 1.1 14
The eCTD Backbone File Specification for Modules 2 through 5
Version 1.1 15
The eCTD Backbone File Specification for Modules 2 through 5
Version 1.1 16
The eCTD Backbone File Specification for Modules 2 through 5
8
See the description of element attributes after this table.
9
See the description of element attributes after this table.
Version 1.1 17
The eCTD Backbone File Specification for Modules 2 through 5
Version 1.1 18
The eCTD Backbone File Specification for Modules 2 through 5
10
See the description of element attributes after this table.
Version 1.1 19
The eCTD Backbone File Specification for Modules 2 through 5
Five of the Module 3 heading elements have attributes. You should provide attribute values for
each of these attributes.
The heading element for the Drug Substance heading, <m3-2-s-drug-substance>, has two
attributes, substance and manufacturer. The purpose of these attributes is to provide text to
indicate the drug substance name or names and organizational headings for different
manufacturers of the drug substance. These situations are more fully described in the Guidance
for Industry M4: The CTD-- Quality document. An example of two Drug Substance heading
elements for different manufacturers of the same drug substance is provided:
<m3-quality>
<m3-2-body-of-data>
<m3-2-s-drug-substance
substance="Cure All USP"
11
See the description of element attributes after this table.
Version 1.1 20
The eCTD Backbone File Specification for Modules 2 through 5
manufacturer="China-DMF-999999">
<leaf></leaf>12
</m3-2-s-drug-substance>
<m3-2-s-drug-substance
substance=" Cure All USP "
manufacturer="Louisiana">
<leaf></leaf>13
</m3-2-s-drug-substance>
</m3-2-body-of-data >
</m3-quality >
You should provide substance and manufacturer attribute values for every Drug Substance
heading element. There is no limit to the number of Drug Substance heading elements. There is
no limit to the number of leaf elements the Drug Substance heading element can contain.
The heading element for the Drug Product heading, <m3-2-p-drug-product>, has three attributes,
product-name, dosageform and manufacturer. The purpose of these attributes is to provide text
to indicate the drug product names and organizational headings for different dosage forms and
the organizational headings for different manufacturers of the drug product. These situations are
more fully described in the Guidance for Industry M4: The CTD-- Quality document. An
example of two Drug Product heading elements for different manufacturers of the same dosage
form and the same product name is provided:
<m3-quality>
<m3-2-body-of-data>
<m3-2-p-drug-product
product-name="Cure All"
dosageform="Injection"
manufacturer="China Plant 1 DMF-0000001">
<leaf></leaf>14
</ m3-2-p-drug-product >
<m3-2-p-drug-product
product-name="Cure All"
dosageform="Injection"
manufacturer="Puerto Rico Internal-Plant-#2">
<leaf></leaf>15
</m3-2-p-drug-product>
</ m3-2-body-of-data >
</m3-quality >
12
Leaf element abbreviated for clarity.
13
Leaf element abbreviated for clarity.
14
Leaf element abbreviated for clarity.
15
Leaf element abbreviated for clarity.
Version 1.1 21
The eCTD Backbone File Specification for Modules 2 through 5
You should provide product-name, dosageform and manufacturer attribute values for every Drug
Product heading element. There is no limit to the number of Drug Product heading elements.
There is no limit to the number of leaf elements the Drug Product heading element can contain.
c) Excipient Attribute
<m3-quality>
<m3-2-p-drug-product
product-name="Cure All"
dosageform="Injection"
manufacturer="China Plant 1 DMF-0000001">
<m3-2-p-4-control-of-excipients
excipient="corn syrup">
<m3-2-p-4-1-specifications>
<leaf></leaf>16
</m3-2-p-4-1-specifications>
<m3-2-p-4-2-analytical-procedures>
<leaf></leaf>17
</m3-2-p-4-2-analytical-procedures>
<m3-2-p-4-4-justification-of-specifications>
<leaf></leaf>18
</m3-2-p-4-4-justification-of-specifications>
</m3-2-p-4-control-of-excipients>
</m3-2-p-drug-product>
</m3-quality>
You should provide an excipient attribute value for every Control of Excipients heading element.
There is no limit to the number of Control of Excipients heading elements. There is no limit to
the number of leaf elements the Control of Excipients heading element can contain.
The heading elements for the Facilities and Equipment heading, <m3-2-a-1-facilities-and-
equipment> and for the Adventitious Agents Safety Evaluation heading, <m3-2-a-2-
16
Leaf element abbreviated for clarity.
17
Leaf element abbreviated for clarity.
18
Leaf element abbreviated for clarity.
Version 1.1 22
The eCTD Backbone File Specification for Modules 2 through 5
<m3-quality>
<m3-2-a-appendices>
<m3-2-a-1-facilities-and-equipment
manufacturer=" China Plant 1 DMF-0000001"
product-name="Cure All">
<leaf></leaf>19
</m3-2-a-1-facilities-and-equipment
<m3-2-a-2-adventitious-agents-safety-evaluation
manufacturer="Animal Extractions Inc"
substance="Parts Substrate"
dosageform="Injection">
<leaf></leaf>20
</m3-2-a-2-adventitious-agents-safety-evaluation>
</m3-2-a-appendices>
</m3-quality>
You should provide a manufacturer, and substance or product-name attribute and value for every
Facilities and Equipment heading element and manufacturer, dosageform and substance or
product-name, for every Adventitious Agents Safety Evaluation heading element. There is no
limit to the number of Facilities and Equipment heading and the Adventitious Agents Safety
Evaluation heading elements. There is no limit to the number of leaf elements the Facilities and
Equipment and the Adventitious Agents Safety Evaluation heading elements can contain.
This section includes the heading and attributes elements relevant to module 4.
1. Heading elements
The module 4 heading elements are summarized in the following table. In some cases, the CTD
may describe more subheadings than appear on this table. Those subheadings should be used as
bookmarks within the individual document. Both the start tag and end tag for each heading
element are provided. If there are one or more subheadings for the heading, the corresponding
element end tag will occur on the table row below the last relevant subheading. The leaf element
is included to show where the leaf elements should be placed. The details for the leaf elements
19
Leaf element abbreviated for clarity.
20
Leaf element abbreviated for clarity.
Version 1.1 23
The eCTD Backbone File Specification for Modules 2 through 5
are not shown on this table to keep it clearer. The leaf elements should only occur where
indicated in this table. A heading element may contain any number of leaf elements. If no
documents are submitted for a heading, you should omit the element for that heading in the
eCTD backbone file.
Version 1.1 24
The eCTD Backbone File Specification for Modules 2 through 5
Version 1.1 25
The eCTD Backbone File Specification for Modules 2 through 5
Version 1.1 26
The eCTD Backbone File Specification for Modules 2 through 5
An example of the elements used to organize the leaf element for the Embryo Fetal Development
Toxicology heading document is provided:
<m4-nonclinical-study-reports>
<m4-2-study-reports>
<m4-2-3-toxicology>
<m4-2-3-5-reproductive-and-developmental-toxicity>
<m4-2-3-5-2-embryo-fetal-development>
<leaf></leaf>21
</m4-2-3-5-2-embryo-fetal-development>
21
Leaf element abbreviated for clarity.
Version 1.1 27
The eCTD Backbone File Specification for Modules 2 through 5
</m4-2-3-5-reproductive-and-developmental-toxicity>
</m4-2-3-toxicology>
</m4-2-study-reports>
</m4-nonclinical-study-reports>
The number of leaf elements that the heading elements can contain is not limited.
This section includes the heading elements and attributes relevant to module 5.
The module 5 heading elements are summarized in the following table. In some cases, the CTD
may describe more subheadings than appear on this table. Those subheadings should be used as
bookmarks within the individual document. Both the start tag and end tag for each heading
element are provided. If there are one or more subheadings for the heading, the corresponding
element end tag will occur on the table row below the last relevant subheading. The leaf element
is included to show where the leaf elements should be placed. The details for the leaf elements
are not shown on this table to keep it clearer. The leaf elements should only occur where
indicated in this table. A heading element may contain any number of leaf elements. If no
documents are submitted for a heading, you should omit the element for that heading in the
eCTD backbone file.
Version 1.1 28
The eCTD Backbone File Specification for Modules 2 through 5
Version 1.1 29
The eCTD Backbone File Specification for Modules 2 through 5
22
See the description of element attributes after this table.
Version 1.1 30
The eCTD Backbone File Specification for Modules 2 through 5
The heading element for the Reports of Efficacy And Safety Studies (ES) heading, <m5-3-5-
reports-of-efficacy-and-safety-studies >, has an attribute called indication. The purpose of the
indication attribute is to provide abbreviation of the clinical indication being summarized under
this heading. If there is more than one indication being claimed, you should create an additional
ES heading element for each indication. Each ES heading element should be the same except for
the unique indication attribute value and leaf content.
Version 1.1 31
The eCTD Backbone File Specification for Modules 2 through 5
The indication attribute for the ES heading element begins after the element name with a space
and the lowercase word indication. The value for the indication attribute is provided in a
statement that begins with the equal sign and quotation mark, (="), followed by the indication
attribute value and ending with a quotation mark. There should be no spaces in the indication
attribute's value statement. An example of two indication attributes and their values within two
ES heading elements is provided:
<m5-clinical-study-reports>
<m5-3-clinical-study-reports>
<m5-3-5-reports-of-efficacy-and-safety-studies
indication="pneumonia ">
<leaf></leaf>23
</m5-3-5-reports-of-efficacy-and-safety-studies >
<m5-3-5-reports-of-efficacy-and-safety-studies
indication="sepsis">
<leaf></leaf>24
</m5-3-5-reports-of-efficacy-and-safety-studies>
</m5-3-clinical-study-reports>
</m5-clinical-study-reports>
You should provide an indication attribute value for every ES heading element. There is no limit
to the number of ES heading elements. There is no limit to the number of leaf elements the ES
heading element can contain.
23
Leaf element abbreviated for clarity.
24
Leaf element abbreviated for clarity.
Version 1.1 32
SECTION 10
Revision History
Date Version Summary of Changes
2003-08-13 1.0 Original version
2004-03-09 1.1 Clarifications to the original version. Constrains from original version
including redundancy of information found in the index.xml file. Added
duration category and values. Added "other" as route of administration
value. Added new name attribute values for file tag element.
Versions between 1.1 and 2.6 have been unpublished drafts
2004-11-17 2.6 Provides specification for both Cumulative and Accumulative
Approaches for presentation of the Study Tagging Files (STF) with
more detailed examples showing index and stf file relationships.
Introduces ich-stf-v2-2.dtd, ich-stf-stylesheet-2-2.xsl and valid-
values.xml.
2005-07-25 2.6 Posting for FDA. Removed Cumulative Approach for STF Lifecycle
and added US regional name attribute value “individual-subject-data-
listing”. Also reinstituted "nonclinical-data" as US specific tag and
marked "pre-clinical-study-reports" as not used in US.
Page 1
FDA Implementation of STF DTD v2.2
An STF should be provided with the submission of any file, or group of files belonging to
a study in Modules 4 and 5. The STFs are required by the United States, but are optional
in Europe and Japan. The STF provides for additional heading elements and heading
attributes not currently provided by the eCTD DTD. In the STF, heading elements are
called file-tags and are included in the doc-content element. Heading attributes are
included in the study-identifier element.
The STF is an XML instance controlled by the ICH STF Document Type Definition
(DTD). The most recent DTD can be found on the ICH web site (www.ich.org). The
DTD should be placed in the dtd subfolder of the util folder. Version 2.2 of the STF DTD
introduces a revised stylesheet and an XML file named, valid-values.xml, which should
be in the style subfolder of the util folder. You should provide a separate STF for each
study in a submission. The name for the STF XML file should start with the term "stf-"
followed by the alphanumeric code used by the sponsor to unambiguously identify the
study (i.e., study-id described below) and followed by ".xml" to complete the file name.
For every submission to FDA that includes one or more files pertaining to a specific
study, you should provide an STF. You should place the STF for the specific study in the
module folder with the corresponding study files. You should place a leaf element in the
Module 4 or 5 eCTD index.xml file for each STF. In the corresponding Module 4 or 5
eCTD index.xml file, the STF’s operation attribute should have a value of "new" for the
first STF for a specific study and "append" for any subsequent STF for the same study
(see "Lifecycle Management of the Study Tagging File". NOTE: STF files submitted to
the FDA should use the accumulative method of STF files even though the ICH version
of the Study Tagging File Specification v2.6 allows for both a cumulative and
accumulative approach). Use the study identifier (i.e., study-id described below) in the
title of the leaf. The STF should only include information on the study documents being
provided or modified within the new submission.
Page 3
FDA Implementation of STF DTD v2.2
The STF root element is ectd:study. The prolog part of the STF XML document and the
STF root element contain information about the following:
1. Version of XML being used
2. Type of characters that are allowed in the file
3. Location of the standards that control the organization of the STF
4. Indication that the file information is ended (end tag)
A sample of the root element and last line of the STF is provided below:
Note: "../../../../" in the path expressions for STF DTD and STF stylesheet depend on
the location where the STF instance is stored.
The STF root element contains two child elements: study-indentifier and study-
document.
Information describing the study is contained in the study-identifier element of the STF.
There are three elements contained in the study-identifier element: title, study-id, and
category.
A. Title Element
The title element provides the full title of the study, not the title of each individual
document. This is the name of the study and all related component study report files that
comprise the study report.
B. study-id Element
The study-id is the internal alphanumeric code used by the sponsor to unambiguously
identify this study.
C. Category Element
The category element provides an additional level of study organization not currently
provided by the eCTD DTD. This element is only relevant for studies provided in the
specific CTD sections cited below.
Page 4
FDA Implementation of STF DTD v2.2
1
Please consult the regional authorities before using "other".
Page 5
FDA Implementation of STF DTD v2.2
The following is an example of the use of the study-identifier elements in an STF for a
long term carcinogenicity study conducted in mice (species="mouse"):
<study-identifier>
<title>Long term carcinogenicity study</title>
<study-id>abc123xyz789</study-id>
<category name="species" info-type="ich" >mouse</category>
<category name="duration" info-type="us" >long</category>
</study-identifier>
The study-document element2 contains information on the subject matter of each file that
is cited as part of the documentation for a study. The study-document element includes
the doc-content element. The doc-content element contains the property and file-tag
elements.
A. Property element
The property element is appropriate when files might need to be grouped by an applicant
provided value. Currently, this element is only to be used for site identification within a
study. For example, in the submission of case-report-forms, multiple forms originating
from the same study site should all be grouped by the study site property element.
B. File-tag element
The file-tag element contains the attributes name and info-type. The text value of the file-
tag element's name attribute indicates the subject matter of the document. The value of
the file-tag name attribute should be selected from the values in the table below. For the
value of the info-type attribute, you should use "ich" if using an ICH value or one of the
2
The ICH STF Specification v2.6 includes a second element named block-content. However STF files
submitted to FDA should not utilize the block-content construct.
Page 6
FDA Implementation of STF DTD v2.2
regional values if the value is not defined in ICH. The table below shows the specified
name attribute values for the file-tag element.
3
Refer to M4: Organisation Document, Granularity Annex for instructions on how to typically construct
study reports.
4
FDA does not use this STF tag value – use the US specific "nonclinical-data" tag instead
Page 7
FDA Implementation of STF DTD v2.2
Page 8
FDA Implementation of STF DTD v2.2
When submitting in the US using a file-tag element with the name attribute value of
"subject-profile" or "case-report-forms", you should include a property element with the
name attribute value "site-identifier" and info-type value "us". The content of the property
element should be text that identifies the site.
Page 9
FDA Implementation of STF DTD v2.2
A. Cumulative Approach
B. Accumulative Approach
In the accumulative approach, the applicant does not need to submit a complete
enumeration of the categories, file-tags and leaf ID values for the files that comprise the
Study Report with each submission. The STF would contain only the changes needed to
be made. When submitting the changes to the study report in the accumulation approach
the operation attribute value of the leaf entry for the subsequent STF should be "append".
The study-document information provided in this subsequent STF should only relate to
what is being modified in the current submission relative to the last submission for the
same STF.
<m4-2-1-1-primary-pharmacodynamics>
<leaf checksum-type="MD5"
version="STF Version 2.2" xlink:type="simple"
checksum="421e55366d62fad0e9510f6aed005272" operation="append"
xlink:href="m4/42-stud-rep/421-pharmacol/4211-prim-pd/stf-jm-12-345.xml"
modified-file="../0000/index.xml#m12345"
ID="m42111">
<title>jm-12-345 Study Tagging File</title>
</leaf>
</m4-2-1-1-primary-pharmacodynamics>
Applicants should contact regional health authorities for the method to be used when
modifying STFs.
For example, an applicant submits an STF for a single-dose oral toxicity study (Study No.
JM-12-345) in serial 0001. The index.xml would contain a leaf entry for this file as
follows:
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="421e55366d62fad0e9510f6aed005272" operation="new"
xlink:href="m4/42-stud-rep/423-tox/4231-single-dose-tox/stf-jm-12-345.xml"
ID="idm42111-0002">
<title>Study No. JM-12-345 STF</title>
</leaf>
<study-identifier>
<title>Single dose oral toxicity study in the mouse and dog</title>
<study-id>jm-12-345</study-id>
<category name = "species" info-type = "ich">rat</category>
<category name = "species" info-type = "ich">dog</category>
<category name = "route-of-admin" info-type = "ich">oral</category>
</study-identifier>
Clearly, the species identified by the species category tags are incorrect.
To correct this information, the applicant would submit a corrected STF in a subsequent
submission. The approach used to manage the STFs (Cumulative or Accumulative)
would determine the specific course of action.
Cumulative Approach
FDA does not use the Cumulative Approach for Study Tagging Files.
Accumulative Approach
In the Accumulative Approach, the information contained in subsequent STFs is
combined with the information contained in previous STFs to provide the reviewer the
‘cumulative’ view of all information. As there is no mechanism for comparing the
information contained in the study-identifier sections of the STFs submitted over time
using the Accumulative Approach, the information contained in the study-identifier
Page 11
FDA Implementation of STF DTD v2.2
section of the most recent STF will be deemed the most current. This applies to all
information contained in the study-identifier section of the STF (title, study-id and
category tags).
In order to correct the study-identifier information cited above for Study JM-12-345
using the Accumulative Approach, an additional STF would be submitted containing the
corrected information.
The index.xml in this subsequent submission (0002) would contain a leaf for the new
STF as follows:
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="421e55366d62fad0e9510f6aed005272" operation="append"
xlink:href="m4/42-stud-rep/423-tox/4231-single-dose-tox/stf-jm-12-345.xml"
modified-file="../0001/index.xml# idm42111-0002"
ID="a345">
<title>Study No. JM-12-345 STF</title>
</leaf>
If there was no additional documentation being provided for this study (and thus the
purpose of this STF is solely to correct the erroneous study-identifier information), the
STF would contain the following:
Note: "../../../../" in the path expressions for STF DTD and STF stylesheet depend on the
location where the STF instance is stored.
Note: The entire study-identifier block should be resubmitted containing all the category
values. The <study-document/> indicates that no additional file-tags are being provided and
is required since the study-document element is a mandatory element.
Page 12
FDA Implementation of STF DTD v2.2
Cumulative Approach
FDA does not use the Cumulative Approach for Study Tagging Files.
Accumulative Approach
Using the Accumulative Approach, the applicant should submit an STF referencing only
the study related files provided in the current submission.
The index.xml for this submission should contain leaf entries for each new file being
provided as well as a leaf for the STF. The leaf of this STF should be submitted with the
‘append’ operation and modify the original STF for the study.
Cumulative Approach
FDA does not use the Cumulative Approach for Study Tagging Files.
Accumulative Approach
Using the Accumulative Approach, the applicant should submit an STF referencing only
the study-related files provided in the current submission.
The index.xml for this submission should contain leaf entries for each new file being
provided as well as a leaf for the STF.
The leaf of this STF should be submitted with the ‘append’ operation and would modify
the original STF for the study.
The leaf entries for the content files being provided in this submission should utilize the
‘replace’ operation as detailed in the eCTD Specifications.
The files that have been replaced in this submission will still be referenced by the pre-
existing STFs for the study but these files will no longer show as ‘current’ because they
have been replaced in the backbone of the application.
Page 13
FDA Implementation of STF DTD v2.2
Cumulative Approach
FDA does not use the Cumulative Approach for Study Tagging Files.
Accumulative Approach
When a file is to be deleted from an STF but the file still needs to remain in the backbone
of the application (e.g., it is referenced by another STF), the index.xml for this
submission should contain a leaf entry with operation "delete" and the modified-file
attribute should include the index.xml#leafID for the instance to be deleted. No additional
STF file would be called for, since the file will be flagged as deleted in this instance.
Cumulative Approach
FDA does not use the Cumulative Approach for Study Tagging Files.
Accumulative Approach
When an applicant determines that an incorrect file-tag value has been assigned to a study
report component file in the STF, the applicant should "delete" the incorrectly tagged file
in the index.xml (to remove the file from any STF referencing it) and then reactivate the
file in the backbone by including a second leaf with the operation value "new". The file
does not need to be resubmitted; the reactivating xlink:href attribute points back to the
original location of the file.
Then, an STF referencing this new leaf entry should be submitted with the corrected file
tag value.
In the following example the applicant inadvertently tagged the synopsis file as a legacy-
clinical-study-report in submission serial 0000 and corrects the error in submission 0003.
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
Page 14
FDA Implementation of STF DTD v2.2
checksum="421e55366d62fad0e9510f6aed005272" operation="new"
xlink:href="m4/42-stud-rep/423-tox/4231-single-dose-tox/synopsis-of-jm-12-345.pdf"
application-version="PDF 1.3"
ID="m42111">
<title>jm-12-345 Study Synopsis</title>
</leaf>
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="421e55366d62fad0e9510f6aed005272" operation="new"
xlink:href="m4/42-stud-rep/423-tox/4231-single-dose-tox/stf-jm-12-345.xml"
application-version="PDF 1.3"
ID="m42112">
<title>Study JM-12-345 STF</title>
</leaf>
<study-document>
<doc-content xlink:href = "../../../index.xml#m42111">
<file-tag name = "legacy-clinical-study-report" info-type = "ich"/>
</doc-content>
</study-document>
In the serial 0003 index.xml, delete the incorrect file-tag by deleting the file from the
index.xml which logically deletes the legacy-clinical-study-report file-tag associated with
it in the STF:
<leaf operation="delete"
checksum="" checksum-type="MD5"
modified-file="../0000/index.xml#m42111"
ID="idm4211stf">
<title/>
</leaf>
Then, add the file as "new" citing the location in the 0000 serial submission - there is no
need to send a second copy of the file:
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="421e55366d62fad0e9510f6aed005272" operation="new"
xlink:href="../0000/m4/42-stud-rep/423-tox/4231-single-dose-tox/synopsis-of-jm-12-
345.pdf"
application-version="PDF 1.3"
<title>jm-12-345 Study Synopsis</title>
ID="r34567">
</leaf>
Page 15
FDA Implementation of STF DTD v2.2
Finally, include a new STF (using the "append" operation) and associate the correct
synopsis file-tag to the file.
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="421e55366d62fad0e9510f6aed005272" operation="append"
xlink:href="m4/42-stud-rep/423-tox/4231-single-dose-tox/stf-jm-12-345.xml"
modified-file="../0000/index.xml#m42112"
ID="r6789">
<title>Study JM-12-345 STF</title>
</leaf>
In the serial 0003 STF for JM-12-345, include the study-id tag to identify the study
report being modified and include the corrected file-tag metadata:
In most situations, one study would generate one STF and the information generated from
the study would reside together with the STF in the most appropriate subsection of the
CTD. However, there are certain situations where one study should generate more than
one STF representation. These situations might exist where:
• different analyses with distinct life-cycle management needs co-exist and should
be distinguishable within the same section of the dossier
• a study generates information that should be presented in a different subsection of
the CTD.
Page 16
FDA Implementation of STF DTD v2.2
Filing all of this information (separate sets of analysis and supportive appendices
and datasets) under just one section of the dossier is considered unsatisfactory, as
there would be no method to associate the ‘secondary’ information to the proper
section of the CTD. An approach might be to include the same “all-inclusive”
STF in both locations to alert the reviewers that there is information contained in
the STF applicable to more than one section of the CTD. However, this creates an
additional burden on the reviewer in identifying which datasets, listings and
appendices are relevant to the PK assessment and which are relevant to the full
safety\efficacy analysis.
Thus, an applicant should have the optional ability to organize these different sets
of information as discrete units by creating a second STF for the same study.
Page 17
FDA Implementation of STF DTD v2.2
Information that is shared by the two analyses (e.g., protocol, Case Report Form)
would be referenced by each STF while information that supports different
sections of the dossier could be clearly organized and submitted in the appropriate
CTD section. This is especially beneficial to applicants preparing two distinct
study reports for the study (one presenting the safety\efficacy analysis on all
patients and one presenting the pharmacokinetic analysis on the subset of patients
who participated in that part of the study).
This section provides a series of sample submissions related to the same study and
illustrates how they would be accomplished using the Cumulative and Accumulative STF
approaches. Since FDA doe not use the Cumulative approach, the following instructions
are for the Accumulative approach.
Submission 0000
An applicant is providing information on a placebo-controlled study in the treatment of
nausea titled "Wonderdrug Study S107" performed under their in-house unique
identification "S107". In submission sequence number 0000, the applicant provides
interim study results in the form of an interim synopsis, the body of the interim study
report and the protocol for the study.
The index.xml for submission 0000 would contain four leaf entries; one for each content
file and one for the STF for the study as follows:
<m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-claimed-
indication>
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="421e55366d62fad0e9510f6aed005272" operation="new"
xlink:href="m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/synopsis.pdf"
application-version="PDF 1.3"
ID="a101">
<title>S107 Study Synopsis - Interim Results</title>
</leaf>
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="88e3be3f2d026b572625ab81ef5b068c" operation="new"
xlink:href=" m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/study-report-body.pdf"
application-version="PDF 1.3"
ID="a102">
<title>S107 Study Report Body - Interim Results</title>
</leaf>
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
Page 18
FDA Implementation of STF DTD v2.2
checksum="98723f7594b5500a861509547c384e46" operation="new"
xlink:href=" m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/protocol.pdf"
application-version="PDF 1.3"
ID="a103">
<title>S107 Study Protocol</title>
</leaf>
<leaf checksum-type="MD5"
version="STF Version 2.2" xlink:type="simple"
checksum="25d3b246313a9dbf688a48da2295260e" operation="new"
xlink:href=" m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/stf-s107.xml"
ID="a104">
<title>Study Tagging File for S107</title>
</leaf>
</m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-claimed-
indication>
The STF provided in submission 0000 is named "stf-s107.xml" and contains the
following information about the documentation being provided for study S107:
Note: "../../../../" in the path expressions for STF DTD and STF stylesheet depend on the
location where the STF instance is stored.
Note: The type of control for this study was intentionally cited as “no-treatment” even
though the study is a placebo-controlled study. This will be corrected in a subsequent
submission (see submission 0002).
Page 19
FDA Implementation of STF DTD v2.2
Submission 0001
In a subsequent submission, the sponsor wishes to provide additional documentation on
Study S107. In submission 0001, the Sponsor provides the Sample Case Report Form and
a protocol amendment.
The index.xml for submission 0001 would contain three leaf entries; one for each content
file (i.e., the protocol amendment and the Sample CRD) and one for the STF. The leaf
entries for the new content files would be identical whether the Sponsor chooses to use
the Cumulative or Accumulative approaches. The leaf entry for the STF and the content
of the STF would differ depending on which approach was utilized.
Cumulative Approach
FDA does not use the Cumulative Approach for Study Tagging Files.
Accumulative Approach
The index.xml for submission 0001 would contain three leaf entries; one for each content
file (i.e., the protocol amendment and the Sample CRD) and one for the STF which
updates the previously submitted STF as shown here:
<m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-claimed-
indication>
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="421e55366d62fad0e9510f6aed005272" operation="new"
xlink:href="m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/protamend01.pdf"
application-version="PDF 1.3"
ID="a567">
<title>S107 Protocol Amendment No. 1</title>
</leaf>
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="88e3be3f2d026b572625ab81ef5b068c" operation="new"
xlink:href=" m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/samplecrf.pdf"
application-version="PDF 1.3"
ID="a568">
<title>S107 Sample Case Report Form</title>
</leaf>
<leaf checksum-type="MD5"
version="STF Version 2.2" xlink:type="simple"
checksum="25d3b246313a9dbf688a48da2295260e" operation="append"
xlink:href=" m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/stf-s107.xml"
modified-file="../0000/index.xml#a104"
ID="a569">
Page 20
FDA Implementation of STF DTD v2.2
The new STF is also named "stf-s107.xml" and summarizes only the new information
being provided in this submission as follows:
Note: "../../../../" in the path expressions for STF DTD and STF stylesheet depend on the
location where the STF instance is stored.
Submission 0002
In a subsequent submission, the sponsor wishes to provide additional documentation on
Study S107. In submission 0002, the Sponsor provides the final study report and synopsis
plus CRF files for two patients who died during the conduct of the study. In addition, it
was finally noticed that the previous STFs had incorrectly identified the study as an
uncontrolled study when, in fact, it was placebo-controlled.
Cumulative Approach
FDA does not use the Cumulative Approach for Study Tagging Files.
Accumulative Approach
The index.xml for submission 0002 would contain five leaf entries; one for each content
file (i.e., synopsis, study report and two patient CRF files) and one for the STF which
would append the previously submitted STF as shown here:
Page 21
FDA Implementation of STF DTD v2.2
<m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-claimed-
indication>
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="421e55366d62fad0e9510f6aed005272" operation="replace"
xlink:href="m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/synopsis.pdf"
modified-file="../0000/index.xml#a101"
application-version="PDF 1.3"
ID="r345">
<title>S107 Study Synopsis - Final</title>
</leaf>
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="88e3be3f2d026b572625ab81ef5b068c" operation="replace"
xlink:href=" m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/s107body.pdf"
modified-file="../0000/index.xml#a102"
application-version="PDF 1.3"
ID="r346">
<title>S107 Study Report - Final</title>
</leaf>
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="421e55366d62fad0e9510f6aed005272" operation="new"
xlink:href="m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/crf/11/12.pdf"
application-version="PDF 1.3"
ID="r347">
<title>CRF for Subject S107-11-12</title>
</leaf>
<leaf checksum-type="MD5"
version=" " xlink:type="simple"
checksum="88e3be3f2d026b572625ab81ef5b068c" operation="new"
xlink:href=" m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/crf/162/5045.pdf"
application-version="PDF 1.3"
ID="r348">
<title>CRF for Patient S107-162-5045</title>
</leaf>
<leaf checksum-type="MD5"
version="STF Version 2.2" xlink:type="simple"
checksum="25d3b246313a9dbf688a48da2295260e" operation="append"
xlink:href=" m5/53-clin-stud-rep/535-rep-effic-safety-stud/nausea/5351-stud-rep-
contr/study-s107/stf-s107.xml"
modified-file="../0001/index.xml#a569"
ID="r349">
<title>Study Tagging File for S107</title>
</leaf>
Page 22
FDA Implementation of STF DTD v2.2
</m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-claimed-
indication>
The new STF is named "stf-s107.xml" and identifies the additional documentation
provided for Study S107 in this submission. The information in this STF also corrects the
erroneous “type-of-control” category tag to “placebo” as follows:
Note: "../../../../" in the path expressions for STF DTD and STF stylesheet depend on the
location where the STF instance is stored.
Page 23
SECTION 11
Contents
Introduction......................................................................................................................... 1
Scope ............................................................................................................................... 1
Purpose ............................................................................................................................ 1
Members .......................................................................................................................... 1
Introduction
At the September 2002 ICH Steering Committee meeting, the ICH M2 Expert Working
Group (EWG) presented the signed Step 3 eCTD Specification for Step 4 consideration
by the ICH Steering Committee. The Steering Committee signed the specification to Step
4 and tasked the M2 EWG to also be the Implementation Working Group (IWG) for the
eCTD Specification. To implement the eCTD across all three regions, change control
should be in place to effectively communicate and execute changes to the eCTD
Specification.
Scope
This document establishes the change control process for the eCTD Specification.
Change control for regional eCTD Module 1 specifications is the regional authority’s
responsibility.
Purpose
The eCTD IWG is authorised by the ICH Steering Committee to administer changes to
the eCTD Specification. Change control is established to serve the following purposes:
• Evaluate and approve or disapprove proposed changes to the eCTD Specification
• Ensure implementation of approved changes
• Represent the interests of all groups who might be affected by changes
Members
The eCTD IWG consists of a Topic Leader, Deputy Topic Leader, and Experts from each
of the six ICH parties, and ICH observers. The Steering Committee can also nominate, or
the eCTD IWG can request, additional members to work with the eCTD IWG to support
eCTD change control.
These members of the eCTD IWG are responsible for performing functions related to
eCTD change control.
Rapporteur
The eCTD IWG Rapporteur will be responsible for:
• Organising and presenting change requests to eCTD IWG in RTF format
• Presenting results of eCTD change control meetings to ICH Steering Committee
• Ensuring results of change control meetings are posted on the ICH Web site
(www.ich.org)
• Identifying change requests in the eCTD Q&A document
1
ICH eCTD Specification Change Control V1.8
Experts
Experts from each region will be responsible for:
• Defining issues related to change requests
• Providing practical solutions
Secretary
The eCTD IWG Secretary will be responsible for:
• Recording approved change requests
• Recording change control meeting minutes
Change Requests
Change requests can originate in ICH CTD change control or through eCTD
implementation, as follows:
1. During CTD change control process, CTD IWGs should consult with the eCTD IWG.
All change requests from a CTD IWG should be documented, showing concurrence
of all ICH parties, including the eCTD IWG, and should receive Steering Committee
approval prior to being submitted to the eCTD IWG as a change request. The eCTD
IWG Rapporteur should make CTD changes a high priority on the eCTD change
control list.
2. For change requests originating in an ICH region, the change request could be
submitted by any interested party to an eCTD IWG member from their region.
Change requests from non-ICH regions can be forwarded to the eCTD IWG
Rapporteur or the ICH Secretariat. Prior to being submitted to the eCTD IWG, the
proposed change should undergo any necessary testing by the eCTD IWG parties in
the region sponsoring the request. Change requests should then be forwarded to the
eCTD IWG Rapporteur for tracking, submission, and resolution.
A change request form is provided in Appendix A. The form is for change requests
originating outside of ICH.
2
ICH eCTD Specification Change Control V1.8
Emergency Meetings
Any member of the eCTD IWG can request that the Rapporteur schedule an emergency
eCTD change control meeting.
• Any change requests requiring testing will be assigned to a sub group of the eCTD
IWG
• Change requests not requiring additional testing will be sent to the eCTD IWG prior
to the next change control meeting
• A discussion of the disposition of a change request with input from each ICH party
will occur at the change control meetings. Any requests that required testing will be
presented by the sub group assigned to the testing. This discussion can involve CTD
review if additional information on the initial change request and/or proposed
solution is warranted.
After the discussion, the change request would take one of the following paths:
• Is not relevant
• Involves a significant new concept
• Involves the M2 EWG or other ICH groups and the ICH step process to make the
necessary eCTD change
3
ICH eCTD Specification Change Control V1.8
2. Defined as in the scope of the eCTD IWG: can be processed by the eCTD IWG and
would take one of the following paths:
• Approved by a unanimous vote from all six ICH parties
– Specification change
– Q&A document
• Deferred to
– Next change control meeting
• Assigned to a subgroup for testing
• Rejected
Additional testing may be called for before a change request can be fully evaluated.
When a change request is assigned for testing, a particular ICH party, or members from
each party, can be assigned to test the change request. The change request would stay on
the eCTD change control agenda and be presented at the next change control meeting for
additional review.
Documentation
Once approved by the Steering Committee, the following documentation would be
posted on the ICH Web site:
• New Version of the eCTD Specification
• Updated change request tracking document that includes the status of approved,
rejected, and deferred requests
4
ICH eCTD Specification Change Control V1.8
Major Releases
Major new releases of the eCTD Specification will be announced at least two years
before Step 4. Major releases include changes that significantly impact the DTD,
completely modify the eCTD architecture, or significantly impact the software
applications being used in the three regions. These major releases will be addressed by
the M2 Expert Working Group (EWG) and follow the ICH step process. Following this
process allows comments from parties external to ICH.
Minor Releases
In between major releases of the ICH eCTD Specification, the eCTD Implementation
Working Group (IWG) could also release new, minor releases of the ICH eCTD
Specification. The scope of these minor releases will be to correct minor issues with the
specification that hinder eCTD implementation or software application development.
Since these are minor modifications to the eCTD Specification, notification will occur
when the minor release is published on the ICH Web site.
Minor releases will continue the numbering sequence of the last major release (e.g., 4.1).
Version Compatibility
Backwards compatibility will be considered for each eCTD Specification release.
Descriptions of the scope of each change will be provided with each new release.
SECTION 12
Version 1.8
This form should be used to request a change to the ICH eCTD Specification. The
change can be to fix a perceived “bug”, meet a new requirement or to enhance existing
functionality. Please provide the following information.
Contact Information
Organisation Name:
Organisation
Address:
Contact Name:
Address:
Telephone Number:
E-mail Address:
Submit a completed copy of this form to an eCTD IWG member in your region in RTF
format. Those not residing in an ICH region can forward this request to the eCTD IWG
Rapporteur or to the ICH Secretariat at the following address. An electronic copy is
preferred with the subject field “eCTD Change Request”.
ICH Secretariat
c/o IFPMA,
30 rue de St-Jean
P.O. Box 758
1211 Geneva 13, Switzerland
Tel: +41 (22) 338 32 06, Telefax: +41 (22) 338 32 30
E-mail : ich@ifpma.org
SECTION 13
ICH M2 EWG
Introduction
The ICH M4 Expert Working Group (EWG) has defined the Common Technical Document (CTD). The
ICH M2 EWG has defined, in the current document, the specification for the Electronic Common
Technical Document (eCTD). The eCTD is defined as an interface for industry to agency transfer of
regulatory information while at the same time taking into consideration the facilitation of the creation,
review, lifecycle management and archival of the electronic submission. The eCTD specification lists the
criteria that will make an electronic submission technically valid. The focus of the specification is to
provide the ability to transfer the registration application electronically from industry to a regulatory
authority. Industry to industry and agency to agency transfer is not addressed.
The specification is divided into a series of main sections followed by a number of appendices in which
detailed technical specifications are given
Background
The specification for the eCTD is based upon content defined within the CTD issued by the ICH M4 EWG.
The CTD describes the organization of modules, sections and documents. The structure and level of detail
specified in the CTD have been used as the basis for defining the eCTD structure and content but where
appropriate, additional details have been developed within the eCTD specification.
The philosophy of the eCTD is to use open standards. Open standards, including proprietary standards,
which through their widespread use can be considered de facto standards, are deemed to be appropriate in
general.
Scope
The CTD as defined by the M4 EWG does not cover the full submission that is to be made in a region. It
describes only modules 2 to 5, which are common across all regions. The CTD does not describe the
content of module 1, the Regional Administrative Information and Prescribing Information, nor does it
describe documents that can be submitted as amendments or variations to the initial application.
The value of producing a specification for the creation of an electronic submission based only upon the
modules described in the CTD would be limited. Therefore, the M2 EWG has produced a specification for
the eCTD that is applicable to all modules of initial registration applications and for other submissions of
information throughout the lifecycle of the product, such as variations and amendments.
This document describes the parts of the registration application that are common to all regions and some
of the lifecycle requirements for products. The parts of the registration application that are specific to a
region will be covered by regional guidance. However, this backbone has been developed to handle both
the regional and common parts of submissions.
Requirements
The specification is designed to support high-level functional requirements such as the following:
Page 1
ICH eCTD Specification V 3.2 February 04, 2004
Change Control
The specification for the eCTD is likely to change with time. Factors that could affect the content of the
specification include, but are not limited to:
• Change in the content of the CTD, either through the amendment of information, at the same level
of detail, or by provision of more detailed definition of content and structure
• Change to the regional requirements for applications that are outside the scope of the CTD
• Updating standards that are already in use within the eCTD
• Identification of new standards that provide additional value for the creation and/or usage of the
eCTD
• Identification of new functional requirements
• Experience of use of the eCTD by all parties
Details of the change control management are described in an external ICH document.
Page 2
Appendix 1: Overall Architecture
Guiding Design Principles
This appendix defines the basic principles that drove the design and architecture of the eCTD. Detailed
specifications are defined in appendices 2 and 6.
Business Model
The business process to be supported can be described as follow:
The primary focus of the eCTD is to provide a data interchange message between industry and agencies.
Industry initiates the process by creating the initial submission in terms of an electronic CTD. Throughout
the lifecycle of this process, additional information will be submitted to update or modify the information
contained in the initial submission (e.g., supplement, amendment, variation.) The agency can submit
acknowledgements, queries and requests to industry. These are considered simple messages using
electronic mail or other transport formats. The overall architecture of the eCTD is designed to provide a
commonly agreed upon submission and submission structure that imposes minimal restriction to the
industry and agencies.
The XML instance of any submission should be created and validated according to the XML eCTD DTD as
defined in appendix 8.
The XML eCTD DTD describes the hierarchical structure according to the CTD as defined by the ICH M4
Expert Working Group. It includes multiple hierarchical levels depending on the specific module as
defined in the CTD. The actual submission can include more hierarchical levels below those defined in the
CTD. The XML eCTD instance covers the entire submission including all hierarchical levels and includes
references to each individual file.
The submission should include a Stylesheet that supports presentation of the XML instance, navigation
according to the table of contents, and provides access to all documents within the submission. A standard
Stylesheet for viewing the eCTD submission is defined and provided by the ICH M2 EWG. Presentation
and navigation via other Stylesheets on the receiving side should be possible.
The XML eCTD DTD includes a reference for each document to the physical file within the folder
structure. The XML eCTD DTD includes attributes for descriptive names of folders and documents.
Page 1-1
Multiple Region Support
The scope of each submission is global according to the Common Technical Document, meaning that
modules 2 through 5 of a submission are intended for all regions with the exception of selected documents
(e.g., in the quality module), which have a regional scope. Module 1 of a submission is regional in nature.
The DTD as defined by the ICH M2 expert working group specifies the structure of the common parts of
the eCTD primarily focusing on module 2 through 5. It allows linking to regional DTDs for module 1,
which will be defined by the authorities in each region.
Lifecycle Management
The applicant creates a submission that is stored in a local repository. The applicant submits the initial
submission to the agency, which imports the submission into another local repository. The nature and kind
of the local repositories is not within the scope of the eCTD. The initial submission should be self-
contained meaning that it includes all documents and no references to other submissions. Regional
guidance should be consulted if references to other submissions are needed.
Following the initial submission, the applicant can submit incremental updates such as amendments and
variations. Updates can refer to documents in the previous submissions. Updates should be designed in a
way that they can be loaded into the repository by fully preserving the initial or previous submission via
version control. The XML backbone should include meta-data identifying the update and providing
navigation aids to filter for different submission types.
It is preferred that when a Common Technical Document is submitted electronically, the entire submission
should be in electronic form with the exception of certain regional forms that currently require written
signatures. See appendix 5 for regional requirements. See appendix 6 for a description of how to submit a
CTD containing both paper and electronic components.
Page 1-2
Appendix 2: The eCTD Submission
Introduction
This appendix specifies the Information Technology aspect of the eCTD submission. Informally, the eCTD
submission is a directory structure with files including the XML eCTD instance, reports, data and other
submission information. The eCTD submission supports multilingual and multi-region aspects.
Directory Structure
The directory structure is a structure of directories and files. There should be a reasonable maximum
number of entries (directories and files) per directory. The directory structure should follow the rules
below. The files could be in several formats as specified of below.
The name of the files and directories are identifiers. They should be short. The file names are not intended
to convey meta-data, though some meaning in the names helps (i.e., no random names.)
Highly recommended names for directories and files are provided in Appendix 4. Any directory names and
file names that are added to the eCTD submission by the applicant should be descriptive and logical.
The intention is to have links from the instance to leaf files in the eCTD submission as opposed to creating
a single XML document that contains the entire eCTD submission. The instance should contain mostly
linking facilities to the leaf files. The instance also contains meta-data at the leaf level.
eCTD Template
The ICH Web site includes an eCTD template that is an empty directory. It is an illustration of an eCTD
submission and it is ready to be populated with the applicant data. Appendix 4 defines the directories used
to create this template.
Page 2-1
use designated by the appropriate ICH CTD Implementation Working Group (IWG) instead. Ideally, a
logical document consists of a single physical file. In the event the physical file exceeds the recommended
maximum file size due to graphics, data content, scanned images, or other large format content, additional
files can make up the logical document. Furthermore, if the logical document consists of multiple file
formats, then more than one physical file would be needed. An example of such a case would be PDF and
XML data that together represent the logical document.
Formats
Formats should be readable at least for as long as it is needed for the regulatory process. This process could
be very long; (e.g., 50 years.) This points to neutral formats: formal standard, industrial standard, vendor
independent, and text-like. The format should be adapted to the type of data. Appendix 7 describes the
way in which these files should be constructed.
The list of agreed to formats will be updated as technology evolves and new requirements arise. XML will
be the preferred format for all types of data.
Common Formats
The common formats that can be included in an eCTD submission are:
• Narrative: Portable Document Format (PDF)
• Structured: Extensible Markup Language (XML)
• Graphic: Whenever possible, use PDF. When appropriate or when PDF is not possible, use Joint
Photographic Experts Group (JPEG), Portable Network Graphics (PNG), Scalable Vector Graphics
(SVG), and Graphics Interchange Format (GIF). Special formats for very high resolutions may be
appropriate on a case-by-case basis.
Links
Links among objects in the eCTD submission should be relative. The intention is to make the eCTD
submission self-contained. All literature references introduced by the applicant should be included in the
submission.
One can always point to a file. The capacity to point to a specific location within a file depends on the
linking technology. Different formats allow for the use of different linking technology. See Appendix 7.
Presentation
Presentation is closely associated with formats. To associate a Stylesheet with a file usually one has to use a
linking technology. The linking between Stylesheet (that could be in a separate file) and a data file should
be relative. In addition, there is the dimension of media. One file could have several Stylesheets; the one
used depends on the media. For example, there could be one presentation for the screen and another for
paper.
Page 2-2
Checksums
The eCTD submission should contain checksums for each individual file including a checksum file for the
eCTD XML instance. Initially, the MD5 Message-Digest Algorithm (MD5) should be used for this
purpose. Including a checksum for each individual file provides a number of benefits including:
• The integrity of each file can be verified by comparing the checksum submitted with the file and
the computed checksum.
• The checksum can be used to verify that the file has not been altered in the historical archive of
the regulatory authority. This is especially useful as the files are migrated from one storage
medium to another, as in the case of backup to magnetic tape storage.
Page 2-3
File Extension
All files should have one and only one file extension. The file extension should be used to indicate the
format of the file. For example:
hello.pdf PDF
hello.rtf RTF
IANA nomenclature
text/css css
text/html html or htm
text/xml xml
application/pdf pdf
application/rtf rtf
application/vnd.ms-excel xls
image/jpeg jpg
image/png png
image/gif gif
The eCTD submission could use formats not registered with the Internet Assigned Numbers Authority
(IANA).
The presence of a format in this list does not imply that it would be considered an acceptable format. For
formats absent from this list, widely used mapping between the formats and the extensions should be used.
Future direction: if a mechanism (e.g., standard) becomes available that associates the formats with file
extension; it should be considered for this specification.
Name
Name is a token composed of the following characters:
• Letters "a" to "z" [U+0061 to U+007A].
• Digits "0" to "9" [U+0030 to U+0039].
• "-" [HYPHEN-MINUS, U+002D].
Page 2-4
Correct names (only the name without the extension):
part-b
myfile
hello
myfile.pdf
hello.cml
The maximum length of the name of a single folder or file is 64 characters including the extension. Only
lower case letters should be used in all file and directory names. The maximum length of a path is 230
characters, including file name, and extension. This allows regulators 26 characters to add to the path in
their review environments. If the path exceeds the 230 character limit, then folder and file names created
by the applicant, and not those listed in Appendix 4 should be abbreviated first. Applicants should also
consult regional media formats and M2 EWG recommendations for possible folder limits imposed by the
media.
Document name is the first name in the file name. For example, “docname” in the file name
“docname.ext”.
Character encoding
The character encoding (charset) in order of preference is:
• Unicode UTF-8, Unicode 16 bits [ISO-10646].
• ISO-8859-1 (Latin-1) or appropriate ISO-8859-x; e.g., ISO-8859-7 for Greek.
• The appropriate SHIFT_JIS.
• Other character encoding agreed upon regionally by the regulatory authority and applicant.
References
[CML] Chemical Markup Language
http://www.xml-cml.org
Page 2-5
[EXCEL] Microsoft Excel
http://www.microsoft.com/office/excel/default.htm
Page 2-6
Appendix 3: General Considerations for the CTD Modules
Introduction
Documents that are provided in the different modules should be formatted as defined by the ICH Common
Technical Document. There should also be consistency in the way navigational aids are provided. Within
each document, bookmarks and hypertext links from the table of contents should be provided to all tables,
figures, publications, and appendices.
Hypertext links should be provided throughout the body of these documents to aid efficient navigation to
annotations, related sections, publications, appendices, tables, and figures that are not located on the same
page. If a list of references is included at the end of a document, there should be hypertext links to the
appropriate publication.
Documents should be generated from electronic source documents and not from scanned material, except
where access to the source electronic file is unavailable or where a signature is required.
The maximum length of the name of a single folder or file is 64 characters including the extension. Folder
or file names should be written in lower case only. All files should have one and only one file extension.
The file extension should be used to indicate the format of the file. More details on the naming conventions
are given in Appendix 2, and examples in Appendix 4.
Typically, the file name would be the applicant’s internal numbering or naming convention for the studies.
The following table gives an example how files could be named.
Table 3-1
Description File Name
… …
1
Regulatory authorities should be notified of additions and changes to the folder structure according to
regional guidance.
Page 3-1
Detailed options on the folders and files are provided in Appendix 4 in case the applicant chooses to submit
more granular documents. It is not mandatory to use the full folder hierarchy. Empty directories can be
omitted; however, when the content is expected justification should be provided why it is missing.
This module contains administrative information that is unique for each region. Regional guidance will
provide the specific instructions on how to provide the administrative forms and detailed prescribing
information. Please refer to Appendix 5 when preparing module 1.
Module 2 Summaries
The files in this module should be provided as PDF text with the exception of a few embedded images,
when needed. The name of the folder for module 2 should be m2. The folders in module 2 should be named
as follows.
Table 3-2
Section in Description Folder Name
CTD
2.2 Introduction 22-intro
The folder hierarchy for module 2 is presented in the screenshot in figure 3-1.
Module 3 Quality
The name of the folder for module 3 should be m3. The folders in module 3 should be named as follows.
Table 3-3
Section in Description Folder Name
CTD
Page 3-2
Section in Description Folder Name
CTD
3.2 Body of Data 32-body-data
2
Each drug substance-manufacturer should be placed in a separate subordinate folder. Folders and files
should be created for each drug substance-manufacturer section included in the submission in accordance
with the hierarchy identified in the following chapters.
3
Each drug product should be placed in a separate subordinate folder. Folders and files should be created
for each drug product section included in the submission in accordance with the hierarchy identified in the
following chapters. Reference should be made to regional guidance to determine whether the inclusion of
multiple products within a single application is considered appropriate.
Page 3-3
Section in Description Folder Name
CTD
3.2.P.5.1 Specification(s) (name, dosage form) 32p51-spec
4
The folder name should include the name of the excipient, abbreviated as necessary to remain within the
64 character limit.
5
This folder should be included where regional information is appropriate. Reference should be made to
regional guidance for the types of information to be included in this section.
Page 3-4
The folder hierarchy for module 3 is presented in the screenshot in figure 3-2.
Table 3-4
Section in
Description Folder Name
CTD
Page 3-5
Section in
Description Folder Name
CTD
Page 3-6
Section in
Description Folder Name
CTD
The folder hierarchy for module 4 is presented in the screenshot in figure 3-3.
Page 3-7
Figure 3-3 Screenshot of the folder structure of module 4
Table 3-5
Section in
Description Folder Name
CTD
Page 3-8
Section in
Description Folder Name
CTD
Page 3-9
Section in
Description Folder Name
CTD
Page 3-10
Section in
Description Folder Name
CTD
535-rep-effic-safety-stud
5.3.5 Reports of Efficacy and Safety Studies
Page 3-11
Section in
Description Folder Name
CTD
6
This folder contains as many folders as studies are included that have included case report forms and/or
individual patient listings. The folders should be named like the corresponding study. The content of the
folders should follow regional guidance.
Page 3-12
The folder hierarchy for module 5 is presented in the screenshot in figure 3-4.
Page 3-13
Page 3-14
Figure 3-4 Screenshot of the folder structure of module 5 (cont)
Page 3-15
Appendix 4: File Organization for the eCTD
Each item in the file organization table that is listed in this appendix includes the information outlined below:
Sequential Each item in the table has a unique sequentially assigned reference number. These reference numbers can
number change with each version of this appendix.
Number CTD section number
Title CTD title
Element Element name in the Backbone
File/Directory Relative path of the File/Directory. The file extension corresponds to the file type; i.e., the “pdf” extension is
only illustrative. Refer to Table 6.1, Appendix 6, for details for the head of the path name
Comment Comments
The file organization table covers files that constitute the backbone itself plus necessary additional files to make the submission complete, readable and
processable. The file names are not mandatory, but highly recommended. Refer to the M4 Organisation Document: Granularity Annex for information on where
multiple documents/files are allowed in each section or subsection of the eCTD.
Where file names are presented in italics applicants would substitute these with file names in accordance with their own naming conventions.
Page 4-1
Table 4-1
Number
Title
1 Element
File index.xml
Comment This is the Backbone
Number
Title
2 Element
File index-md5.txt
Comment The MD5 of the Backbone
Page 4-2
Number 1
Title Administrative Information and Prescribing Information
3 Element m1-administrative-information-and-prescribing-information
Directory m1
Comment Only one of the regional directories is needed
Number
Title
Element
4
Directory m1/eu
EU directory: In addition to the appropriate regional documents, the regional xml instance should be located in this folder. Refer to regional
Comment
guidance for details
Number
Title
Element
5
Directory m1/jp
Japan directory: In addition to the appropriate regional documents, the regional xml instance should be located in this folder. Refer to
Comment
regional guidance for details
Number
Title
Element
6
Directory m1/us
US directory: In addition to the appropriate regional documents, the regional xml instance should be located in this folder. Refer to regional
Comment
guidance for details
Number
Title
Element
7
Directory m1/xx
xx directory; where xx is a two character country code from ISO-3166-1. In addition to the appropriate regional documents, the regional
Comment
xml instance should be located in this folder. Refer to regional guidance for details
Page 4-3
Number 2
Title Common Technical Document Summaries
8 Element m2-common-technical-document-summaries
Directory m2
Comment
Number 2.2
Title Introduction
9 Element m2-2-introduction
Directory m2/22-intro
Comment
Number 2.2
Title Introduction
10 Element m2-2-introduction
File m2/22-intro/introduction.pdf
Comment
Number 2.3
Title Quality Overall Summary
Element m2-3-quality-overall-summary
11
Directory
m2/23-qos
Refer to the Granularity Annex of the M4 Organisation Document for guidance on the flexibility of multiple documents for the Quality
Comment
Overall Summary
Number 2.3
Title Introduction
12 Element m2-3-introduction
File m2/23-qos/introduction.pdf
Comment
13 Number 2.3.S
Title Drug Substance - Name - Manufacturer
Element m2-3-s-drug-substance
File m2/23-qos/drug-substance.pdf
Page 4-4
Refer to the Granularity Annex of the M4 Organisation Document for guidance on the flexibility of multiple documents for the
Quality Overall Summary
Where there are more than one drug substance and/or manufacturer, separate files should be provided for each. The
file name should always include the name of the drug substance e.g., ranitidine hydrochloride through inclusion of
Comment the International Non-proprietary Name to give 'ranitidine-hydrochloride'. Similarly, for manufacturer, the file name
should always include the name of the manufacturer e.g., ranitidine-hydrochloride-manufacturer-1.pdf.
Where there is more than one manufacturer, the drug substance file should be repeated but with an indication of
each manufacturer concerned included in the file name, the first instance e.g., 'drug-substance-1- manufacturer-1.pdf'
and the second 'drug-substance-1-manufacturer-2.pdf'.
Number 2.3.P
Title Drug Product -Name
Elementm2-3-p-drug-product
File m2/23-qos/drug-product-name.pdf
Refer to the Granularity Annex of the M4 Organisation Document for guidance on the flexibility of multiple documents for the Quality
14 Overall Summary
he file name should always include the name of the drug product through inclusion of the name of the form/strength to give e.g., 'drug-
product-tablet-5mg'.
Comment
Where the application is for a complex presentation with multiple components the file name should identify additional items such as the
component.
Refer to regional guidance for definition of what constitutes a drug product and the acceptability of more than one drug product in an
application. Where more than one drug product is acceptable in an application, a separate file should be provided for each drug product.
Number 2.3.A
Title Appendices
Element m2-3-a-appendices
15
File m2/23-qos/appendices.pdf
Refer to the Granularity Annex of the M4 Organisation Document for guidance on the flexibility of multiple documents for the Quality
Comment
Overall Summary
Number 2.3.R
Title Regional Information
Element m2-3-r-regional-information
16
File m2/23-qos/regional-information.pdf
Refer to the Granularity Annex of the M4 Organisation Document for guidance on the flexibility of multiple documents for the Quality
Comment
Overall Summary
17 Number 2.4
Page 4-5
Title Nonclinical Overview
Element m2-4-nonclinical-overview
Directory m2/24-nonclin-over
Comment
Number 2.4
Title Nonclinical Overview
Element m2-4-nonclinical-overview
18
File m2/24-nonclin-over/nonclinical-overview.pdf
Typically, this logical document should consist of a single file. The CTD defines further heading levels and navigation should be provided
Comment
within the document to these sub-headings.
Number 2.5
Title Clinical Overview
19 Element m2-5-clinical-overview
Directory m2/25-clin-over
Comment
Number 2.5
Title Clinical Overview
Element m2-5-clinical-overview
20
File m2/25-clin-over/clinical-overview.pdf
Typically, this logical document should consist of a single file. The CTD defines further heading levels and navigation should be provided
Comment
within the document to these sub-headings.
Number 2.6
Title Nonclinical Written and Tabulated Summaries
21 Element m2-6-nonclinical-written-and-tabulated-summaries
Directory m2/26-nonclin-sum
Comment
Number 2.6.1
Title Introduction
22 Element m2-6-1-introduction
File m2/26-nonclin-sum/introduction.pdf
Comment
23 Number 2.6.2
Title Pharmacology Written Summary
Element m2-6-2-pharmacology-written-summary
File m2/26-nonclin-sum/pharmacol-written-summary.pdf
Page 4-6
Typically, this logical document should consist of a single file. The CTD defines further heading levels and navigation should be provided
Comment
within the document to these sub-headings.
Number 2.6.3
Title Pharmacology Tabulated Summary
24 Element m2-6-3-pharmacology-tabulated-summary
File m2/26-nonclin-sum/pharmacol-tabulated-summary.pdf
Comment Should have further navigation via bookmarks
Number 2.6.4
Title Pharmacokinetics Written Summary
Element m2-6-4-pharmacokinetics-written-summary
25
File m2/26-nonclin-sum/pharmkin-written-summary.pdf
Typically, this logical document should consist of a single file. The CTD defines further heading levels and navigation should be provided
Comment
within the document to these sub-headings.
Number 2.6.5
Title Pharmacokinetics Tabulated Summary
26 Element m2-6-5-pharmacokinetics-tabulated-summary
File m2/26-nonclin-sum/pharmkin-tabulated-summary.pdf
Comment Should have further navigation via bookmarks
Number 2.6.6
Title Toxicology Written Summary
Element m2-6-6-toxicology-written-summary
27
File m2/26-nonclin-sum/toxicology-written-summary.pdf
Typically, this logical document should consist of a single file. The CTD defines further heading levels and navigation should be provided
Comment
within the document to these sub-headings.
Number 2.6.7
Title Toxicology Tabulated Summary
28 Element m2-6-7-toxicology-tabulated-summary
File m2/26-nonclin-sum/toxicology-tabulated-summary.pdf
Comment Should have further navigation via bookmarks
Number 2.7
Title Clinical Summary
29 Element m2-7-clinical-summary
Directory m2/27-clin-sum
Comment
30 Number 2.7.1
Page 4-7
Title Summary of Biopharmaceutic Studies and Associated Analytical Methods
Element m2-7-1-summary-of-biopharmaceutic-studies-and-associated-analytical-methods
File m2/27-clin-sum/summary-biopharm.pdf
Typically, this logical document should consist of a single file. The CTD defines further heading levels and navigation should be provided
Comment
within the document to these sub-headings.
Number 2.7.2
Title Summary of Clinical Pharmacology Studies
Element m2-7-2-summary-of-clinical-pharmacology-studies
31
File m2/27-clin-sum/summary-clin-pharm.pdf
Typically, this logical document should consist of a single file. The CTD defines further heading levels and navigation should be provided
Comment
within the document to these sub-headings.
Number 2.7.3
Title Summary of Clinical Efficacy – Indication
Element m2-7-3-summary-of-clinical-efficacy
File m2/27-clin-sum/summary-clin-efficacy-indication.pdf
32 The file name should always include the indication being claimed (abbreviated if appropriate) e.g., 'summary-clin-efficacy-asthma'. Where
there is more than one indication (e.g., asthma & migraine) then the first indication has a file name 'summary-clin-efficacy-asthma' and the
Comment second 'summary-clin-efficacy-migraine'.
Typically, this logical document should consist of a single file. The CTD defines further heading levels and navigation should be provided
within the document to these sub-headings.
Number 2.7.4
Title Summary of Clinical Safety
Element m2-7-4-summary-of-clinical-safety
33
File m2/27-clin-sum/summary-clin-safety.pdf
Typically, this logical document should consist of a single file. The CTD defines further heading levels and navigation should be provided
Comment
within the document to these sub-headings.
Number 2.7.5
Title Literature References
34 Element m2-7-5-literature-references
File m2/27-clin-sum/literature-references.pdf
Comment
35 Number 2.7.6
Title Synopses of Individual Studies
Element m2-7-6-synopses-of-individual-studies
File m2/27-clin-sum/synopses-indiv-studies.pdf
Page 4-8
These synopses should already be located in the Clinical Study Reports in Module 5 and should not, therefore, be repeated in Module 2. It is
Comment
considered sufficient to provide hyperlinks from the listing of the studies, located here, to the locations of the synopses in Module 5.
Page 4-9
Number 3
Title Quality
36 Element m3-quality
Directory m3
Comment Refer to the Granularity Annex of the M4 Organisation Document for guidance on the flexibility of multiple documents for Module 3
Number 3.2
Title Body of Data
37 Element m3-2-body-of-data
Directory m3/32-body-data
Comment
Number 3.2.S
Title Drug Substance
38 Element m3-2-s-drug-substance
Directory m3/32-body-data/32s-drug-sub
Comment
39 Number 3.2.S
Title Drug Substance - Drug Substance Name - Manufacturer
Element m3-2-s-drug-substance
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1
Page 4-10
The folder name should always include the name of the drug substance e.g., ranitidine through inclusion of the
International Non-proprietary Name to give 'ranitidine-hydrochloride'. Similarly, for manufacturer, the folder name
should always include the name of the manufacturer e.g., ranitidine-manufacturer-1.
Where there is more than one manufacturer, the drug substance folder should be repeated but with an indication of
each manufacturer concerned included in the folder name, the first instance e.g., 'drug-substance-1- manufacturer-1'
and the second 'drug-substance-1-manufacturer-2'.
Comment Where there is more than one drug substance (e.g., ranitidine hydrochloride and cimetidine) then the first drug
substance has a folder 'ranitidine-hydrochloride' and the second 'cimetidine'.
Typically the applicant would include the specific manufacturer(s) (and/or site) in the folder name.
Number 3.2.S.1
Title General Information (name, manufacturer)
40 Element m3-2-s-1-general-information
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s1-gen-info
Comment
Number 3.2.S.1.1
Title Nomenclature (name, manufacturer)
41 Element m3-2-s-1-1-nomenclature
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s1-gen-info/nomenclature.pdf
Comment
Number 3.2.S.1.2
Title Structure (name, manufacturer)
42 Element m3-2-s-1-2-structure
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s1-gen-info/structure.pdf
Comment
43 Number 3.2.S.1.3
Page 4-11
Title General Properties (name, manufacturer)
Element m3-2-s-1-3-general-properties
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s1-gen-info/general-properties.pdf
Comment
Number 3.2.S.2
Title Manufacture (name, manufacturer)
44 Element m3-2-s-2-manufacture
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s2-manuf
Comment
Number 3.2.S.2.1
Title Manufacturer(s) (name, manufacturer)
45 Element m3-2-s-2-1-manufacturer
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s2-manuf/manufacturer.pdf
Comment For this document there should be only information regarding one manufacturer
Number 3.2.S.2.2
Title Description of Manufacturing Process and Process Controls (name, manufacturer)
46 Element m3-2-s-2-2-description-of-manufacturing-process-and-process-controls
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s2-manuf/manuf-process-and-controls.pdf
Comment
Number 3.2.S.2.3
Title Control of Materials (name, manufacturer)
47 Element m3-2-s-2-3-control-of-materials
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s2-manuf/control-of-materials.pdf
Comment
Number 3.2.S.2.4
Title Controls of Critical Steps and Intermediates (name, manufacturer)
48 Element m3-2-s-2-4-controls-of-critical-steps-and-intermediates
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s2-manuf/control-critical-steps.pdf
Comment
Number 3.2.S.2.5
Title Process Validation and/or Evaluation (name, manufacturer)
49 Element m3-2-s-2-5-process-validation-and-or-evaluation
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s2-manuf/process-validation.pdf
Comment
Page 4-12
Number 3.2.S.2.6
Title Manufacturing Process Development (name, manufacturer)
50 Element m3-2-s-2-6-manufacturing-process-development
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s2-manuf/manuf-process-development.pdf
Comment
Number 3.2.S.3
Title Characterisation (name, manufacturer)
51 Element m3-2-s-3-characterisation
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s3-charac
Comment
Number 3.2.S.3.1
Title Elucidation of Structure and Other Characteristics (name, manufacturer)
52 Element m3-2-s-3-1-elucidation-of-structure-and-other-characteristics
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s3-charac/elucidation-of-structure.pdf
Comment
Number 3.2.S.3.2
Title Impurities (name, manufacturer)
53 Element m3-2-s-3-2-impurities
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s3-charac/impurities.pdf
Comment
Number 3.2.S.4
Title Control of Drug Substance (name, manufacturer)
54 Element m3-2-s-4-control-of-drug-substance
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub
Comment
Number 3.2.S.4.1
Title Specification (name, manufacturer)
55 Element m3-2-s-4-1-specification
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s41-spec
Comment
Number 3.2.S.4.1
Title Specification (name, manufacturer)
56 Element m3-2-s-4-1-specification
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s41-spec/specification.pdf
Comment
Page 4-13
Number 3.2.S.4.2
Title Analytical Procedures (name, manufacturer)
57 Element m3-2-s-4-2-analytical-procedures
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s42-analyt-proc
Comment The example below shows how a multiple file approach, where a separate file is provided for each analytical procedure, may be organized.
Number 3.2.S.4.2.1
Title Analytical Procedure-1
58 Element m3-2-s-4-2-analytical-procedures
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s42-analyt-proc/analytical-procedure-1.pdf
Comment
Number 3.2.S.4.2.2
Title Analytical Procedure-2
59 Element m3-2-s-4-2-analytical-procedures
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s42-analyt-proc/analytical-procedure-2.pdf
Comment
Number 3.2.S.4.2.3
Title Analytical Procedure-3
60 Element m3-2-s-4-2-analytical-procedures
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s42-analyt-proc/analytical-procedure-3.pdf
Comment
Number 3.2.S.4.3
Title Validation of Analytical Procedures
61 Element m3-2-s-4-3-validation-of-analytical-procedures (name, manufacturer)
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s43-val-analyt-proc
Comment The example below shows how a multiple file approach, where a separate file is provided for each analytical procedure, may be organized.
Number 3.2.S.4.3.1
Title Validation of Analytical Procedure-1
62 Element m3-2-s-4-3-validation-of-analytical-procedures
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s43-val-analyt-proc/validation-analyt-procedure-1.pdf
Comment
63 Number 3.2.S.4.3.2
Title Validation of Analytical Procedure-2
Element m3-2-s-4-3-validation-of-analytical-procedures
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s43-val-analyt-proc/validation-analyt-procedure-2.pdf
Page 4-14
Comment
Number 3.2.S.4.3.3
Title Validation of Analytical Procedure-3
64 Element m3-2-s-4-3-validation-of-analytical-procedures
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s43-val-analyt-proc/validation-analyt-procedure-3.pdf
Comment
Number 3.2.S.4.4
Title Batch Analyses (name, manufacturer)
65 Element m3-2-s-4-4-batch-analyses
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s44-batch-analys
Comment
Number 3.2.S.4.4
Title Batch Analyses (name, manufacturer)
66 Element m3-2-s-4-4-batch-analyses
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s44-batch-analys/batch-analyses.pdf
Comment
Number 3.2.S.4.5
Title Justification of Specification (name, manufacturer)
67 Element m3-2-s-4-5-justification-of-specification
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s45-justif-spec
Comment
Number 3.2.S.4.5
Title Justification of Specification (name, manufacturer)
68 Element m3-2-s-4-5-justification-of-specification
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s4-contr-drug-sub/32s45-justif-spec/justification-of-specification.pdf
Comment
Number 3.2.S.5
Title Reference Standards or Materials (name, manufacturer)
69 Element m3-2-s-5-reference-standards-or-materials
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s5-ref-stand
Comment
70 Number 3.2.S.5
Title Reference Standards or Materials (name, manufacturer)
Element m3-2-s-5-reference-standards-or-materials
Page 4-15
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s5-ref-stand/reference-standards.pdf
Comment Where a multiple file approach is taken for this section, the file names should indicate which reference standard is covered in the document.
Number 3.2.S.6
Title Container Closure System (name, manufacturer)
71 Element m3-2-s-6-container-closure-system
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s6-cont-closure-sys
Comment
Number 3.2.S.6
Title Container Closure System (name, manufacturer)
72 Element m3-2-s-6-container-closure-system
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s6-cont-closure-sys/container-closure-system.pdf
Comment
Number 3.2.S.7
Title Stability (name, manufacturer)
73 Element m3-2-s-7-stability
Directory m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s7-stab
Comment
Number 3.2.S.7.1
Title Stability Summary and Conclusions (name, manufacturer)
74 Element m3-2-s-7-1-stability-summary-and-conclusions
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s7-stab/stability-summary.pdf
Comment
Number 3.2.S.7.2
Title Post-approval Stability Protocol and Stability Commitment (name, manufacturer)
75 Element m3-2-s-7-2-post-approval-stability-protocol-and-stability-commitment
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s7-stab/postapproval-stability.pdf
Comment
Number 3.2.S.7.3
Title Stability Data (name, manufacturer)
76 Element m3-2-s-7-3-stability-data
File m3/32-body-data/32s-drug-sub/substance-1-manufacturer-1/32s7-stab/stability-data.pdf
Comment
77 Number 3.2.P
Title Drug Product (name, dosage form)
Element m3-2-p-drug-product
Page 4-16
Directory m3/32-body-data/32p-drug-prod
Comment
Number 3.2.P
Title Drug Product (name, dosage form) – Name
Element m3-2-p-drug-product
Directory m3/32-body-data/32p-drug-prod/product-1
78 The folder name should always include the name of the drug product through inclusion of the name of the form/strength to give e.g., 'tablet-
5mg'. Where there is more than one drug product (e.g., powder for reconstitution and diluent) then the first drug product has a folder
Comment 'powder-for-reconstitution' and the second 'diluent'.
Refer to regional guidance for definition of what constitutes a drug product and the acceptability of more than one drug product in an
application.
Number 3.2.P.1
Title Description and Composition of the Drug Product (name, dosage form)
79 Element m3-2-p-1-description-and-composition-of-the-drug-product
Directory m3/32-body-data/32p-drug-prod/product-1/32p1-desc-comp
Comment
Number 3.2.P.1
Title Description and Composition of the Drug Product (name, dosage form)
80 Element m3-2-p-1-description-and-composition-of-the-drug-product
File m3/32-body-data/32p-drug-prod/product-1/32p1-desc-comp/description-and-composition.pdf
Comment
Number 3.2.P.2
Title Pharmaceutical Development (name, dosage form)
Element m3-2-p-2-pharmaceutical-development
81
Directory m3/32-body-data/32p-drug-prod/product-1/32p2-pharm-dev
Refer to the M4 Organisation Document: Granularity Annex for guidance on the flexibility of multiple documents for the Pharmaceutical
Comment
Development section.
Number 3.2.P.2
Title Pharmaceutical Development (name, dosage form)
Element m3-2-p-2-pharmaceutical-development
82 File m3/32-body-data/32p-drug-prod/product-1/32p2-pharm-dev/pharmaceutical-development.pdf
Refer to the M4 Organisation Document: Granularity Annex for guidance on the flexibility of multiple documents for the Pharmaceutical
Comment
Development section.
Page 4-17
Number 3.2.P.3
Title Manufacture (name, dosage form)
83 Element m3-2-p-3-manufacture
Directory m3/32-body-data/32p-drug-prod/product-1/32p3-manuf
Comment
Number 3.2.P.3.1
Title Manufacturer(s) (name, dosage form)
84 Element m3-2-p-3-1-manufacturers
File m3/32-body-data/32p-drug-prod/product-1/32p3-manuf/manufacturers.pdf
Comment
Number 3.2.P.3.2
Title Batch Formula (name, dosage form)
85 Element m3-2-p-3-2-batch-formula
File m3/32-body-data/32p-drug-prod/product-1/32p3-manuf/batch-formula.pdf
Comment
Number 3.2.P.3.3
Title Description of Manufacturing Process and Process Controls (name, dosage form)
86 Element m3-2-p-3-3-description-of-manufacturing-process-and-process-controls
File m3/32-body-data/32p-drug-prod/product-1/32p3-manuf/manuf-process-and-controls.pdf
Comment
Number 3.2.P.3.4
Title Controls of Critical Steps and Intermediates (name, dosage form)
87 Element m3-2-p-3-4-controls-of-critical-steps-and-intermediates
File m3/32-body-data/32p-drug-prod/product-1/32p3-manuf/control-critical-steps.pdf
Comment
Number 3.2.P.3.5
Title Process Validation and/or Evaluation (name, dosage form)
88 Element m3-2-p-3-5-process-validation-and-or-evaluation
File m3/32-body-data/32p-drug-prod/product-1/32p3-manuf/process-validation.pdf
Comment The applicant has the option to submit one or multiple files, one for each validation or evaluation.
89 Number 3.2.P.4
Title Control of Excipients (name, dosage form)
Element m3-2-p-4-control-of-excipients
Directory m3/32-body-data/32p-drug-prod/product-1/32p4-contr-excip
Page 4-18
Comment
Number 3.2.P.4
Title Control of Excipients (name, dosage form) – Excipient
Element m3-2-p-4-control-of-excipients
90 Directory m3/32-body-data/32p-drug-prod/product-1/32p4-contr-excip/excipient-1
For a drug product containing more than one excipient, the information requested for sections 3.2.P.4.1 – 3.2.P.4.4 should be provided in its
entirety for each excipient. For compendial excipient(s) without additional specification tests, it is appropriate to have all information in
Comment
one file, making sure to introduce a folder for each of new documents to avoid mixing files and folders at the same level. Non-compendial
excipients should follow the structure outlined below.
Number 3.2.P.4.1
Title Specifications (name, dosage form)
91 Element m3-2-p-4-1-specifications
File m3/32-body-data/32p-drug-prod/product-1/32p4-contr-excip/excipient-1/specifications.pdf
Comment See comment under 3.2.P.4.
Number 3.2.P.4.2
Title Analytical Procedures (name, dosage form)
92 Element m3-2-p-4-2-analytical-procedures
File m3/32-body-data/32p-drug-prod/product-1/32p4-contr-excip/excipient-1/analytical-procedures.pdf
Comment See comment under 3.2.P.4.
Number 3.2.P.4.3
Title Validation of Analytical Procedures (name, dosage form)
93 Element m3-2-p-4-3-validation-of-analytical-procedures
File m3/32-body-data/32p-drug-prod/product-1/32p4-contr-excip/excipient-1/validation-analyt-procedures.pdf
Comment See comment under 3.2.P.4.
Number 3.2.P.4.4
Title Justification of Specifications (name, dosage form)
94 Element m3-2-p-4-4-justification-of-specifications
File m3/32-body-data/32p-drug-prod/product-1/32p4-contr-excip/excipient-1/justification-of-specifications.pdf
Comment See comment under 3.2.P.4.
Number 3.2.P.4.5
Title Excipients of Human or Animal Origin (name, dosage form)
95 Element m3-2-p-4-5-excipients-of-human-or-animal-origin
File m3/32-body-data/32p-drug-prod/product-1/32p4-contr-excip/excipients-human-animal.pdf
Comment
96 Number 3.2.P.4.6
Page 4-19
Title Novel Excipients (name, dosage form)
Element m3-2-p-4-6-novel-excipients
File m3/32-body-data/32p-drug-prod/product-1/32p4-contr-excip/novel-excipients.pdf
Comment
Number 3.2.P.5
Title Control of Drug Product (name, dosage form)
97 Element m3-2-p-5-control-of-drug-product
Directory m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod
Comment
Number 3.2.P.5.1
Title Specification(s) (name, dosage form)
98 Element m3-2-p-5-1-specifications
Directory m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p51-spec
Comment
Number 3.2.P.5.1
Title Specification(s) (name, dosage form)
99 Element m3-2-p-5-1-specifications
File m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p51-spec/specifications.pdf
Comment
Number 3.2.P.5.2
Title Analytical Procedures (name, dosage form)
100 Element m3-2-p-5-2-analytical-procedures
Directory m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p52-analyt-proc
Comment The example below shows how a multiple file approach, where a separate file is provided for each analytical procedure, may be organized.
Number 3.2.P.5.2.1
Title Analytical Procedure – 1
101 Element m3-2-p-5-2-analytical-procedures
File m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p52-analyt-proc/analytical-procedure-1.pdf
Comment
Number 3.2.P.5.2.2
Title Analytical Procedure – 2
102 Element m3-2-p-5-2-analytical-procedures
File m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p52-analyt-proc/analytical-procedure-2.pdf
Comment
Page 4-20
Number 3.2.P.5.2.3
Title Analytical Procedure – 3
103 Element m3-2-p-5-2-analytical-procedures
File m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p52-analyt-proc/analytical-procedure-3.pdf
Comment
Number 3.2.P.5.3
Title Validation of Analytical Procedures (name, dosage form)
104 Element m3-2-p-5-3-validation-of-analytical-procedures
Directory m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p53-val-analyt-proc
Comment The example below shows how a multiple file approach, where a separate file is provided for each analytical procedure, may be organized.
Number 3.2.P.5.3.1
Title Validation of Analytical Procedures – 1
105 Element m3-2-p-5-3-validation-of-analytical-procedures
File m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p53-val-analyt-proc/validation-analytical-procedures-1.pdf
Comment
Number 3.2.P.5.3.2
Title Validation of Analytical Procedures – 2
106 Element m3-2-p-5-3-validation-of-analytical-procedures
File m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p53-val-analyt-proc/validation-analytical-procedures-2.pdf
Comment
Number 3.2.P.5.3.3
Title Validation of Analytical Procedures – 3
107 Element m3-2-p-5-3-validation-of-analytical-procedures
File m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p53-val-analyt-proc/validation-analytical-procedures-3.pdf
Comment
Number 3.2.P.5.4
Title Batch Analyses (name, dosage form)
108 Element m3-2-p-5-4-batch-analyses
Directory m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p54-batch-analys
Comment
109 Number 3.2.P.5.4
Title Batch Analyses (name, dosage form)
Element m3-2-p-5-4-batch-analyses
File m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p54-batch-analys/batch-analyses.pdf
Page 4-21
Comment
Number 3.2.P.5.5
Title Characterisation of Impurities (name, dosage form)
110 Element m3-2-p-5-5-characterisation-of-impurities
Directory m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p55-charac-imp
Comment
Number 3.2.P.5.5
Title Characterisation of Impurities (name, dosage form)
111 Element m3-2-p-5-5-characterisation-of-impurities
File m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p55-charac-imp/characterisation-impurities.pdf
Comment
Number 3.2.P.5.6
Title Justification of Specifications (name, dosage form)
112 Element m3-2-p-5-6-justification-of-specifications
Directory m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p56-justif-spec
Comment
Number 3.2.P.5.6
Title Justification of Specifications (name, dosage form)
113 Element m3-2-p-5-6-justification-of-specifications
File m3/32-body-data/32p-drug-prod/product-1/32p5-contr-drug-prod/32p56-justif-spec/justification-of-specifications.pdf
Comment
Number 3.2.P.6
Title Reference Standards or Materials (name, dosage form)
114 Element m3-2-p-6-reference-standards-or-materials
Directory m3/32-body-data/32p-drug-prod/product-1/32p6-ref-stand
Comment
Number 3.2.P.6
Title Reference Standards or Materials (name, dosage form)
115 Element m3-2-p-6-reference-standards-or-materials
File m3/32-body-data/32p-drug-prod/product-1/32p6-ref-stand/reference-standards.pdf
Comment When a multiple file approach is taken for this section, the file names should indicate which reference standard is covered in the document.
116 Number 3.2.P.7
Title Container Closure System (name, dosage form)
Element m3-2-p-7-container-closure-system
Directory m3/32-body-data/32p-drug-prod/product-1/32p7-cont-closure-sys
Page 4-22
Comment
Number 3.2.P.7
Title Container Closure System (name, dosage form)
117 Element m3-2-p-7-container-closure-system
File m3/32-body-data/32p-drug-prod/product-1/32p7-cont-closure-sys/container-closure-system.pdf
Comment
Number 3.2.P.8
Title Stability (name, dosage form)
118 Element m3-2-p-8-stability
Directory m3/32-body-data/32p-drug-prod/product-1/32p8-stab
Comment
Number 3.2.P.8.1
Title Stability Summary and Conclusion (name, dosage form)
119 Element m3-2-p-8-1-stability-summary-and-conclusion
File m3/32-body-data/32p-drug-prod/product-1/32p8-stab/stability-summary.pdf
Comment
Number 3.2.P.8.2
Title Post-approval Stability Protocol and Stability Commitment (name, dosage form)
120 Element m3-2-p-8-2-post-approval-stability-protocol-and-stability-commitment
File m3/32-body-data/32p-drug-prod/product-1/32p8-stab/postapproval-stability.pdf
Comment
Number 3.2.P.8.3
Title Stability Data (name, dosage form)
121 Element m3-2-p-8-3-stability-data
File m3/32-body-data/32p-drug-prod/product-1/32p8-stab/stability-data.pdf
Comment
Number 3.2.A
Title Appendices
122 Element m3-2-a-appendices
Directory m3/32-body-data/32a-app
Comment
123 Number 3.2.A.1
Title Facilities and Equipment (name, manufacturer)
Element m3-2-a-1-facilities-and-equipment
Directory m3/32-body-data/32a-app/32a1-fac-equip
Page 4-23
Several reports are likely to be included in this appendix. The organisation is left to the applicant to define. However, where there is more
Comment
than one manufacturer a folder should be created for each manufacturer and the identity of the manufacturer included in the directory name.
Number 3.2.A.1.1
Title Facilities and Equipment Report 1
124 Element m3-2-a-1-facilities-and-equipment
File m3/32-body-data/32a-app/32a1-fac-equip/facilities-and-equipment-report-1.pdf
Comment
Number 3.2.A.1.2
Title Facilities and Equipment Report 2
125 Element m3-2-a-1-facilities-and-equipment
File m3/32-body-data/32a-app/32a1-fac-equip/facilities-and-equipment-report-2.pdf
Comment
Number 3.2.A.1.3
Title Facilities and Equipment Report 3
126 Element m3-2-a-1-facilities-and-equipment
File m3/32-body-data/32a-app/32a1-fac-equip/facilities-and-equipment-report-3.pdf
Comment
Number 3.2.A.2
Title Adventitious Agents Safety Evaluation (name, dosage form, manufacturer)
Element m3-2-a-2-adventitious-agents-safety-evaluation
127 Directory m3/32-body-data/32a-app/32a2-advent-agent
Nonviral adventitious agents reports should be placed in this folder. For viral adventitious agents the following sub-folder structure should
Comment be used. However, where the is more than one drug substance, drug product, manufacturer etc., a directory should be created each option
and its identity included in the directory name.
Number 3.2.A.2.1
Title Adventitious Agents Safety Evaluation Report 1
128 Element m3-2-a-2-adventitious-agents-safety-evaluation
File m3/32-body-data/32a-app/32a2-advent-agent/adventitious-agents-report-1.pdf
Comment
Number 3.2.A.2.2
Title Adventitious Agents Safety Evaluation Report 2
129 Element m3-2-a-2-adventitious-agents-safety-evaluation
File m3/32-body-data/32a-app/32a2-advent-agent/adventitious-agents-report-2.pdf
Comment
130 Number 3.2.A.2.3
Page 4-24
Title Adventitious Agents Safety Evaluation Report 3
Element m3-2-a-2-adventitious-agents-safety-evaluation
File m3/32-body-data/32a-app/32a2-advent-agent/adventitious-agents-report-3.pdf
Comment
Number 3.2.A.3
Title Excipients – Name
Element m3-2-a-3-excipients
Directory m3/32-body-data/32a-app/32a3-excip-name-1
131 The name of any novel excipient should be included in the folder name. If there is more than one novel excipient then each folder should
have unique identification through the use of different names e.g., '32a3-excip-name-1' and '32a3-excip-name-2'.
Comment
The directory/file structure would typically follow that of the drug substance section in Module 3. Refer to Regional guidances for the need
for such information to be included in the submission directly as opposed to its inclusion in a Drug Master File.
Number 3.2.R
Title Regional Information
132 Element m3-2-r-regional-information
Directory m3/32-body-data/32r-reg-info
Comment Refer to the M4 Organisation Document: Granularity Annex for the approach to take with this section.
Number 3.3
Title Literature References
133 Element m3-3-literature-references
Directory m3/33-lit-ref
Comment Copies of literature references should ordinarily be submitted as individual files (i.e., one for each reference).
Number 3.3.1
Title Reference 1
134 Element m3-3-literature-references
File m3/33-lit-ref/reference-1.pdf
Comment
Number 3.3.2
Title Reference 2
135 Element m3-3-literature-references
File m3/33-lit-ref/reference-2.pdf
Comment
136 Number 3.3.3
Title Reference 3
Page 4-25
Element m3-3-literature-references
File m3/33-lit-ref/reference-3.pdf
Comment
Page 4-26
Number 4
Title Nonclinical Study Reports
137 Element m4-nonclinical-study-reports
Directory m4
Comment
Number 4.2
Title Study Reports
138 Element m4-2-study-reports
Directory m4/42-stud-rep
Comment
Number 4.2.1
Title Pharmacology
139 Element m4-2-1-pharmacology
Directory m4/42-stud-rep/421-pharmacol
Comment
Number 4.2.1.1
Title Primary Pharmacodynamics
140 Element m4-2-1-1-primary-pharmacodynamics
Directory m4/42-stud-rep/421-pharmacol/4211-prim-pd
Comment
Number4.2.1.1.1
Title Study Report 1
Element
m4-2-1-1-primary-pharmacodynamics
File m4/42-stud-rep/421-pharmacol/4211-prim-pd/study-report-1.pdf
Typically a single file should be provided for each study report in Module 4. However, where the study report is large (e.g., a
carcinogenicity study) the applicant can choose to submit the report as more than one file. In this case the text portion of the report should
141 be one file and the appendices may be one or more files. In choosing the level of granularity for these reports, the applicant should consider
that, when relevant information is changed at any point in the product's lifecycle, replacements of complete documents/files should be
provided.
Comment
Where the approach of multiple files is used it is recommended that a directory is created at the study report level and the relevant files
included within the directory.
It is possible to have the additional graphical file(s) inserted directly into the PDF file, thus making management of the file easier.
Alternatively, the applicant can choose to manage graphical files independently.
This comment is applicable to all study reports in Module 4.
Page 4-27
Number 4.2.1.1.2
Title Study Report 2
142 Element m4-2-1-1-primary-pharmacodynamics
File m4/42-stud-rep/421-pharmacol/4211-prim-pd/study-report-2.pdf
Comment
Number 4.2.1.1.3
Title Study Report 3
143 Element m4-2-1-1-primary-pharmacodynamics
File m4/42-stud-rep/421-pharmacol/4211-prim-pd/study-report-3.pdf
Comment
Number 4.2.1.2
Title Secondary Pharmacodynamics
144 Element m4-2-1-2-secondary-pharmacodynamics
Directory m4/42-stud-rep/421-pharmacol/4212-sec-pd
Comment
Number 4.2.1.2.1
Title Study Report 1
145 Element m4-2-1-2-secondary-pharmacodynamics
File m4/42-stud-rep/421-pharmacol/4212-sec-pd/study-report-1.pdf
Comment
Number 4.2.1.2.2
Title Study Report 2
146 Element m4-2-1-2-secondary-pharmacodynamics
File m4/42-stud-rep/421-pharmacol/4212-sec-pd/study-report-2.pdf
Comment
Number 4.2.1.2.3
Title Study Report 3
147 Element m4-2-1-2-secondary-pharmacodynamics
File m4/42-stud-rep/421-pharmacol/4212-sec-pd/study-report-3.pdf
Comment
Number 4.2.1.3
Title Safety Pharmacology
148 Element m4-2-1-3-safety-pharmacology
Directory m4/42-stud-rep/421-pharmacol/4213-safety-pharmacol
Comment
Page 4-28
Number 4.2.1.3.1
Title Study Report 1
149 Element m4-2-1-3-safety-pharmacology
File m4/42-stud-rep/421-pharmacol/4213-safety-pharmacol/study-report-1.pdf
Comment
Number 4.2.1.3.2
Title Study Report 2
150 Element m4-2-1-3-safety-pharmacology
File m4/42-stud-rep/421-pharmacol/4213-safety-pharmacol/study-report-2.pdf
Comment
Number 4.2.1.3.3
Title Study Report 3
151 Element m4-2-1-3-safety-pharmacology
File m4/42-stud-rep/421-pharmacol/4213-safety-pharmacol/study-report-3.pdf
Comment
Number 4.2.1.4
Title Pharmacodynamic Drug Interactions
152 Element m4-2-1-4-pharmacodynamic-drug-interactions
Directory m4/42-stud-rep/421-pharmacol/4214-pd-drug-interact
Comment
Number 4.2.1.4.1
Title Study Report 1
153 Element m4-2-1-4-pharmacodynamic-drug-interactions
File m4/42-stud-rep/421-pharmacol/4214-pd-drug-interact/study-report-1.pdf
Comment
Number 4.2.1.4.2
Title Study Report 2
154 Element m4-2-1-4-pharmacodynamic-drug-interactions
File m4/42-stud-rep/421-pharmacol/4214-pd-drug-interact/study-report-2.pdf
Comment
155 Number 4.2.1.4.3
Title Study Report 3
Element m4-2-1-4-pharmacodynamic-drug-interactions
File m4/42-stud-rep/421-pharmacol/4214-pd-drug-interact/study-report-3.pdf
Page 4-29
Comment
Number 4.2.2
Title Pharmacokinetics
156 Element m4-2-2-pharmacokinetics
Directory m4/42-stud-rep/422-pk
Comment
Number 4.2.2.1
Title Analytical Methods and Validation Reports (if separate reports are available)
157 Element m4-2-2-1-analytical-methods-and-validation-reports
Directory m4/42-stud-rep/422-pk/4221-analyt-met-val
Comment
Number 4.2.2.1.1
Title Study Report 1
158 Element m4-2-2-1-analytical-methods-and-validation-reports
File m4/42-stud-rep/422-pk/4221-analyt-met-val/study-report-1.pdf
Comment
Number 4.2.2.1.2
Title Study Report 2
159 Element m4-2-2-1-analytical-methods-and-validation-reports
File m4/42-stud-rep/422-pk/4221-analyt-met-val/study-report-2.pdf
Comment
Number 4.2.2.1.3
Title Study Report 3
160 Element m4-2-2-1-analytical-methods-and-validation-reports
File m4/42-stud-rep/422-pk/4221-analyt-met-val/study-report-3.pdf
Comment
Number 4.2.2.2
Title Absorption
161 Element m4-2-2-2-absorption
Directory m4/42-stud-rep/422-pk/4222-absorp
Comment
162 Number 4.2.2.2.1
Title Study Report 1
Element m4-2-2-2-absorption
File m4/42-stud-rep/422-pk/4222-absorp/study-report-1.pdf
Page 4-30
Comment
Number 4.2.2.2.2
Title Study Report 2
163 Element m4-2-2-2-absorption
File m4/42-stud-rep/422-pk/4222-absorp/study-report-2.pdf
Comment
Number 4.2.2.2.3
Title Study Report 3
164 Element m4-2-2-2-absorption
File m4/42-stud-rep/422-pk/4222-absorp/study-report-3.pdf
Comment
Number 4.2.2.3
Title Distribution
165 Element m4-2-2-3-distribution
Directory m4/42-stud-rep/422-pk/4223-distrib
Comment
Number 4.2.2.3.1
Title Study Report 1
166 Element m4-2-2-3-distribution
File m4/42-stud-rep/422-pk/4223-distrib/study-report-1.pdf
Comment
Number 4.2.2.3.2
Title Study Report 2
167 Element m4-2-2-3-distribution
File m4/42-stud-rep/422-pk/4223-distrib/study-report-2.pdf
Comment
Number 4.2.2.3.3
Title Study Report 3
168 Element m4-2-2-3-distribution
File m4/42-stud-rep/422-pk/4223-distrib/study-report-3.pdf
Comment
169 Number 4.2.2.4
Title Metabolism
Element m4-2-2-4-metabolism
Directory m4/42-stud-rep/422-pk/4224-metab
Page 4-31
Comment
Number 4.2.2.4.1
Title Study Report 1
170 Element m4-2-2-4-metabolism
File m4/42-stud-rep/422-pk/4224-metab/study-report-1.pdf
Comment
Number 4.2.2.4.2
Title Study Report 2
171 Element m4-2-2-4-metabolism
File m4/42-stud-rep/422-pk/4224-metab/study-report-2.pdf
Comment
Number 4.2.2.4.3
Title Study Report 3
172 Element m4-2-2-4-metabolism
File m4/42-stud-rep/422-pk/4224-metab/study-report-3.pdf
Comment
Number 4.2.2.5
Title Excretion
173 Element m4-2-2-5-excretion
Directory m4/42-stud-rep/422-pk/4225-excr
Comment
Number 4.2.2.5.1
Title Study Report 1
174 Element m4-2-2-5-excretion
File m4/42-stud-rep/422-pk/4225-excr/study-report-1.pdf
Comment
Number 4.2.2.5.2
Title Study Report 2
175 Element m4-2-2-5-excretion
File m4/42-stud-rep/422-pk/4225-excr/study-report-2.pdf
Comment
176 Number 4.2.2.5.3
Title Study Report 3
Element m4-2-2-5-excretion
Page 4-32
File m4/42-stud-rep/422-pk/4225-excr/study-report-3.pdf
Comment
Number 4.2.2.6
Title Pharmacokinetic Drug Interactions (nonclinical)
177 Element m4-2-2-6-pharmacokinetic-drug-interactions
Directory m4/42-stud-rep/422-pk/4226-pk-drug-interact
Comment
Number 4.2.2.6.1
Title Study Report 1
178 Element m4-2-2-6-pharmacokinetic-drug-interactions
File m4/42-stud-rep/422-pk/4226-pk-drug-interact/study-report-1.pdf
Comment
Number 4.2.2.6.2
Title Study Report 2
179 Element m4-2-2-6-pharmacokinetic-drug-interactions
File m4/42-stud-rep/422-pk/4226-pk-drug-interact/study-report-2.pdf
Comment
Number 4.2.2.6.3
Title Study Report 3
180 Element m4-2-2-6-pharmacokinetic-drug-interactions
File m4/42-stud-rep/422-pk/4226-pk-drug-interact/study-report-3.pdf
Comment
Number 4.2.2.7
Title Other Pharmacokinetic Studies
181 Element m4-2-2-7-other-pharmacokinetic-studies
Directory m4/42-stud-rep/422-pk/4227-other-pk-stud
Comment
Number 4.2.2.7.1
Title Study Report 1
182 Element m4-2-2-7-other-pharmacokinetic-studies
File m4/42-stud-rep/422-pk/4227-other-pk-stud/study-report-1.pdf
Comment
183 Number 4.2.2.7.2
Title Study Report 2
Element m4-2-2-7-other-pharmacokinetic-studies
Page 4-33
File m4/42-stud-rep/422-pk/4227-other-pk-stud/study-report-2.pdf
Comment
Number 4.2.2.7.3
Title Study Report 3
184 Element m4-2-2-7-other-pharmacokinetic-studies
File m4/42-stud-rep/422-pk/4227-other-pk-stud/study-report-3.pdf
Comment
Number 4.2.3
Title Toxicology
185 Element m4-2-3-toxicology
Directory m4/42-stud-rep/423-tox
Comment
Number 4.2.3.1
Title Single-Dose Toxicity (in order by species, by route)
186 Element m4-2-3-1-single-dose-toxicity
Directory m4/42-stud-rep/423-tox/4231-single-dose-tox
Comment
Number 4.2.3.1.1
Title Study Report 1
187 Element m4-2-3-1-single-dose-toxicity
File m4/42-stud-rep/423-tox/4231-single-dose-tox/study-report-1.pdf
Comment
Number 4.2.3.1.2
Title Study Report 2
188 Element m4-2-3-1-single-dose-toxicity
File m4/42-stud-rep/423-tox/4231-single-dose-tox/study-report-2.pdf
Comment
Number 4.2.3.1.3
Title Study Report 3
189 Element m4-2-3-1-single-dose-toxicity
File m4/42-stud-rep/423-tox/4231-single-dose-tox/study-report-3.pdf
Comment
190 Number 4.2.3.2
Title Repeat-Dose Toxicity (in order by species, by route, by duration, including supportive toxicokinetics evaluations)
Page 4-34
Element m4-2-3-2-repeat-dose-toxicity
Directory m4/42-stud-rep/423-tox/4232-repeat-dose-tox
Comment
Number 4.2.3.2.1
Title Study Report 1
191 Element m4-2-3-2-repeat-dose-toxicity
File m4/42-stud-rep/423-tox/4232-repeat-dose-tox/study-report-1.pdf
Comment
Number 4.2.3.2.2
Title Study Report 2
192 Element m4-2-3-2-repeat-dose-toxicity
File m4/42-stud-rep/423-tox/4232-repeat-dose-tox/study-report-2.pdf
Comment
Number 4.2.3.2.3
Title Study Report 3
193 Element m4-2-3-2-repeat-dose-toxicity
File m4/42-stud-rep/423-tox/4232-repeat-dose-tox/study-report-3.pdf
Comment
Number 4.2.3.3
Title Genotoxicity
194 Element m4-2-3-3-genotoxicity
Directory m4/42-stud-rep/423-tox/4233-genotox
Comment
Number 4.2.3.3.1
Title In vitro
195 Element m4-2-3-3-1-in-vitro
Directory m4/42-stud-rep/423-tox/4233-genotox/42331-in-vitro
Comment
Number 4.2.3.3.1.1
Title Study Report 1
196 Element m4-2-3-3-1-in-vitro
File m4/42-stud-rep/423-tox/4233-genotox/42331-in-vitro/study-report-1.pdf
Comment
197 Number 4.2.3.3.1.2
Title Study Report 2
Page 4-35
Element m4-2-3-3-1-in-vitro
File m4/42-stud-rep/423-tox/4233-genotox/42331-in-vitro/study-report-2.pdf
Comment
Number 4.2.3.3.1.3
Title Study Report 3
198 Element m4-2-3-3-1-in-vitro
File m4/42-stud-rep/423-tox/4233-genotox/42331-in-vitro/study-report-3.pdf
Comment
Number 4.2.3.3.2
Title In vivo (including supportive toxicokinetics evaluations)
199 Element m4-2-3-3-2-in-vivo
Directory m4/42-stud-rep/423-tox/4233-genotox/42332-in-vivo
Comment
Number 4.2.3.3.2.1
Title Study Report 1
200 Element m4-2-3-3-2-in-vivo
File m4/42-stud-rep/423-tox/4233-genotox/42332-in-vivo/study-report-1.pdf
Comment
Number 4.2.3.3.2.2
Title Study Report 2
201 Element m4-2-3-3-2-in-vivo
File m4/42-stud-rep/423-tox/4233-genotox/42332-in-vivo/study-report-2.pdf
Comment
Number 4.2.3.3.2.3
Title Study Report 3
202 Element m4-2-3-3-2-in-vivo
File m4/42-stud-rep/423-tox/4233-genotox/42332-in-vivo/study-report-3.pdf
Comment
Number 4.2.3.4
Title Carcinogenicity (including supportive toxicokinetics evaluations)
203 Element m4-2-3-4-carcinogenicity
Directory m4/42-stud-rep/423-tox/4234-carcigen
Comment
204 Number 4.2.3.4.1
Page 4-36
Long-term studies (in order by species, including range-finding studies that cannot be appropriately included under repeat-dose toxicity or
Title
pharmacokinetics)
Element m4-2-3-4-1-long-term-studies
Directory m4/42-stud-rep/423-tox/4234-carcigen/42341-lt-stud
Comment
Number 4.2.3.4.1.1
Title Study Report 1
205 Element m4-2-3-4-1-long-term-studies
File m4/42-stud-rep/423-tox/4234-carcigen/42341-lt-stud/study-report-1.pdf
Comment
Number 4.2.3.4.1.2
Title Study Report 2
206 Element m4-2-3-4-1-long-term-studies
File m4/42-stud-rep/423-tox/4234-carcigen/42341-lt-stud/study-report-2.pdf
Comment
Number 4.2.3.4.1.3
Title Study Report 3
207 Element m4-2-3-4-1-long-term-studies
File m4/42-stud-rep/423-tox/4234-carcigen/42341-lt-stud/study-report-3.pdf
Comment
Number 4.2.3.4.2
Short- or medium-term studies (including range-finding studies that cannot be appropriately included under repeat-dose toxicity or
Title
pharmacokinetics)
208
Element m4-2-3-4-2-short-or-medium-term-studies
Directory m4/42-stud-rep/423-tox/4234-carcigen/42342-smt-stud
Comment
Number 4.2.3.4.2.1
Title Study Report 1
209 Element m4-2-3-4-2-short-or-medium-term-studies
File m4/42-stud-rep/423-tox/4234-carcigen/42342-smt-stud/study-report-1.pdf
Comment
210 Number 4.2.3.4.2.2
Title Study Report 2
Element m4-2-3-4-2-short-or-medium-term-studies
File m4/42-stud-rep/423-tox/4234-carcigen/42342-smt-stud/study-report-2.pdf
Page 4-37
Comment
Number 4.2.3.4.2.3
Title Study Report 3
211 Element m4-2-3-4-2-short-or-medium-term-studies
File m4/42-stud-rep/423-tox/4234-carcigen/42342-smt-stud/study-report-3.pdf
Comment
Number 4.2.3.4.3
Title Other studies
212 Element m4-2-3-4-3-other-studies
Directory m4/42-stud-rep/423-tox/4234-carcigen/42343-other-stud
Comment
Number 4.2.3.4.3.1
Title Study Report 1
213 Element m4-2-3-4-3-other-studies
File m4/42-stud-rep/423-tox/4234-carcigen/42343-other-stud/study-report-1.pdf
Comment
Number 4.2.3.4.3.2
Title Study Report 2
214 Element m4-2-3-4-3-other-studies
File m4/42-stud-rep/423-tox/4234-carcigen/42343-other-stud/study-report-2.pdf
Comment
Number 4.2.3.4.3.3
Title Study Report 3
215 Element m4-2-3-4-3-other-studies
File m4/42-stud-rep/423-tox/4234-carcigen/42343-other-stud/study-report-3.pdf
Comment
Number 4.2.3.5
Reproductive and Developmental Toxicity (including range-finding studies and supportive toxicokinetics evaluations) (If modified study
Title
designs are used, the following subheadings should be modified accordingly)
216
Element m4-2-3-5-reproductive-and-developmental-toxicity
Directory m4/42-stud-rep/423-tox/4235-repro-dev-tox
Comment
217 Number 4.2.3.5.1
Title Fertility and early embryonic development
Element m4-2-3-5-1-fertility-and-early-embryonic-development
Page 4-38
Directory m4/42-stud-rep/423-tox/4235-repro-dev-tox/42351-fert-embryo-dev
Comment
Number 4.2.3.5.1.1
Title Study Report 1
218 Element m4-2-3-5-1-fertility-and-early-embryonic-development
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42351-fert-embryo-dev/study-report-1.pdf
Comment
Number 4.2.3.5.1.2
Title Study Report 2
219 Element m4-2-3-5-1-fertility-and-early-embryonic-development
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42351-fert-embryo-dev/study-report-2.pdf
Comment
Number 4.2.3.5.1.3
Title Study Report 3
220 Element m4-2-3-5-1-fertility-and-early-embryonic-development
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42351-fert-embryo-dev/study-report-3.pdf
Comment
Number 4.2.3.5.2
Title Embryo-fetal development
221 Element m4-2-3-5-2-embryo-fetal-development
Directory m4/42-stud-rep/423-tox/4235-repro-dev-tox/42352-embryo-fetal-dev
Comment
Number 4.2.3.5.2.1
Title Study Report 1
222 Element m4-2-3-5-2-embryo-fetal-development
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42352-embryo-fetal-dev/study-report-1.pdf
Comment
Number 4.2.3.5.2.2
Title Study Report 2
223 Element m4-2-3-5-2-embryo-fetal-development
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42352-embryo-fetal-dev/study-report-2.pdf
Comment
224 Number 4.2.3.5.2.3
Title Study Report 3
Page 4-39
Element m4-2-3-5-2-embryo-fetal-development
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42352-embryo-fetal-dev/study-report-3.pdf
Comment
Number 4.2.3.5.3
Title Prenatal and postnatal development, including maternal function
225 Element m4-2-3-5-3-prenatal-and-postnatal-development-including-maternal-function
Directory m4/42-stud-rep/423-tox/4235-repro-dev-tox/42353-pre-postnatal-dev
Comment
Number 4.2.3.5.3.1
Title Study Report 1
226 Element m4-2-3-5-3-prenatal-and-postnatal-development-including-maternal-function
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42353-pre-postnatal-dev/study-report-1.pdf
Comment
Number 4.2.3.5.3.2
Title Study Report 2
227 Element m4-2-3-5-3-prenatal-and-postnatal-development-including-maternal-function
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42353-pre-postnatal-dev/study-report-2.pdf
Comment
Number 4.2.3.5.3.3
Title Study Report 3
228 Element m4-2-3-5-3-prenatal-and-postnatal-development-including-maternal-function
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42353-pre-postnatal-dev/study-report-3.pdf
Comment
Number 4.2.3.5.4
Title Studies in which the offspring (juvenile animals) are dosed and/or further evaluated
229 Element m4-2-3-5-4-studies-in-which-the-offspring-juvenile-animals-are-dosed-and-or-further-evaluated
Directory m4/42-stud-rep/423-tox/4235-repro-dev-tox/42354-juv
Comment
Number 4.2.3.5.4.1
Title Study Report 1
230 Element m4-2-3-5-4-studies-in-which-the-offspring-juvenile-animals-are-dosed-and-or-further-evaluated
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42354-juv/study-report-1.pdf
Comment
231 Number 4.2.3.5.4.2
Title Study Report 2
Page 4-40
Element m4-2-3-5-4-studies-in-which-the-offspring-juvenile-animals-are-dosed-and-or-further-evaluated
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42354-juv/study-report-2.pdf
Comment
Number 4.2.3.5.4.3
Title Study Report 3
232 Element m4-2-3-5-4-studies-in-which-the-offspring-juvenile-animals-are-dosed-and-or-further-evaluated
File m4/42-stud-rep/423-tox/4235-repro-dev-tox/42354-juv/study-report-3.pdf
Comment
Number 4.2.3.6
Title Local Tolerance
233 Element m4-2-3-6-local-tolerance
Directory m4/42-stud-rep/423-tox/4236-loc-tol
Comment
Number 4.2.3.6.1
Title Study Report 1
234 Element m4-2-3-6-local-tolerance
File m4/42-stud-rep/423-tox/4236-loc-tol/study-report-1.pdf
Comment
Number 4.2.3.6.2
Title Study Report 2
235 Element m4-2-3-6-local-tolerance
File m4/42-stud-rep/423-tox/4236-loc-tol/study-report-2.pdf
Comment
Number 4.2.3.6.3
Title Study Report 3
236 Element m4-2-3-6-local-tolerance
File m4/42-stud-rep/423-tox/4236-loc-tol/study-report-3.pdf
Comment
Number 4.2.3.7
Title Other Toxicity Studies (if available)
237 Element m4-2-3-7-other-toxicity-studies
Directory m4/42-stud-rep/423-tox/4237-other-tox-stud
Comment
238 Number 4.2.3.7.1
Title Antigenicity
Page 4-41
Element m4-2-3-7-1-antigenicity
Directory m4/42-stud-rep/423-tox/4237-other-tox-stud/42371-antigen
Comment
Number 4.2.3.7.1.1
Title Study Report 1
239 Element m4-2-3-7-1-antigenicity
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42371-antigen/study-report-1.pdf
Comment
Number 4.2.3.7.1.2
Title Study Report 2
240 Element m4-2-3-7-1-antigenicity
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42371-antigen/study-report-2.pdf
Comment
Number 4.2.3.7.1.3
Title Study Report 3
241 Element m4-2-3-7-1-antigenicity
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42371-antigen/study-report-3.pdf
Comment
Number 4.2.3.7.2
Title Immunotoxicity
242 Element m4-2-3-7-2-immunotoxicity
Directory m4/42-stud-rep/423-tox/4237-other-tox-stud/42372-immunotox
Comment
Number 4.2.3.7.2.1
Title Study Report 1
243 Element m4-2-3-7-2-immunotoxicity
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42372-immunotox/study-report-1.pdf
Comment
Number 4.2.3.7.2.2
Title Study Report 2
244 Element m4-2-3-7-2-immunotoxicity
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42372-immunotox/study-report-2.pdf
Comment
245 Number 4.2.3.7.2.3
Page 4-42
Title Study Report 3
Element m4-2-3-7-2-immunotoxicity
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42372-immunotox/study-report-3.pdf
Comment
Number 4.2.3.7.3
Title Mechanistic studies (if not included elsewhere)
246 Element m4-2-3-7-3-mechanistic-studies
Directory m4/42-stud-rep/423-tox/4237-other-tox-stud/42373-mechan-stud
Comment
Number 4.2.3.7.3.1
Title Study Report 1
247 Element m4-2-3-7-3-mechanistic-studies
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42373-mechan-stud/study-report-1.pdf
Comment
Number 4.2.3.7.3.2
Title Study Report 2
248 Element m4-2-3-7-3-mechanistic-studies
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42373-mechan-stud/study-report-2.pdf
Comment
Number 4.2.3.7.3.3
Title Study Report 3
249 Element m4-2-3-7-3-mechanistic-studies
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42373-mechan-stud/study-report-3.pdf
Comment
Number 4.2.3.7.4
Title Dependence
250 Element m4-2-3-7-4-dependence
Directory m4/42-stud-rep/423-tox/4237-other-tox-stud/42374-dep
Comment
Number 4.2.3.7.4.1
Title Study Report 1
251 Element m4-2-3-7-4-dependence
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42374-dep/study-report-1.pdf
Comment
252 Number 4.2.3.7.4.2
Page 4-43
Title Study Report 2
Element m4-2-3-7-4-dependence
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42374-dep/study-report-2.pdf
Comment
Number 4.2.3.7.4.3
Title Study Report 3
253 Element m4-2-3-7-4-dependence
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42374-dep/study-report-3.pdf
Comment
Number 4.2.3.7.5
Title Metabolites
254 Element m4-2-3-7-5-metabolites
Directory m4/42-stud-rep/423-tox/4237-other-tox-stud/42375-metab
Comment
Number 4.2.3.7.5.1
Title Study Report 1
255 Element m4-2-3-7-5-metabolites
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42375-metab/study-report-1.pdf
Comment
Number 4.2.3.7.5.2
Title Study Report 2
256 Element m4-2-3-7-5-metabolites
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42375-metab/study-report-2.pdf
Comment
Number 4.2.3.7.5.3
Title Study Report 3
257 Element m4-2-3-7-5-metabolites
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42375-metab/study-report-3.pdf
Comment
Number 4.2.3.7.6
Title Impurities
258 Element m4-2-3-7-6-impurities
Directory m4/42-stud-rep/423-tox/4237-other-tox-stud/42376-imp
Comment
Page 4-44
Number 4.2.3.7.6.1
Title Study Report 1
259 Element m4-2-3-7-6-impurities
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42376-imp/study-report-1.pdf
Comment
Number 4.2.3.7.6.2
Title Study Report 2
260 Element m4-2-3-7-6-impurities
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42376-imp/study-report-2.pdf
Comment
Number 4.2.3.7.6.3
Title Study Report 3
261 Element m4-2-3-7-6-impurities
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42376-imp/study-report-3.pdf
Comment
Number 4.2.3.7.7
Title Other
262 Element m4-2-3-7-7-other
Directory m4/42-stud-rep/423-tox/4237-other-tox-stud/42377-other
Comment
Number 4.2.3.7.7.1
Title Study Report 1
263 Element m4-2-3-7-7-other
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42377-other/study-report-1.pdf
Comment
Number 4.2.3.7.7.2
Title Study Report 2
264 Element m4-2-3-7-7-other
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42377-other/study-report-2.pdf
Comment
265 Number 4.2.3.7.7.3
Title Study Report 3
Element m4-2-3-7-7-other
File m4/42-stud-rep/423-tox/4237-other-tox-stud/42377-other/study-report-3.pdf
Page 4-45
Comment
Number 4.3
Title Literature References
266 Element m4-3-literature-references
Directory m4/43-lit-ref
Comment Copies of literature references should ordinarily be submitted as individual files (i.e., one for each reference).
Number 4.3.1
Title Reference 1
267 Element m4-3-literature-references
File m4/43-lit-ref/reference-1.pdf
Comment
Number 4.3.2
Title Reference 2
268 Element m4-3-literature-references
File m4/43-lit-ref/reference-2.pdf
Comment
Number 4.3.3
Title Reference 3
269 Element m4-3-literature-references
File m4/43-lit-ref/reference-3.pdf
Comment
Page 4-46
Number 5
Title Clinical Study Reports
270 Element m5-clinical-study-reports
Directory m5
Comment
Number 5.2
Title Tabular Listing of all Clinical Studies
271 Element m5-2-tabular-listing-of-all-clinical-studies
Directory m5/52-tab-list
Comment
Number 5.2
Title Tabular Listing of all Clinical Studies
272 Element m5-2-tabular-listing-of-all-clinical-studies
File m5/52-tab-list/tabular-listing.pdf
Comment
Number 5.3
Title Clinical Study Reports
273 Element m5-3-clinical-study-reports
Directory m5/53-clin-stud-rep
Comment
Number 5.3.1
Title Reports of Biopharmaceutic Studies
274 Element m5-3-1-reports-of-biopharmaceutic-studies
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud
Comment
Number 5.3.1.1
Title Bioavailability (BA) Study Reports
275 Element m5-3-1-1-bioavailability-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5311-ba-stud-rep
Comment
276 Number 5.3.1.1.1
Title Study Report 1
Element m5-3-1-1-bioavailability-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5311-ba-stud-rep/study-report-1
Page 4-47
The applicants should ordinarily provide the study reports as multiple files (a synopsis, a main body and appropriate appendices).
Appendices should be organized in accordance with the ICH E3 guideline which describes the content and format of the clinical study
report. In choosing the level of granularity for reports the applicant should consider that, when relevant information is changed at any point
in the product's lifecycle, replacements of complete documents/files should be provided.
Comment
It is possible to have the additional graphic file(s) inserted directly into the PDF file, thus making management of the file easier.
Alternatively, the applicant can choose to manage these graphic files independently.
This comment is applicable to all study reports in Module 5.
A directory should be created for each study and the files associated with the study report should be organized within the directory.
Number 5.3.1.1.2
Title Study Report 2
277 Element m5-3-1-1-bioavailability-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5311-ba-stud-rep/study-report-2
Comment
Number 5.3.1.1.3
Title Study Report 3
278 Element m5-3-1-1-bioavailability-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5311-ba-stud-rep/study-report-3
Comment
Number 5.3.1.2
Title Comparative BA and Bioequivalence (BE) Study Reports
279 Element m5-3-1-2-comparative-ba-and-bioequivalence-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5312-compar-ba-be-stud-rep
Comment
Number 5.3.1.2.1
Title Study Report 1
280 Element m5-3-1-2-comparative-ba-and-bioequivalence-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5312-compar-ba-be-stud-rep/study-report-1
Comment
Number 5.3.1.2.2
Title Study Report 2
281 Element m5-3-1-2-comparative-ba-and-bioequivalence-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5312-compar-ba-be-stud-rep/study-report-2
Comment
282 Number 5.3.1.2.3
Title Study Report 3
Page 4-48
Element m5-3-1-2-comparative-ba-and-bioequivalence-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5312-compar-ba-be-stud-rep/study-report-3
Comment
Number 5.3.1.3
Title In vitro – In vivo Correlation Study Reports
283 Element m5-3-1-3-in-vitro-in-vivo-correlation-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5313-in-vitro-in-vivo-corr-stud-rep
Comment
Number 5.3.1.3.1
Title Study Report 1
284 Element m5-3-1-3-in-vitro-in-vivo-correlation-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5313-in-vitro-in-vivo-corr-stud-rep/study-report-1
Comment
Number 5.3.1.3.2
Title Study Report 2
285 Element m5-3-1-3-in-vitro-in-vivo-correlation-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5313-in-vitro-in-vivo-corr-stud-rep/study-report-2
Comment
Number 5.3.1.3.3
Title Study Report 3
286 Element m5-3-1-3-in-vitro-in-vivo-correlation-study-reports
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5313-in-vitro-in-vivo-corr-stud-rep/study-report-3
Comment
Number 5.3.1.4
Title Reports of Bioanalytical and Analytical Methods for Human Studies
287 Element m5-3-1-4-reports-of-bioanalytical-and-analytical-methods-for-human-studies
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5314-bioanalyt-analyt-met
Comment
Number 5.3.1.4.1
Title Study Report 1
288 Element m5-3-1-4-reports-of-bioanalytical-and-analytical-methods-for-human-studies
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5314-bioanalyt-analyt-met/study-report-1
Comment
289 Number 5.3.1.4.2
Title Study Report 2
Page 4-49
Element m5-3-1-4-reports-of-bioanalytical-and-analytical-methods-for-human-studies
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5314-bioanalyt-analyt-met/study-report-2
Comment
Number 5.3.1.4.3
Title Study Report 3
290 Element m5-3-1-4-reports-of-bioanalytical-and-analytical-methods-for-human-studies
Directory m5/53-clin-stud-rep/531-rep-biopharm-stud/5314-bioanalyt-analyt-met/study-report-3
Comment
Number 5.3.2
Title Reports of Studies Pertinent to Pharmacokinetics using Human Biomaterials
291 Element m5-3-2-reports-of-studies-pertinent-to-pharmacokinetics-using-human-biomaterials
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat
Comment
Number 5.3.2.1
Title Plasma Protein Binding Study Reports
292 Element m5-3-2-1-plasma-protein-binding-study-reports
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5321-plasma-prot-bind-stud-rep
Comment
Number 5.3.2.1.1
Title Study Report 1
293 Element m5-3-2-1-plasma-protein-binding-study-reports
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5321-plasma-prot-bind-stud-rep/study-report-1
Comment
Number 5.3.2.1.2
Title Study Report 2
294 Element m5-3-2-1-plasma-protein-binding-study-reports
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5321-plasma-prot-bind-stud-rep/study-report-2
Comment
Number 5.3.2.1.3
Title Study Report 3
295 Element m5-3-2-1-plasma-protein-binding-study-reports
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5321-plasma-prot-bind-stud-rep/study-report-3
Comment
296 Number 5.3.2.2
Title Reports of Hepatic Metabolism and Drug Interaction Studies
Page 4-50
Element m5-3-2-2-reports-of-hepatic-metabolism-and-drug-interaction-studies
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5322-rep-hep-metab-interact-stud
Comment
Number 5.3.2.2.1
Title Study Report 1
297 Element m5-3-2-2-reports-of-hepatic-metabolism-and-drug-interaction-studies
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5322-rep-hep-metab-interact-stud/study-report-1
Comment
Number 5.3.2.2.2
Title Study Report 2
298 Element m5-3-2-2-reports-of-hepatic-metabolism-and-drug-interaction-studies
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5322-rep-hep-metab-interact-stud/study-report-2
Comment
Number 5.3.2.2.3
Title Study Report 3
299 Element m5-3-2-2-reports-of-hepatic-metabolism-and-drug-interaction-studies
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5322-rep-hep-metab-interact-stud/study-report-3
Comment
Number 5.3.2.3
Title Reports of Studies Using Other Human Biomaterials
300 Element m5-3-2-3-reports-of-studies-using-other-human-biomaterials
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5323-stud-other-human-biomat
Comment
Number 5.3.2.3.1
Title Study Report 1
301 Element m5-3-2-3-reports-of-studies-using-other-human-biomaterials
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5323-stud-other-human-biomat/study-report-1
Comment
Number 5.3.2.3.2
Title Study Report 2
302 Element m5-3-2-3-reports-of-studies-using-other-human-biomaterials
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5323-stud-other-human-biomat/study-report-2
Comment
303 Number 5.3.2.3.3
Title Study Report 3
Page 4-51
Element m5-3-2-3-reports-of-studies-using-other-human-biomaterials
Directory m5/53-clin-stud-rep/532-rep-stud-pk-human-biomat/5323-stud-other-human-biomat/study-report-3
Comment
Number 5.3.3
Title Reports of Human Pharmacokinetic (PK) Studies
304 Element m5-3-3-reports-of-human-pharmacokinetics-pk-studies
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud
Comment
Number 5.3.3.1
Title Healthy Subject PK and Initial Tolerability Study Reports
305 Element m5-3-3-1-healthy-subject-pk-and-initial-tolerability-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5331-healthy-subj-pk-init-tol-stud-rep
Comment
Number 5.3.3.1.1
Title Study Report 1
306 Element m5-3-3-1-healthy-subject-pk-and-initial-tolerability-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5331-healthy-subj-pk-init-tol-stud-rep/study-report-1
Comment
Number 5.3.3.1.2
Title Study Report 2
307 Element m5-3-3-1-healthy-subject-pk-and-initial-tolerability-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5331-healthy-subj-pk-init-tol-stud-rep/study-report-2
Comment
Number 5.3.3.1.3
Title Study Report 3
308 Element m5-3-3-1-healthy-subject-pk-and-initial-tolerability-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5331-healthy-subj-pk-init-tol-stud-rep/study-report-3
Comment
Number 5.3.3.2
Title Patient PK and Initial Tolerability Study Reports
309 Element m5-3-3-2-patient-pk-and-initial-tolerability-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5332-patient-pk-init-tol-stud-rep
Comment
310 Number 5.3.3.2.1
Page 4-52
Title Study Report 1
Element m5-3-3-2-patient-pk-and-initial-tolerability-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5332-patient-pk-init-tol-stud-rep/study-report-1
Comment
Number 5.3.3.2.2
Title Study Report 2
311 Element m5-3-3-2-patient-pk-and-initial-tolerability-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5332-patient-pk-init-tol-stud-rep/study-report-2
Comment
Number 5.3.3.2.3
Title Study Report 3
312 Element m5-3-3-2-patient-pk-and-initial-tolerability-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5332-patient-pk-init-tol-stud-rep/study-report-3
Comment
Number 5.3.3.3
Title Intrinsic Factor PK Study Reports
313 Element m5-3-3-3-intrinsic-factor-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5333-intrin-factor-pk-stud-rep
Comment
Number 5.3.3.3.1
Title Study Report 1
314 Element m5-3-3-3-intrinsic-factor-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5333-intrin-factor-pk-stud-rep/study-report-1
Comment
Number 5.3.3.3.2
Title Study Report 2
315 Element m5-3-3-3-intrinsic-factor-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5333-intrin-factor-pk-stud-rep/study-report-2
Comment
Number 5.3.3.3.3
Title Study Report 3
316 Element m5-3-3-3-intrinsic-factor-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5333-intrin-factor-pk-stud-rep/study-report-3
Comment
317 Number 5.3.3.4
Page 4-53
Title Extrinsic Factor PK Study Reports
Element m5-3-3-4-extrinsic-factor-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5334-extrin-factor-pk-stud-rep
Comment
Number 5.3.3.4.1
Title Study Report 1
318 Element m5-3-3-4-extrinsic-factor-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5334-extrin-factor-pk-stud-rep/study-report-1
Comment
Number 5.3.3.4.2
Title Study Report 2
319 Element m5-3-3-4-extrinsic-factor-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5334-extrin-factor-pk-stud-rep/study-report-2
Comment
Number 5.3.3.4.3
Title Study Report 3
320 Element m5-3-3-4-extrinsic-factor-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5334-extrin-factor-pk-stud-rep/study-report-3
Comment
Number 5.3.3.5
Title Population PK Study Reports
321 Element m5-3-3-5-population-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5335-popul-pk-stud-rep
Comment
Number 5.3.3.5.1
Title Study Report 1
322 Element m5-3-3-5-population-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5335-popul-pk-stud-rep/study-report-1
Comment
Number 5.3.3.5.2
Title Study Report 2
323 Element m5-3-3-5-population-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5335-popul-pk-stud-rep/study-report-2
Comment
Page 4-54
Number 5.3.3.5.3
Title Study Report 3
324 Element m5-3-3-5-population-pk-study-reports
Directory m5/53-clin-stud-rep/533-rep-human-pk-stud/5335-popul-pk-stud-rep/study-report-3
Comment
Number 5.3.4
Title Reports of Human Pharmacodynamic (PD) Studies
325 Element m5-3-4-reports-of-human-pharmacodynamics-pd-studies
Directory m5/53-clin-stud-rep/534-rep-human-pd-stud
Comment
Number 5.3.4.1
Title Healthy Subject PD and PK/PD Study Reports
326 Element m5-3-4-1-healthy-subject-pd-and-pk-pd-study-reports
Directory m5/53-clin-stud-rep/534-rep-human-pd-stud/5341-healthy-subj-pd-stud-rep
Comment
Number 5.3.4.1.1
Title Study Report 1
327 Element m5-3-4-1-healthy-subject-pd-and-pk-pd-study-reports
Directory m5/53-clin-stud-rep/534-rep-human-pd-stud/5341-healthy-subj-pd-stud-rep/study-report-1
Comment
Number 5.3.4.1.2
Title Study Report 2
328 Element m5-3-4-1-healthy-subject-pd-and-pk-pd-study-reports
Directory m5/53-clin-stud-rep/534-rep-human-pd-stud/5341-healthy-subj-pd-stud-rep/study-report-2
Comment
Number 5.3.4.1.3
Title Study Report 3
329 Element m5-3-4-1-healthy-subject-pd-and-pk-pd-study-reports
Directory m5/53-clin-stud-rep/534-rep-human-pd-stud/5341-healthy-subj-pd-stud-rep/study-report-3
Comment
330 Number 5.3.4.2
Title Patient PD and PK/PD Study Reports
Element m5-3-4-2-patient-pd-and-pk-pd-study-reports
Directory m5/53-clin-stud-rep/534-rep-human-pd-stud/5342-patient-pd-stud-rep
Page 4-55
Comment
Number 5.3.4.2.1
Title Study Report 1
331 Element m5-3-4-2-patient-pd-and-pk-pd-study-reports
Directory m5/53-clin-stud-rep/534-rep-human-pd-stud/5342-patient-pd-stud-rep/study-report-1
Comment
Number 5.3.4.2.2
Title Study Report 2
332 Element m5-3-4-2-patient-pd-and-pk-pd-study-reports
Directory m5/53-clin-stud-rep/534-rep-human-pd-stud/5342-patient-pd-stud-rep/study-report-2
Comment
Number 5.3.4.2.3
Title Study Report 3
333 Element m5-3-4-2-patient-pd-and-pk-pd-study-reports
Directory m5/53-clin-stud-rep/534-rep-human-pd-stud/5342-patient-pd-stud-rep/study-report-3
Comment
Number 5.3.5
Title Reports of Efficacy and Safety Studies
334 Element m5-3-5-reports-of-efficacy-and-safety-studies
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud
Comment
Number 5.3.5
Title Reports of Efficacy and Safety Studies - Indication Name
Element m5-3-5-reports-of-efficacy-and-safety-studies
335
Directory
m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1
The folder name should always include the indication being claimed, for example, 'asthma' (abbreviated if appropriate). Where there is
Comment
more than one indication (e.g., asthma and migraine), then the first indication has a folder 'asthma' and the second 'migraine'.
Number 5.3.5.1
Title Study Reports of Controlled Clinical Studies Pertinent to the Claimed Indication
336 Element m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-claimed-indication
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5351-stud-rep-contr
Comment
337 Number 5.3.5.1.1
Title Study Report 1
Element m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-claimed-indication
Page 4-56
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5351-stud-rep-contr/study-report-1
Comment
Number 5.3.5.1.2
Title Study Report 2
338 Element m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-claimed-indication
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5351-stud-rep-contr/study-report-2
Comment
Number 5.3.5.1.3
Title Study Report 3
339 Element m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-claimed-indication
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5351-stud-rep-contr/study-report-3
Comment
Number 5.3.5.2
Title Study Reports of Uncontrolled Clinical Studies
340 Element m5-3-5-2-study-reports-of-uncontrolled-clinical-studies
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5352-stud-rep-uncontr
Comment
Number 5.3.5.2.1
Title Study Report 1
341 Element m5-3-5-2-study-reports-of-uncontrolled-clinical-studies
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5352-stud-rep-uncontr/study-report-1
Comment
Number 5.3.5.2.2
Title Study Report 2
342 Element m5-3-5-2-study-reports-of-uncontrolled-clinical-studies
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5352-stud-rep-uncontr/study-report-2
Comment
Number 5.3.5.2.3
Title Study Report 3
343 Element m5-3-5-2-study-reports-of-uncontrolled-clinical-studies
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5352-stud-rep-uncontr/study-report-3
Comment
344 Number 5.3.5.3
Title Reports of Analyses of Data from More than One Study
Element m5-3-5-3-reports-of-analyses-of-data-from-more-than-one-study
Page 4-57
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5353-rep-analys-data-more-one-stud
Comment
Number 5.3.5.3.1
Title Study Report 1
345 Element m5-3-5-3-reports-of-analyses-of-data-from-more-than-one-study
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5353-rep-analys-data-more-one-stud/study-report-1
Comment
Number 5.3.5.3.2
Title Study Report 2
346 Element m5-3-5-3-reports-of-analyses-of-data-from-more-than-one-study
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5353-rep-analys-data-more-one-stud/study-report-2
Comment
Number 5.3.5.3.3
Title Study Report 3
347 Element m5-3-5-3-reports-of-analyses-of-data-from-more-than-one-study
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5353-rep-analys-data-more-one-stud/study-report-3
Comment
Number 5.3.5.4
Title Other Study Reports
348 Element m5-3-5-4-other-study-reports
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5354-other-stud-rep
Comment
Number 5.3.5.4.1
Title Study Report 1
349 Element m5-3-5-4-other-study-reports
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5354-other-stud-rep/study-report-1
Comment
Number 5.3.5.4.2
Title Study Report 2
350 Element m5-3-5-4-other-study-reports
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5354-other-stud-rep/study-report-2
Comment
351 Number 5.3.5.4.3
Title Study Report 3
Page 4-58
Element m5-3-5-4-other-study-reports
Directory m5/53-clin-stud-rep/535-rep-effic-safety-stud/indication-1/5354-other-stud-rep/study-report-3
Comment
Number 5.3.6
Title Reports of Postmarketing Experience
352 Element m5-3-6-reports-of-postmarketing-experience
Directory m5/53-clin-stud-rep/536-postmark-exp
Comment
Number 5.3.7
Title Case Report Forms and Individual Patient Listings
353 Element m5-3-7-case-report-forms-and-individual-patient-listings
Directory m5/53-clin-stud-rep/537-crf-ipl
Comment
Number 5.3.7.1
Title Study 1
354 Element m5-3-7-case-report-forms-and-individual-patient-listings
Directory m5/53-clin-stud-rep/537-crf-ipl/study-1
Comment
Number5.3.7.1.1
Title Document/Dataset 1
Element
m5-3-7-case-report-forms-and-individual-patient-listings
355
File m5/53-clin-stud-rep/537-crf-ipl/study-1/filename-1.pdf
The filename and extension should include the description of the file and appropriate file extension according to Appendix 2. Reference
Comment
should be made to regional guidance for the acceptability of submission of datasets
Number 5.3.7.1.2
Title Document/Dataset 2
356 Element m5-3-7-case-report-forms-and-individual-patient-listings
File m5/53-clin-stud-rep/537-crf-ipl/study-1/filename-2.pdft
Comment
Number 5.3.7.1.3
Title Document/Dataset 3
357 Element m5-3-7-case-report-forms-and-individual-patient-listings
File m5/53-clin-stud-rep/537-crf-ipl/study-1/filename-3.pdf
Comment
Page 4-59
Number 5.3.7.2
Title Study 2
358 Element m5-3-7-case-report-forms-and-individual-patient-listings
Directory m5/53-clin-stud-rep/537-crf-ipl/study-2
Comment define element
Number 5.3.7.2.1
Title Document/Dataset 1
359 Element m5-3-7-case-report-forms-and-individual-patient-listings
File m5/53-clin-stud-rep/537-crf-ipl/study-2/filename-1.pdf
Comment
Number 5.3.7.2.2
Title Document/Dataset 2
360 Element m5-3-7-case-report-forms-and-individual-patient-listings
File m5/53-clin-stud-rep/537-crf-ipl/study-2/filename-2.pdf
Comment
Number 5.3.7.2.3
Title Document/Dataset 3
361 Element m5-3-7-case-report-forms-and-individual-patient-listings
File m5/53-clin-stud-rep/537-crf-ipl/study-2/filename-3.pdf
Comment
Number 5.3.7.3
Title Study 3
362 Element m5-3-7-case-report-forms-and-individual-patient-listings
Directory m5/53-clin-stud-rep/537-crf-ipl/study-3
Comment define element
Number 5.3.7.3.1
Title Document/Dataset 1
363 Element m5-3-7-case-report-forms-and-individual-patient-listings
File m5/53-clin-stud-rep/537-crf-ipl/study-3/filename-1.pdf
Comment
364 Number 5.3.7.3.2
Title Document/Dataset 2
Element m5-3-7-case-report-forms-and-individual-patient-listings
File m5/53-clin-stud-rep/537-crf-ipl/study-3/filename-2.pdf
Page 4-60
Comment
Number 5.3.7.3.3
Title Document/Dataset 3
365 Element m5-3-7-case-report-forms-and-individual-patient-listings
File m5/53-clin-stud-rep/537-crf-ipl/study-3/filename-3.pdf
Comment
Number 5.4
Title Literature References
366 Element m5-4-literature-references
Directory m5/54-lit-ref
Comment Copies of literature references should ordinarily be submitted as individual files (i.e,. one for each reference).
Number 5.4.1
Title Reference 1
367 Element m5-4-literature-references
File m5/54-lit-ref/reference-1.pdf
Comment
Number 5.4.2
Title Reference 2
368 Element m5-4-literature-references
File m5/54-lit-ref/reference-2.pdf
Comment
Number 5.4.3
Title Reference 3
369 Element m5-4-literature-references
File m5/54-lit-ref/reference-3.pdf
Comment
Page 4-61
Number
Title
370 Element
Directory util
Comment utilities
Number
Title
371 Element
Directory util/dtd
Comment DTDs – it is not necessary to include regional DTDs other than the one for the region to which the application is being made
Number
Title
372 Element
File util/dtd/ich-ectd-3-2.dtd
Comment DTD for the instance – the version used to create the eCTD submission must be included
Number
Title
373 Element
File util/dtd/eu-regional-1-0.dtd
Comment DTD for the EU specific documentation
Number
Title
374 Element
File util/dtd/jp-regional-1-0.dtd
Comment DTD for the Japan specific documentation
Number
Title
375 Element
File util/dtd/us-regional-1-0.dtd
Comment DTD for the US specific documentation
376 Number
Title
Element
Page 4-62
File util/dtd/xx-regional-1-0.dtd
Comment DTD for the xx specific documentation, where xx is a two character country code from ISO-3166-1
Number
Title
377 Element
Directory util/style
Comment Directory for style sheets – default (ICH) and applicant specific stylesheets
Number
Title
378 Element
File util/style/ectd-1-0.xsl
Comment The specific version of the eCTD stylesheet used by the applicant as a reference during the creation of the submission should be included.
Page 4-63
Appendix 5: Region Specific Information Including Transmission and
Receipt
Introduction
This section describes region specific information for content that is not explicitly included in the Common
Technical Document and logistical details appropriate for the transmission and receipt of submissions using
the electronic Common Technical Document.
Regional guidance will provide the specific instructions on how to provide the administrative forms and
detailed prescribing information. Please refer to this information and appendix 6 when preparing module 1.
Module 1 includes all administrative documents (e.g., forms and certifications) and labeling, including the
documents described in regional guidance.
Not all regionally specific documents are included in module 1. Technical reports required for a specific
region should be placed in modules 2 to 5. These reports should be included in the module most appropriate
for the content of the information provided.
Each region provides specific guidance on the format and content of the regional requirements of each
module. Table 5-1 provides contact information for each region.
Table 5-1
Region Internet Address Electronic Mail Contact
European Union http://www.emea.eu.int esubmission@emea.eu.int
Food And Drug Administration, http://www.fda.gov/cber Esubprep@cber.fda.gov
USA http://www.fda.gov/cder esub@cder.fda.gov
Submission Addresses
Submissions should be sent directly to the appropriate regulatory authority. Information needed to send
physical media to each regulatory authority is found at the reference location in Table 5-2.
Table 5-2
Regulatory Authority Reference location
EMEA, European Union http://www.eudra.org/
or national agencies http://heads.medagencies.org
Ministry of Health, Labour and Welfare, Japan http://www.mhlw.go.jp
http://www.nihs.go.jp
Food and Drug Administration, United States of http://www.fda.gov/
America
Health Canada, Health Protection Branch, Canada http://www.hc-sc.gc.ca/hpb-dgps/therapeut
Page 5-1
Media
Refer to the M2 recommendations on the ICH Website for a list of media types accepted by all ICH
regions.
Cover Letter
Applicants should provide a cover letter as a PDF file (cover.pdf). A paper cover letter should also be
included with non-electronic portions of the submission (such as forms with signatures or seals, and
certifications). The cover letter should include:
Transport
Secure data exchange over the Internet is the recommended means for transporting submissions. However,
until the regulatory authorities can develop secure electronic gateways, submissions should continue to be
physically transported by courier or registered mail.
Security
An MD5 checksum should be included for each physical file in the eCTD. The checksum allows the
recipient to verify integrity of the physical files in the submission. The XML eCTD DTD provides the
location of the files and a tag name contains the checksums.
A checksum of the XML eCTD instance should also be included. Applicants should name this checksum
file index-md5.txt and include it as a file in the same directory as the XML eCTD instance. Applicants
should print the contents of the index-md5.txt file and include the paper copy with the paper cover letter for
the submission.
An applicant can provide the eCTD as an encrypted file in accordance with the ICH M2 Recommendation
4.1, if the regulatory body has implemented it. This solution allows the eCTD to be encrypted and
transferred over the Internet (if Internet receipt is implemented regionally) or to be encrypted on one of the
approved physical media standards. The purpose of encryption is to protect the privacy of the confidential
information and to ensure it is only available to the authorized receiver. Encryption is always appropriate
when the eCTD is sent via the Internet.
Encryption is not considered necessary if the information is sent using a physical media, although
encryption is an option. The applicant should assume all liability for the media until it is delivered to the
regulatory authority.
Page 5-2
Applicants should not include any file level security settings or password protection for individual files in
the eCTD. Applicants should allow printing, changes to the document, selecting text and graphics, and
adding or changing notes and form fields. Internal security and access control processes in the regulatory
authority should maintain the integrity of the submitted files.
Receipt
Upon arrival at the regulatory authority, the submission is archived according to local regulations. A read-
only copy of the submission is then made available to the review community in the regulatory authority.
This is typically done by placing the copy on a network server.
Acknowledgment
Each regulatory authority should acknowledge the receipt of the eCTD submission according to the policy
and procedure of the individual regulatory authority. Applicants should use the address in Table 5-1 to find
guidance regarding acknowledgments.
Page 5-3
Appendix 6: The eCTD XML Submission
Background
Many factors have influenced the design of the eCTD. Factors that have had a significant impact on the
design are listed below:
• The submissions should accommodate full regulatory dossiers, supplements, amendments, and
variations.
• The submissions should be able to accommodate regional requirements that are represented in
regional guidance documents, regulations, and statutes.
• The technology should be extensible so that as technology changes, the new electronic solutions
can be accommodated.
The eCTD is designed around the concept of a backbone. The backbone is similar to a container that holds
the files that are part of the submission. The backbone is based on an XML Document Type Definition
(DTD). There is a close relationship between the logical documents defined in the CTD and entities in the
backbone. The backbone will provide the navigation links to the various files and information that make
up the submission.
The file that is produced based on the XML eCTD DTD is the eCTD XML instance or XML backbone.
The XML backbone allows more than one entry or link to point to the same physical file. This should be
done with caution since managing the life cycle of that file can be more difficult for the regulatory
authority if there is more than one pointer to the file.
In order to preserve the navigational linkages that can be present in the documents contained in the eCTD,
the directory structure should be preserved by the agencies. The navigational links should be relative links
within a module.
Specific folder and file names have been defined in appendix 4. The top level of the directory structure
will vary by region. The identification of the top-level folder uniquely identifies the submission in a
region. The submission identification should be used as the folder name in the top-level directory. For
example, if the submission number were CTD 123456, the root directory would be named “ctd-123456”.
The original submission and subsequent amendments and variations should use the same top-level folder
name. Submissions should be differentiated by a subfolder named according to the sequence number of the
submission in that region. Table 6-1 and Figure 6-1 illustrate this naming convention.
Table 6-1
Submission number Sequence number Type of submission
ctd-123456 0000 Original Submission
ctd-123456 0001 First amendment, supplement or
variation
ctd-123456 0002 Second amendment, supplement
or variation
…
ctd-123456 nnnn Nth amendment, supplement or
variation
Page 6-1
Figure 6-1
You should submit the XML backbone as a single file named index.xml, which should be placed in the
submission sequence number folder for that submission. In the example shown in Figure 6-1, there should
be an index.xml file in folder “0000”, folder “0001” and folder “0002”. The MD5 checksum file, index-
md5.txt, should be in each folder with the corresponding index.xml file. The DTD for index.xml should be
in the “util” folder for each submission.
The regional administrative XML backbone file, if supplied, should be in the region specific module 1
folder for each submission. The DTD for the regional XML backbone file should be in the util folder for
each submission.
Table 6-2 presents the file locations for the example in Figure 6-1.
Table 6-2
Submission Folder Files
ctd-123456/0000 index.xml
index-md5.txt
ctd-123456/0000/m1/us us-regional.xml
ctd-123456/0000/util ich-ectd-3-2.dtd
us-regional-1-0.dtd
ctd-123456/0001 index.xml
index-md5.txt
ctd-123456/0001/m1/us us-regional.xml
ctd-123456/0001/util/dtd ich-ectd-3-2.dtd
us-regional-1-0.dtd
ctd-123456/0002 index.xml
index-md5.txt
ctd-123456/0002/m1/us us-regional.xml
ctd-123456/0002/util/dtd ich-ectd-3-2.dtd
us-regional-1-0.dtd
Lifecycle Management
It is important for the recipients of an eCTD to be able to establish the location of the submission in the
lifecycle of a product.
The eCTD is capable of containing initial submissions, supplements, amendments, and variations. There
are no uniform definitions for these terms in the three regions, but amendments and supplements are terms
used in the United States. Variations apply in Europe. The variations, supplements, and amendments are
used to provide additional information to an original regulatory dossier. For example, if a new
manufacturer for the drug substance were being proposed, this would result in submission of an amendment
or supplement to the FDA and a variation to Europe. When regulatory authorities request additional
information, the information is also provided as a variation, supplement, or amendment to the original
Page 6-2
submission. Therefore, the regulatory agencies should have a way to manage the lifecycle of the
submission. This function should be provided by each regulatory authority in the form of guidance that can
include regional DTDs and specifications. The relevant regional DTD should be referenced in the eCTD
DTD by the applicant.
The eCTD DTD provides some facilities for lifecycle management at the file level but does not fully
support the life cycle at the submission level. When revisions are sent to a regulatory authority, the new
file should be submitted as a leaf element associated with the same tag name as the file being amended or
deleted. The “modified-file” attribute of the leaf element should contain the leaf ID of the file being
amended, replaced, or deleted. This will allow the regulatory authority to accurately locate the original file
and update the original file’s status. A detailed description of modified-file is provided in the next section.
Operation Attribute
The operation attribute is a key to managing each individual file in a submission. The applicant uses the
operation attribute to tell the regulatory authority how the applicant intends the files in the submission to be
used. The operation attribute describes the relation between files in subsequent submissions during the life
cycle of a medicinal product. In the very first submission all the files will be new. In the second, third, and
subsequent submissions, all the newly submitted files can have different operation attributes due to having
or not having a relation with previously submitted files. Table 6-2 describes the meaning of each allowed
value of the operation attribute.
The purpose of the modified-file attribute is to provide the location of a document that is being modified
(i.e. replaced, appended or deleted) by the leaf element. The modified-file attribute should have a value
when the operation attribute has a value of append, replace or delete. The modified-file attribute points to
the “index.xml” file and the leaf ID of the file being altered.
modified-file="../0001/index.xml#a1234567"
This would provide the information needed to locate the file with the leaf element ID assigned as
"a1234567" and provided in the sequence folder numbered "0001".
Page 6-3
If a modified-file attribute is presented with no value (i.e. no characters or spaces between the quotation
marks, modified-file="") it will be the same as not including the attribute in the leaf element.
The following case examples show the use of each of the operation attribute values. These examples do not
cover all possible situations. Consult the appropriate regulatory authority if you have specific questions
about the use of the operation attribute. When actually populating the XML instance, use the leaf ID to
refer to files.
Case 2 – Two submissions. Submission 0000 is the first submission of a dossier. Submission 0001 is a
subsequent amendment or variation in which the applicant intends to completely replace the structure.pdf
file in submission 0000. The intent is to keep the original structure.pdf for historical purposes but to
consider only the contents of the 0001\…\structure.pdf as relevant to the review. These two submissions
could be described as follows:
- Submission 0000 is the first submission of the file structure.pdf, and this file is the current
version of this file.
- Submission 0001, which is submitted at a later time, is the submission of the file
structure.pdf, which is now current and replaces the file structure.pdf in submission 0000.
Table 6-5
Submission File name Operation File Being Modified Sample logical display
sequence # in a review tool
0000 0000\…\structure.pdf New structure.pdf (current)
0001 0001\…\structure.pdf Replace 0000\…\structure.pdf structure.pdf (replaced)
structure.pdf (current)
Case 3 – Two submissions. Submission 0000 is the first submission of a dossier. Submission 0001 is an
amendment or variation where the applicant intends to add new information to the original structure.pdf
file, which was submitted in submission 0000. The intent is to have the reviewer consider the contents of
both files relevant to the submission. These two submissions could be described as follows:
- Submission 0000 is the first submission of the file structure.pdf, and this file is the current
version of this file.
- Submission 0001, submitted at a later time, is the submission of the file structure.pdf, which
is the current file but contains information that should be appended to file structure.pdf in
submission 0000. Both files should be considered relevant to the review of the dossier.
Table 6-6
Submission File name Operation Modified file Sample logical
sequence # display in a review
tool
0000 0000\…\structure.pdf New structure.pdf (current)
0001 0001\…\structure.pdf Append 0000\...\structure.pdf structure.pdf (current -
appended)
structure.pdf (current)
Case 4 – Two submissions. Submission 0000 is the first submission of a dossier. Submission 0001 is an
amendment or variation where the applicant intends to delete a file in the previous submission. The intent
Page 6-4
is to have the reviewer disregard the contents of the original file, possibly because it should not have been
submitted with the original dossier. These two submissions could be described as follows:
- Submission 0000 is the first submission of the file structure.pdf and this file is the current
version of this file.
- Submission 0001, submitted at a later time, requests that the file structure.pdf in submission
0000 be deleted and no longer considered relevant to the review of the dossier.
Table 6-7
Submission File name Operation File Being Sample logical display in
sequence # Modified a review tool
0000 0000\...\structure.pdf New structure.pdf (current)
0001 Delete 0000\...\structure.pdf structure.pdf (no longer
relevant to the review)
Page 6-5
Once the appropriate tag has been selected, use the <leaf> element and attributes to specify a file in the
submission. See “Instructions for preparing the eCTD” in this appendix for details.
Page 6-6
eCTD Element/Attribute Instructions
The eCTD consists of 5 primary modules:
• m1-administrative-information-and-prescribing-information
• m2-common-technical-document-summaries
• m3-quality
• m4-nonclinical-study-reports
• m5-clinical-study-reports
Each of the 5 modules is divided into sub elements, each with a distinct <tag> that represents a CTD table
of contents location. The steps should be completed as shown in the following example, where all files are
submitted for modules 1 through 5:
1. You should select a tag element that best corresponds to the CTD table of contents location for a
document or file being submitted. For example, select the tag <m2-4-nonclinical-overview> to submit
the nonclinical overview document.
2. You should create a child <leaf> element underneath the <m2-4-nonclinical-overview> tag.
3. You should provide the relative location and file name of the actual file containing the nonclinical
overview in the “xlink:href” attribute for the <leaf> element.
4. You should provide a descriptive title for the file that contains the nonclinical overview in the <title>
element of the <leaf>.
5. You should provide information for the appropriate attributes of the <leaf> element as described in
Table 6-8.
The table 6-8 describes each of these elements and attributes in further detail. In the current review
environment, the following leaf attributes are the most useful to the end user:
• ID
• xml:lang
• checksum
• checksum-type
• modified-file
• operation
Page 6-7
• application-version
• xlink:href
Table 6-8
Element Attribute Description/Instructions Example
Any table of A table of contents tag represents a
contents tag grouping of one or more files related
such as <m2- to a specific section of the Common
4- Technical Document.
nonclinical- One or more child <leaf> elements
overview> can be declared for a parent table of
contents tag.
It is possible to extend a table of
contents tag by providing a <node-
extension> element. This can be done
at the lowest level of the defined table
of contents tags but should be done
only when absolutely necessary. See
the section “Instructions for extending
eCTD tag elements” in this appendix.
ID A unique identifier for this location in id403 (note: At this level, ID is optional
the XML instance. and may provide for navigation within
the index.
xml:lang The primary language used by the En
files in this entire section of the
submission. Use ISO-639 standard
language abbreviations
<leaf> A leaf corresponds to a file.
One or more child leaf elements can
be submitted for a parent table of
contents tag.
application- The version of the software PDF 1.3
version application that was used to create this
file.
font-library Commercial name of fonts/font set
used to create the document.
ID Unique identifier for this file in the id050520
XML instance. Leaf ID must start
with a character.
checksum The checksum value for the file being e854d3002c02a61fe5cbe926fd97b001
submitted.
checksum- The checksum algorithm used. MD5
type
modified- The purpose of the modified-file modified-
file attribute is to provide the location of a file="../0001/index.xml#a1234567"
document that is being modified (i.e.
replaced, appended or deleted) by the
leaf element. The modified-file
attribute should have a value when the
operation attribute has a value of
append, replace or delete. The
modified-file attribute points to the
“index.xml” file and the leaf ID of the
file being altered.
Page 6-8
Element Attribute Description/Instructions Example
operation Indicates the operation to be New
performed on the “modified-file”.
You should select one of the
following valid values:
• new
• replace
• append
• delete
See the section Operation Attribute in
this appendix for details on the
meaning of these values.
version The file submitter’s internal version V23.5
number or version identification for
the report.
xlink:actuate Not Currently Used
xlink:href Provide the pointer to the actual file. 0000/m2/27-clin-sum/literature-
Use the relative path to the file and references.pdf
the file name.
xlink:role Not Currently Used
xlink:show Not Currently Used.
xlink:type Fixed value of “simple”. simple
keywords Not Currently Used
<title> This element is associated with a study report 1234
“leaf” and provides a description of
the file being submitted.
ID Unique identifier for this location in a1234567
the XML instance. Leaf ID must start
with a character.
This submission includes the file “clinical-overview.pdf” in the relative directory “m2/25-clin-over/” (i.e.
the one starting below the dossier number directory). The file is “new” and has a descriptive name of
“Clinical Overview”
7
Note that these XML examples are examples only and do not necessarily contain all of the elements and
attributes that you should use when preparing an eCTD submission.
Page 6-9
The regional review application should treat this as a new submission to be associated with the submission
identified in CTD module 1, which is region specific.
If this is the first submission for Dossier CTD 123456, all the files in this submission are in the ctd-
123456\0000 directory and below.
To replace a file, add the replacement file <leaf> element under the same tag element as the original file. If
this is the second submission for Dossier CTD 123456, all the files in this submission are in the ctd-
123456\0001 directory and below.
Table 6-9
Element Attribute Description/Instructions Example
<m2-7-3-summary-of-clinical-efficacy> Indication Name of the indication pain
<m5-3-5-reports-of-efficacy-and-safety-studies> Indication Name of the indication. pain
Note that the indication attribute is used by the regulatory authority to apply to all the table of contents tags
beneath the <m2-7-3-summary-of-clinical-efficacy> and <m5-3-5-reports-of-efficacy-and-safety-studies>
tags. This is an example of a section of the instance showing the submission of information about two
indications:
Page 6-10
xlink:href =
"m2/27-clin-sum/summary-clin-efficacy-pain.pdf">
<title>pain efficacy summary</title>
</leaf>
</m2-7-3-summary-of-clinical-efficacy>
<m2-7-3-summary-of-clinical-efficacy indication = "nausea">
<leaf ID=”a123457” operation = "new" xlink:type = "simple"
checksum-type=“md5” checksum =
"e854d3002c02a61fe54be926fd973401"
xlink:href =
"m2/27-clin-summ/summary-clin-efficacy-nausea.pdf">
<title>nausea efficacy summary</title>
</leaf>
</m2-7-3-summary-of-clinical-efficacy>
</m2-7-clinical-summary>
</m2-common-technical-document-summaries>
<m5-clinical-study-reports>
<m5-3-clinical-study-reports>
<m5-3-5-reports-of-efficacy-and-safety-studies indication = "pain">
<leaf ID=”a123458” operation = "new" xlink:type = "simple" checksum-
type=“md5”
checksum =
"e854d3002c02a61fe544e926fd973401"
xlink:href =
"m5/53-clin-stud-rep/535-rep-eff-safety-stud/pain/pain-sr1.pdf">
<title>pain study report 1</title>
</leaf>
</m5-3-5-reports-of-efficacy-and-safety-studies>
<m5-3-5-reports-of-efficacy-and-safety-studies indication = "nausea">
<leaf ID=”a123459” operation = "new" xlink:type = "simple" checksum-
type=“md5” checksum =
"e854d3002c02a614e54be926fd973401"
xlink:href =
"m5/53-clin-stud-rep/535-rep-eff-safety-stud/nausea/nausea-sr15.pdf">
<title>nausea study report 15</title>
</leaf>
</m5-3-5-reports-of-efficacy-and-safety-studies>
</m5-3-clinical-study-reports>
</m5-clinical-study-reports>
</ectd:ectd>
Table 6-10
Element Attribute Description/Instructions Example
<m3-2-s-drug-substance> Substance Name of one of the drug substances Acetaminophen
Manufacturer Name of the manufacturer of the drug substance my supplier
This is an example of a section of the instance showing the submission of information about two drug
substances, one of which is supplied by two manufacturers:
<m3-2-body-of-data>
<m3-2-s-drug-substance substance = "acetaminophen" manufacturer = "my supplier">
<leaf ID=”a123456” operation = "new" xlink:type = "simple" checksum-type=“md5”
checksum =
"e854d3002c02361fe54be926fd973401"
Page 6-11
xlink:href =
"m3/32-body-data/32s-drug-sub/acetaminophen-my-supplier/acetaminophen.pdf">
<title>acetaminophen my supplier data</title>
</leaf>
</m3-2-s-drug-substance>
<m3-2-s-drug-substance substance = "acetaminophen" manufacturer = "bulk company 2">
<leaf ID=”a123457” operation = "new" xlink:type = "simple" checksum-type=“md5”
checksum =
"e854d3002402a61fe54be926fd973401"
xlink:href =
"m3/32-body-data/32s-drug-sub/acetaminophen-bulk-company-2/acetaminophen2.pdf">
<title>acetaminophen company 2 data</title>
</leaf>
</m3-2-s-drug-substance>
<m3-2-s-drug-substance substance = "codeine" manufacturer = "drug company 2">
<leaf ID=”a123458” operation = "new" xlink:type = "simple" checksum-type=“md5”
checksum =
"e854d3002c02461fe54be926fd973401"
xlink:href =
"m3/32-body-data/32s-drug-sub/codeine-drug-company-2/codeine-quality-data.pdf">
<title>codeine data</title>
</leaf>
</m3-2-s-drug-substance>
</m3-2-body-of-data>
Multiple drug products use additional attributes associated with the <m3-2-p-drug-product> element to
allow unique combinations of the drug product name and dosage form to be submitted. The following table
shows the use of these attributes.
Table 6-11
Element Attribute Description/Instructions Example
<m3-2-p-drug-product> product-name Name of one of the drug products Wonder drug
dosageform Dosage form and strength of the drug product Tablet-5 mg
manufacturer Manufacturer of the drug product Company A
This is an example of a section of the instance showing the submission of information about two drug
products:
<m3-2-body-of-data>
<m3-2-p-drug-product product-name = “wonder drug” dosageform=“capsule-5mg”>
<leaf ID=”a123456” operation = "new" xlink:type = "simple" checksum-type=“md5” checksum =
"e854d3002c02a61fe5cbe226fd973401"
xlink:href =
"m3/32-body-data/32p-drug-prod/capsule-5mg/32p1-desc-comp/description-and-
composition.pdf">
<title>wonder drug capsule product information</title>
</leaf>
</m3-2-p-drug-product>
<m3-2-p-drug-product product-name = “wonder drug” dosageform=“tablet-5mg”>
<leaf ID=”a123457” operation = "new" xlink:type = "simple" checksum-type=“md5” checksum =
"e854d3002c02a61fe5cbe926fd973401"
xlink:href =
"m3/32-body-data/32p-drug-prod/tablet-5mg/32p1-desc-comp/description-and-
composition.pdf">
<title>wonder drug tablet product data</title>
</leaf>
</m3-2-p-drug-product>
</m3-2-body-of-data>
Page 6-12
Instructions for Extending XML eCTD DTD Elements
An applicant can extend the definition of an element by creating node extensions beneath a defined table of
contents tag. Using node extensions is discouraged and should only be done when there is no other feasible
means to submit information. The child element <node-extension> should be used for each new table of
contents node created. The <title> element value is inherited from the parent element. You should follow
the following principles when using <node-extension>:
1. You should only extend the lowest level of defined elements. For example you can extend the
<m2-3-r-regional-information> element but not the <m2-3-quality-overall-summary> element
since the latter is not the lowest element defined in the table of contents.
2. Do not extend the element more than one level. For example, you should not extend <node-
extension> <title>special-fda-summary</title> </node-extension> with another <node-extension>.
The following is an example of a section of the eCTD instance in which an applicant extends the <m2-3-r-
regional-information> to provide specific regional information as requested by a regulatory authority. The
title element associated with the <node-extension> describes the extension. Alternatively, the regional
information in this example could have been provided as a <leaf> element under the <m2-3-r-regional-
information> element without the use of a “node extension”.
<m2-common-technical-document-summaries>
<m2-3-quality-overall-summary>
<m2-3-r-regional-information>
<node-extension>
<title>special-fda-summary</title>
<leaf ID=”a123456” operation = "new" xlink:type = "simple" xlink:href =
"m2/23-qos/fda/fda-extra-quality-sum.pdf">
<title> FDA extra quality summary </title>
</leaf>
</node-extension>
</m2-3-r-regional-information>
</m2-3-quality-overall-summary>
</m2-common-technical-document-summaries>
To update a file that has been submitted as an extended node, you should submit the replacement file using
exactly the same element and “node extension” information, including the <title> element for the <node-
extension>. This makes it possible for the regulatory authority to locate the original file and update its
status.
This is an example of the instance showing the submission of a paper efficacy overview document.
<m2-common-technical-document-summaries>
<m2-5-clinical-overview xml:lang = "en">
<leaf ID=”a123456” operation = "new" xlink:type = "simple" checksum-type=“md5”
checksum =
"e854d3002c02a61fe5cbe926fd973401" ID=“ID050520”
xlink:href = "m2/25-clin-over/clinical-overview.pdf"
application-version = "Acrobat 5">
Page 6-13
<title>Paper Submission </title>
</leaf>
</m2-5-clinical-overview>
</m2-common-technical-document-summaries>
Page 6-14
Appendix 7: Specification for Submission Formats
Introduction
This appendix describes the way files should be constructed for inclusion in the eCTD. This section
includes file formats that are commonly used in electronic submissions. Other formats can be used
according to guidance published in each region.
PDF
Adobe Portable Document Format (PDF) is a published format created by Adobe Systems Incorporated
(http://www.adobe.com). It is not necessary to use a product from Adobe or from any specific company to
produce PDF documents. PDF is accepted as a standard for documents defined in this specification. The
following recommendations support the creation of PDF files that agencies can review effectively. For any
specification of the Japanese version of Adobe Acrobat, or where Japanese characters will be in the file,
please refer to the regional guidance.
To ensure that PDF files can be accessed efficiently, PDF files should be no larger than 100 megabytes.
Optimize PDF files for fast web view.
Version
Agencies should be able to read all PDF files with version 4.0 or higher of the Acrobat Reader. Agencies
should not need any additional software to read and navigate the PDF files. However, review can be
facilitated through use of Adobe Acrobat since significantly more functionality is available in this product
than with Acrobat Reader.
Fonts
PDF viewing software automatically substitutes a font to display text if the font used to create the text is
unavailable on the reviewer’s computer. Font substitution can affect a document’s appearance and
structure, and in some cases, the information conveyed by a document. Agencies cannot guarantee the
availability of any fonts except Times New Roman, Arial, and Courier and fonts supported in the Acrobat
product set itself. Therefore, all additional fonts used in the PDF files should be embedded to ensure that
those fonts would always be available to the reviewer. When embedding fonts, all characters for the font
should be embedded, not just a subset of the fonts being used in the document
Embedding fonts requires additional computer storage space. Three techniques to help limit the storage
space taken by embedding fonts include:
• Limiting the number of fonts used in each document
Japanese fonts (2-byte fonts) are larger than Roman fonts (1-byte fonts), therefore, the specification allows
a subset to be embedded for all Japanese fonts. The purpose of embedding fonts to is to allow the receiver
of the document to use a personal computer to display and print the document correctly without having the
same fonts installed in the computer. Therefore, it is not necessary to embed all Japanese fonts. Embedding
a subset of Japanese fonts should work satisfactorily.
Definition of Subset
A subset means to embed only those characters used in the document. Embedding a full-set means all
characters that comprise the font are embedded, even characters that are not used in the document. All
two-byte fonts such as Japanese should be embedded as a sub-set.
Page 7-1
The following should be considered when embedding fonts:
Advantages:
• Embedding fonts allows the PDF file to be correctly displayed and printed on any receiving PC
environment.
• The computer does not need the original fonts installed.
Disadvantages:
• The file size increases when fonts are embedded.
• When document contains many pages, this may make the document slower to print.
• Many eCTD documents contain a large number of pages. Printing time in such cases becomes a
concern.
• When using Japanese fonts, rules of operation should be established between the sender and receiver.
(See regional guidance)
• The use of popular fonts only would allow the sender and receiver to view and print the document
correctly without embedding fonts.
Font Size
Resizing a document because the contents are too small to read is inefficient. Times New Roman, 12-point
font, the font used for this document, is adequate in size for narrative text and should be used whenever
possible. It is sometimes tempting to use fonts which are smaller than 12 point in tables and charts but this
should be avoided whenever possible. When choosing a font size for tables, a balance should be sought
between providing sufficient information on a single page to facilitate data comparisons for the reviewer
while maintaining a font size that remains legible. The corollary of this is that in using larger font size,
more tables might be necessary, which can complicate data comparisons since data might now be included
in separate tables. Generally, Times New Roman font sizes 9-10 or an equivalent size of other
recommended fonts are considered acceptable in tables but smaller font sizes should be avoided.
Page Orientation
Pages should be properly oriented so that all portrait pages are presented in portrait and all landscape pages
are presented in landscape. To achieve this, the page orientation of landscape pages should be set to
landscape prior to saving the PDF document in final form.
Page 7-2
Methods for Creating PDF Documents and Images
The method used for creating PDF documents should produce the best replication of a paper document. To
ensure that the paper and PDF version of the document are the same, the document should be printed from
the PDF version. Documents that are available only in paper should be scanned at resolutions that will
ensure the pages are legible both on the computer screen and when printed. At the same time, the file size
should be limited. It is recommended that scanning be undertaken at a resolution of 300 dots per inch (dpi)
to balance legibility and file size. The use of grayscale or color is discouraged because of file size. After
scanning, resampling to a lower resolution should be avoided.
When creating PDF files containing images, the images should not be downsampled. Downsampling does
not preserve all of the pixels in the original. For PDF images, one of the following lossless compression
techniques should be used:
• For lossless compression of color and grayscale images, use Zip/Flate (one technique with two names).
This is specified in Internet RFC 1950 and RFC 1951 (http://info.internet.isi.edu/in-
notes/rfc/files/rfc1950.txt).
• For lossless compression of black and white images, use the CCITT Group 4 Fax compression
technique. It is specified as CCITT recommendations T.6 (1988) - Facsimile coding schemes and
coding control functions for Group 4 facsimile apparatus.
Paper documents containing hand-written notes should be scanned at 300 dpi. Hand-written notes should
be done in black ink for clarity.
For photographs, the image should be obtained with a resolution of 600 dpi. If black and white photos are
submitted, 8-bit grayscale images should be considered. If color photos are submitted, 24-bit RGB images
should be considered. A captured image should not be subjected to non-uniform scaling (i.e., sizing).
Gels and karyotypes should be scanned directly, rather than from photographs. Scanning should be at 600
dpi and 8-bit grayscale depth.
In general, for documents with a table of contents, bookmarks for each item listed in the table of contents
should be provided including all tables, figures, publications, other references, and appendices. Bookmarks
should follow hierarchical level and order of table of contents. These bookmarks are essential for the
efficient navigation through documents. The bookmark hierarchy should be identical to the table of
contents with no additional bookmark levels beyond those present in the table of contents. Each additional
level increases the need for space to read the bookmarks. The use of no more than 4 levels in the hierarchy
is recommended.
Hypertext links throughout the document to support annotations, related sections, references, appendices,
tables, or figures that are not located on the same page are helpful and improve navigation efficiency.
Relative paths should be used when creating hypertext links to minimize the loss of hyperlink functionality
when folders are moved between disk drives. Absolute links that reference specific drives and root
directories will no longer work once the submission is loaded onto the Agency’s network servers.
Page 7-3
When creating bookmarks and hyperlinks, the magnification setting Inherit Zoom should be used so that
the destination page displays at the same magnification level that the reviewer is using for the rest of the
document.
Page Numbering
Only the internal page numbers of the document are required (1-n). No additional page/volume numbers
running across documents are expected. It is easier to navigate through an electronic document if the page
numbers for the document and the PDF file are the same. To accomplish this, the first page of the
document should be numbered page 1, and all subsequent pages (including appendices and attachments)
should be numbered consecutively with Arabic numerals. Roman numerals should not be used to number
pages (e.g., title pages, tables of contents) and pages should not be left unnumbered (e.g., title page.)
Numbering in this manner keeps the Acrobat numbering in synchrony with the internal document page
numbers.
Two exceptions to this rule can occur (see details in the guidance for the modules of the CTD.
• First, where a document is split because of its size (e.g., >50MB), the second or subsequent file
should be numbered consecutively to that of the first or preceding file.
• Second, where several small documents with their own internal page numbering have been
combined into a single file, it is not necessary to provide additional page numbering, instead the
start of each sub document should be book marked.
Security
No security settings or password protection for PDF files should be included. Security fields should be set
to allow printing, changes to the document, selecting text and graphics, and adding or changing notes and
form fields.
XML Files
A working group at the World Wide Web Consortium (W3C) developed XML. It is a nonproprietary
language developed to improve on previous markup languages including standard generalized markup
language (SGML) and hypertext markup language (HTML).
Information in an XML file is divided into specific pieces. These pieces are called objects or element types.
The element type identifies the piece of information. For example, the name of the company submitting a
registration application in eCTD format for review is identified with the element type <applicant>. All
element type names are bracketed using the special characters <>. Inside the XML document, the element
Page 7-4
type name is placed just prior to the piece of information and after the information. This is called tagging.
So, in the XML file, the applicant could be tagged as follows <applicant>Worldwide Pharmaceuticals
Inc.</applicant>. The “/” prior to the element type denotes that this is the end of the information about the
applicant.
By using a hierarchical structure, XML allows you to relate two or more elements. This is accomplished by
nesting one element within another.
Additional information about the element type is provided by attributes. Attributes are placed within the
element types and are surrounded by quotation marks (“ ”.) For example, if you wanted to show that the
applicant name is presented in the English language, you could add this piece of information as an attribute.
This could be represented in the XML file as <applicant XML:LANG=“EN”> Worldwide Pharmaceuticals
Inc.</applicant>.
XML files are read by a parser found in Internet browsers. Stylesheets provide the browser with the
information to create tables, fonts, and colors for display.
The specific names of the element types and attributes as well as the valid syntax, structure and format for
defining the XML elements are included in a file called document type definition (DTD). If the XML
document does not follow the DTD, then the file will not be able to be used properly.
The top three lines of the XML file should include the XML version, the stylesheet type and address, and
the DTD name and address.
Additional information about the XML standard can be found at the W3C Web site at http://www.w3c.org.
SVG Files
SVG is a language for describing two-dimensional graphics in XML. SVG allows for three types of
graphic objects: vector graphic shapes (e.g., paths consisting of straight lines and curves), images, and
text. Graphical objects can be grouped, styled, transformed and composited into previously rendered
objects. Text can be in any XML namespace suitable to the application, which enhances searchability
and accessibility of the SVG graphics. The feature set includes nested transformations, clipping paths,
alpha masks, filter effects, template objects, and extensibility.
SVG drawings can be dynamic and interactive. The Document Object Model (DOM) for SVG, which
includes the full XML DOM, allows for straightforward and efficient vector graphics animation via
scripting. A rich set of event handlers such as onmouseover and onclick can be assigned to any SVG
graphical object. Because of its compatibility and leveraging of other Web standards, features like
scripting can be done on SVG elements and other XML elements from different namespaces
simultaneously within the same Web page. 8
The specific use of SVG in a submission should be discussed with the regulatory authority.
8
This description of SVG is from w3c Web page http://www.w3c.org/graphics/svg
Page 7-5
Appendix 8: XML eCTD DTD
<?xml version='1.0' encoding='UTF-8' ?>
<!ATTLIST m5-3-5-reports-of-efficacy-and-safety-studies
%att;
indication CDATA #REQUIRED
- Since ID is only needed for files referenced in a LEAF, changed ID back to IMPLIED for:
<!ENTITY % att " ID ID #REQUIRED
xml:lang CDATA #IMPLIED">
Page 8-1
End of changes
-->
<!ENTITY % att " ID ID #IMPLIED
xml:lang CDATA #IMPLIED">
Page 8-2
xml:lang CDATA #IMPLIED >
<!-- ============================================================= -->
<!-- CTD Backbone structures -->
<!-- ============================================================= -->
<!ELEMENT m1-administrative-information-and-prescribing-information (leaf*)>
Page 8-3
<!ATTLIST m2-6-2-pharmacology-written-summary %att; >
<!ELEMENT m2-6-3-pharmacology-tabulated-summary ((leaf | node-extension)*)>
Page 8-4
<!ELEMENT m3-2-s-1-general-information (leaf* , m3-2-s-1-1-nomenclature? , m3-2-s-1-2-structure? ,
m3-2-s-1-3-general-properties?)>
Page 8-5
<!ELEMENT m3-2-s-4-2-analytical-procedures ((leaf | node-extension)*)>
Page 8-6
<!ATTLIST m3-2-p-3-2-batch-formula %att; >
<!ELEMENT m3-2-p-3-3-description-of-manufacturing-process-and-process-controls ((leaf | node-
extension)*)>
Page 8-7
<!ELEMENT m3-2-p-5-6-justification-of-specifications ((leaf | node-extension)*)>
Page 8-8
<!ATTLIST m4-2-study-reports %att; >
<!ELEMENT m4-2-1-pharmacology (leaf* , m4-2-1-1-primary-pharmacodynamics? , m4-2-1-2-
secondary-pharmacodynamics? , m4-2-1-3-safety-pharmacology? , m4-2-1-4-pharmacodynamic-drug-
interactions?)>
Page 8-9
<!ATTLIST m4-2-3-3-genotoxicity %att; >
<!ELEMENT m4-2-3-3-1-in-vitro ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-5-4-studies-in-which-the-offspring-juvenile-animals-are-dosed-and-or-further-
evaluated %att; >
<!ELEMENT m4-2-3-6-local-tolerance ((leaf | node-extension)*)>
Page 8-10
<!ELEMENT m4-2-3-7-3-mechanistic-studies ((leaf | node-extension)*)>
Page 8-11
<!ATTLIST m5-3-2-1-plasma-protein-binding-study-reports %att; >
<!ELEMENT m5-3-2-2-reports-of-hepatic-metabolism-and-drug-interaction-studies ((leaf | node-
extension)*)>
<!ATTLIST m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-claimed-indication
%att; >
<!ELEMENT m5-3-5-2-study-reports-of-uncontrolled-clinical-studies ((leaf | node-extension)*)>
Page 8-12
<!ATTLIST m5-3-5-3-reports-of-analyses-of-data-from-more-than-one-study %att; >
<!ELEMENT m5-3-5-4-other-study-reports ((leaf | node-extension)*)>
Page 8-13
Appendix 9: Glossary
This glossary provides the definition of terms associated with the eCTD.
Architecture
A general term for the design and construction of computer systems, including technical infrastructure,
information (data), and applications.
ASCII
American Standard Code for Information Interchange. A specification for representing text as computer-
readable information.
Bookmark
A bookmark is a type of link with representative that links to a different view or page in a document.
Browser
A program that allows the user to read hypertext, to view contents of Web pages, and to navigate from one
page to another (e.g., Netscape Navigator, Mosaic, Microsoft Internet Explorer.)
Decryption
To reverse encryption.
DTD
Document Type Definition. A hierarchical organization or representation of the information contents of a
document utilized by SGML or XML.
eCTD
The electronic format of the ICH Common Technical Document
Encryption
The process of reversibly confusing text or data using a secret formula.
ESTRI
Electronic Standards for the Transfer of Regulatory Information.
EWG
Expert Working Group.
HTML
Hypertext Markup Language. Commonly used to format Web pages.
Hypertext
Page 9-1
A system that enables links to be established between specific words or figures in a document to other text,
tables or image allowing quick access to the linked items (such as on the World Wide Web).
ICH
International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals
for Human Use.
Infrastructure
The basic support services for computing; the hardware, operating system, and network on which
applications and data are stored and on which the database management systems run.
Internet
The world-wide network of computers for accessing, sending, sharing, and transferring information
between sites at different locations. It is uncontrolled and unadministered, and when you connect to the
Internet, you actually become a part of it.
ISO
International Standards Organization, founded in 1946, it is the principal international standards-setting
organization.
Leaf
The eCTD DTD XML element that describes the content to be provided. The leaf consists of a file and the
meta-data associated with that file. Such files are placed in a directory structure that is similar to branches
of a tree.
Logical Document
One or more CTD table of contents sections that together contain the minimum amount of information to
be exchanged. Ideally, this is a single physical file.
M2
Multidisciplinary Group 2 (ESTRI) of ICH.
Network
A communication system that connects different computers and enables them to share peripherals such as
printers, disk drives and databases. Users (clients) can access applications and databases connected by the
network.
Node Extension
The extension of the definition of an element beneath a defined table of contents tag.
PDF
Portable Document Format, a proprietary (Adobe Systems) de facto standard for the electronic transfer of
documents.
SGML
Standardized Generalized Markup Language. An ISO standard for describing structured information in a
platform independent manner.
Page 9-2
Standard
A technical specification that addresses a business requirement, has been implemented in viable
commercial products, and, to the extent practical, complies with recognized standards organizations such as
ISO.
Web page
Any page on the World Wide Web. The page usually offers the reader access to other topics of interest.
XML
Extensible Markup Language. An ISO standard for describing structured information in a platform-
independent manner.
Page 9-3
SECTION 14
Ginny Ventura
Regulatory Information Specialist
CDER, U.S. FDA
June 21, 2006
Overview
• CDER’s eCTD processing
• How our tools look and work
• Frequently encountered issues
• Examples
• How to ensure success
Fewer Technical Issues
eCTD Submission
xlink:href
• “Extra” files
• Failing to Repeat Complete Directory Structure on
each media component in a set
– Unreferenced Files may not be located by
reviewers
Include Module 1 in All eCTD
Submissions
To Summarize
Session 317
Medical/Scientific Writing Track
Learning objectives
At the conclusion of this session, participants should be able to:
2
ICH
INTERNATIONAL CONFERENCE ON
HARMONIS/ZATION
of
Technical Requirements
for the Registration of
Pharmaceuticals for Human Use
http://www.ich.org
Hosted by ICH Secretariat
IFPMA-Geneva, Switzerland
A Unique Approach
• ICH was created in 1990
• Agreement between the EU, Japan and the
USA to harmonize different regional
requirements for registration of
pharmaceutical drug products
• Unique because joint effort by regulators and
associated pharmaceutical industry trade
associations
ICH Objectives
1
Overview
• Study data standards
• Status of patient profile pilot
• Medical Review Technology for an NDA Safety Database
– Steve Gitterman, M.D., Ph.D., Deputy Director, Division of
Special Pathogens and Immunologic Drug Products
• Demo
– Steve Wilson, DrPH, Deputy Division Director, Division of
Biometrics II
• Study data submission transition milestones
• Q and A
– Norman Stockbridge, M.D., Ph.D., Deputy Director, Division of
CardioRenal Drug Products 2
What are Case Report
Tabulations?
• Study data
– Information collected during trials submitted to
the agency for evaluation
• Raw and derived data
• Multiple presentations
• Data definitions
– Information to understand the data
3
CRT Data Presentations
• Data tabulations datasets
– Each record includes a single observation for a subject
• Data listing datasets
– Each record includes a series of observations collected for a subject during
a study or for each visit during the study organized by domain
• Subject profiles
– PDF files that include all study data collected for an individual subject
organized by time
• Analysis datasets
– Records arranged to support a specific analysis not covered by other data
presentations (i.e., tabulations, listings or profiles)
4
Why Standards?
• Improve time to market for safe and effective treatments
(increased patient safety and reduced costs)
– Improve efficiency for clinical research
• Facilitates design and conduct of clinical trials
• Facilitates communication between researchers and study
sponsor (e.g., between CRO and drug company)
– Improves efficiency of evaluation of safety and efficacy
of investigational treatments
• Facilitates communication between regulatory authority and
applicant
• Facilitates development of efficient review environment (e.g.,
training, analysis tools)
5
Efficient Review Environment
• Standards provide:
– Common structure and terminology
– Single data source for review (less redundant
data)
• Standards allow:
– Use of common tools and techniques
– Common training
– Single validation of data
6
Study Data Standards
Goals
• Study data model
• Terminology and coding
• Content
7
Study Data Models
• HL7 Regulated Clinical Research
Information Management (RCRIM)
Technical Committee
– CDISC Submissions Data Domains Model
– Standard for Exchange of Nonclinical Data
(SEND)
– Annotated ECG waveform data
– Stability data
8
Terminology Standards
Initiatives
• Government
– FDA Data Council, HHS Data Council, CHI,
NCVHS
• Accredited Standards Development
Organizations
– HL7, ANSI, ISO
• Other
– ICH, CDISC, SEND consortium
9
Content Standards
• Indication specific guidance from individual
review divisions regarding specific data
collection recommendations
10
Patient Profile Pilot
• Evaluate
– Study data and data definition standard
– Use of standardized study data
• Current analysis and visualization tools
• PPD Informatics Patient Profiles
• Lincoln Technologies WebSDM
– Management of data
• WebSDM data validation, processing
• JANUS data repository model
11
Study Data and Data Definition
Standard
• CDISC Submission Domains Data Model
– FDA evaluated and commented on previous
CDISC versions
– CDISC version 3.1 being prepared for
presentation to RCRIM as informative standard
• Anticipate adoption of CDISC standard for
submission of study data and data definition
following approval by HL7
12
Use of Study Data
• PPD Patient Profiles
– Development of EasyView
• Allows reviewer to generate subject profile and
summary views of the data
• Allows sharing of techniques
• Uses standard study data and data definitions
– Anticipated implementation following approval
of CDISC standards by HL7 RCRIM
13
Use of Study Data
• Lincoln Technologies WebSDM
– Development
• Allows reviewers to
– Browse submitted datasets,
– Generate data tabulations and data listings presentations,
– Create summaries and reports
• Allows sharing of techniques
• Uses standard study data and data definitions
– Anticipated implementation following approval
of CDISC standards by HL7 RCRIM 14
Management of Data
• Lincoln Technologies WebSDM
– Development
• Validation of data
• Parsing of data into database
– Anticipated implementation following approval
of CDISC standards by HL7 RCRIM
• JANUS Data Repository
– Development
• Data model
15
• Implementation requirements
Medical Review Technology for an NDA Safety Database
Steve Gitterman, M.D., Ph.D., Deputy Director, Division of Special
Pathogens and Immunologic Drug Products
Demo
Steve Wilson, DrPH, Deputy Division Director, Division of Biometrics II
16
Study Data Submission
Transition Milestones
• Replace paper tables with electronic datasets
• Replace nonstandard datasets with standard
electronic datasets
• Replace data listings and patient profiles with
standard datasets and tools
• Replace SAS transport datasets with XML data files
• Add terminology and content standards
• Replace analysis datasets with standardized
communication of analysis methods and tools
17
Electronic Datasets
Electronic
Data Acrobat
Document Room
•Tabulations
•Data listings Stat/transfer
•Profiles Dataset files
•Analysis datasets
•Programs
•Definition
Tools
Data listing
Tools
Tabulations
Electronic
Data Acrobat
Document Room
•Std Tabulations
•Data listings Stat/transfer
•Profiles Dataset files
•Analysis datasets
•Programs JANUS
•Definition Study Data
Repository Profile
Data listing
Tools
Tabulations
Profile
Tools
Datasets
Annex to
M4: Organization of the CTD
Additional copies are available from:
October 2005
ICH
TABLE OF CONTENTS
INTRODUCTION......................................................................................................................... 1
ANNEX : GRANULARITY DOCUMENT ................................................................................ 2
Definition of a Document.............................................................................................................. 2
Module 2 .................................................................................................................................................. 3
Module 3 .................................................................................................................................................. 4
Module 4 .................................................................................................................................................. 6
Module 5 .................................................................................................................................................. 7
Document Pagination and Segregation....................................................................................... 8
Section Numbering Within Documents ...................................................................................... 8
Table of Contents Formatting...................................................................................................... 8
Module 2 .................................................................................................................................................. 8
Module 3 .................................................................................................................................................. 9
Module 4 .................................................................................................................................................. 9
Module 5 ................................................................................................................................................ 10
Contains Nonbinding Recommendations
Granularity Document
Annex to M4: Organization of the CTD
This guidance represents the Food and Drug Administration's (FDA's) current thinking on this topic. It
does not create or confer any rights for or on any person and does not operate to bind FDA or the public.
You can use an alternative approach if that approach satisfies the requirements of the applicable statutes
and regulations. If you want to discuss an alternative approach, contact the FDA staff responsible for
implementing this guidance. If you cannot identify the appropriate FDA staff, call the appropriate
number listed on the title page of this guidance.
INTRODUCTION
This is one in a series of guidances that provide recommendations for applicants preparing the
Common Technical Document for the Registration of Pharmaceuticals for Human Use (CTD) for
submission to the U.S. Food and Drug Administration (FDA). This annex to the M4 guidance on
the organization of the CTD was developed by ICH in response to requests for additional
information after the harmonized CTD guidance documents were finalized in November 2000.
The annex is intended to clarify what constitutes a document in the paper CTD and in the eCTD,
and includes the following information for modules 2 through 5:
The information provided here reflects the consensus of the ICH parties. The annex will be
incorporated in FDA’s next revision of the M4 guidance.
1
This guidance was developed within the M4 CTD and M2 eCTD Implementation Working Groups of the
International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for
Human Use (ICH) and has been subject to consultation by the regulatory parties, in accordance with the ICH
process. This document has been endorsed by the ICH Steering Committee at Step 4 of the ICH process in
September 2002. A revision was signed off by ICH in November 2003, and the annex was corrected in Janaury
2004. At Step 4 of the process, the final draft is recommended for adoption to the regulatory bodies of the European
Union, Japan, and the United States.
1
Contains Nonbinding Recommendations
FDA's guidance documents, including this guidance, do not establish legally enforceable
responsibilities. Instead, guidances describe the Agency's current thinking on a topic and should
be viewed only as recommendations, unless specific regulatory or statutory requirements are
cited. The use of the word should in Agency guidances means that something is suggested or
recommended, but not required.
The CTD specifies many section headings and numbers. Could guidance be provided for
all modules on headings in relation to document location and the section headings within
those documents? Could guidance also be provided on where in the CTD and eCTD
multiple documents can be located in the hierarchy?
Could guidance be given on how documents should be paginated and on what the module
Table of Contents should therefore include?
Definition of a Document
A document is defined for a paper submission as a set of pages, numbered sequentially and
divided from other documents by a tab (see Document Pagination and Segregation section of this
Annex). A document can be equated to a file for an electronic submission. The granularity of
the paper and electronic submissions should be equivalent, although if a paper submission is
updated to be an electronic submission, some changes in granularity could be introduced to
facilitate on-going lifecycle management. In an electronic submission, a new file starts at the
same point at which, in a paper submission, a tab divides the documents.
In deciding whether one or more documents or files are appropriate, it should be considered that
once a particular approach has been adopted, the same approach should be used throughout the
life of the dossier since it is the intention that replacement documents/files be provided when
information is changed.
The following tables describe the levels in the CTD/eCTD hierarchy at which documents/files
should be placed and whether single or multiple documents are appropriate at each point. This
describes all sections of a CTD/eCTD, but for individual submissions, all sections might not be
applicable.
2
Contains Nonbinding Recommendations
Module 2
Module 2 2.1 The TOC is only called for in the paper version of
the CTD; there is no entry needed for the eCTD
2.2
Note 1
2.3 Introduction
Note 2
2.3.S 2.3.S.1
2.3.S.2
2.3.S.3
2.3.S.4
2.3.S.5
2.3.S.6
2.3.S.7
Note 3
2.3.P 2.3.P.1
2.3.P.2
2.3.P.3
2.3.P.4
2.3.P.5
2.3.P.6
2.3.P.7
2.3.P.8
2.3.A 2.3.A.1
2.3.A.2
2.3.A.3
2.3.R
2.4
2.5
2.6 2.6.1
2.6.2
2.6.3
2.6.4
2.6.5
2.6.6
2.6.7
2.7 2.7.1
2.7.2
Note 4
2.7.3
2.7.4
2.7.5
2.7.6
Key
Documents rolled up to this level are not considered appropriate
One document may be submitted at this level
Note 1 : Optionality of granularity for the Quality Overall Summary is provided in order to
accommodate different levels of complexity of products. The applicant can choose the level at
which the QOS is managed.
Note 3 : For a drug product supplied with reconstitution diluent(s), the information on the
diluent(s) should be provided in a separate part “P” document.
Note 4 : One document for each indication should be submitted, although closely
related indications can be within a single document.
3
Contains Nonbinding Recommendations
Module 3
Note 1 3.1 The TOC is only called for in the paper version of the CTD;
Module 3
there is no entry needed for the eCTD
3.2 Note 2 3.2.S.1 3.2.S.1.1
3.2.S
3.2.S.1.2
3.2.S.1.3
3.2.S.2 3.2.S.2.1
3.2.S.2.2
3.2.S.2.3
3.2.S.2.4
3.2.S.2.5
3.2.S.2.6
3.2.S.3 3.2.S.3.1
3.2.S.3.2
3.2.S.4 3.2.S.4.1
3.2.S.4.2
3.2.S.4.3
3.2.S.4.4
3.2.S.4.5
3.2.S.5
3.2.S.6
3.2.S.7 3.2.S.7.1
3.2.S.7.2
3.2.S.7.3
Note 3 3.2.P.1
3.2.P
3.2.P.2 Note 4
3.2.P.2.1
Note 4
3.2.P.2.2
3.2.P.2.3
3.2.P.2.4
3.2.P.2.5
3.2.P.2.6
3.2.P.3 3.2.P.3.1
3.2.P.3.2
3.2.P.3.3
3.2.P.3.4
3.2.P.3.5
3.2.P.4 3.2.P.4.1
3.2.P.4.2
3.2.P.4.3
3.2.P.4.4
3.2.P.4.5
3.2.P.4.6
3.2.P.5 3.2.P.5.1
3.2.P.5.2
3.2.P.5.3
3.2.P.5.4
4
Contains Nonbinding Recommendations
3.2.P.5.5
3.2.P.5.6
3.2.P.6
3.2.P.7
3.2.P.8 3.2.P.8.1
3.2.P.8.2
3.2.P.8.3
3.2.A 3.2.A.1
3.2.A.2
3.2.A.3
3.2.R Note 5
Key
Documents rolled up to this level are not considered appropriate
One or multiple documents can be submitted at this level
Note 1 : In choosing the level of granularity for this Module, the applicant should consider that,
when relevant information is changed at any point in the product's lifecycle, replacements of
complete documents/files should be provided in the CTD and eCTD.
Note 2 : For a drug product containing more than one drug substance, the information requested
for part “S” should be provided in its entirety for each drug substance.
Note 3 : For a drug product supplied with reconstitution diluent(s), the information on the
diluent(s) should be provided in a separate part “P”, as appropriate.
Note 4 : The lower level of headings included in CTD-Q at this point are unlikely to be
individual documents or files.
5
Contains Nonbinding Recommendations
Module 4
Module 4 4.1 The TOC is only called for in the paper version of the CTD; there
is no entry needed for the eCTD
Note 1
4.2 4.2.1 4.2.1.1 Studies
Note 1
4.2.1.2 Studies
Note 1
4.2.1.3 Studies
Note 1
4.2.1.4 Studies
Note 1
4.2.2 4.2.2.1 Studies
Note 1
4.2.2.2 Studies
Note 1
4.2.2.3 Studies
Note 1
4.2.2.4 Studies
Note 1
4.2.2.5 Studies
Note 1
4.2.2.6 Studies
Note 1
4.2.2.7 Studies
Note 1
4.2.3 4.2.3.1 Studies
Note 1
4.2.3.2 Studies
Note 1
4.2.3.3 4.2.3.3.1 Studies
Note 1
4.2.3.3.2 Studies
Note 1
4.2.3.4 4.2.3.4.1 Studies
Note 1
4.2.3.4.2 Studies
Note 1
4.2.3.4.3 Studies
Note 1
4.2.3.5 4.2.3.5.1 Studies
Note 1
4.2.3.5.2 Studies
Note 1
4.2.3.5.3 Studies
Note 1
4.2.3.5.4 Studies
Note 1
4.2.3.6 Studies
Note 1
4.2.3.7 4.2.3.7.1 Studies
Note 1
4.2.3.7.2 Studies
Note 1
4.2.3.7.3 Studies
Note 1
4.2.3.7.4 Studies
Note 1
4.2.3.7.5 Studies
Note 1
4.2.3.7.6 Studies
Note 1
4.2.3.7.7 Studies
4.3 One file per
Note 2
reference
Key
Documents rolled up to this level are not considered appropriate
One or multiple documents can be submitted at this level
Note 1 : Typically, a single document should be provided for each study report included in
Module 4. However, where the study report is large, (e.g., a carcinogenicity study), the applicant
can choose to submit the report as more than one document. In this case, the text portion of the
report should be one document and the appendices can be one or more documents. In choosing
the level of granularity for these reports, the applicant should consider that, when relevant
information is changed at any point in the product's lifecycle, replacements of complete
documents/files should be provided.
6
Contains Nonbinding Recommendations
Module 5
Module 5 5.1 The TOC is only called for in the paper version of the CTD; there
is no entry needed for the eCTD
5.2
Note 1
5.3 5.3.1 5.3.1.1 Studies
Note 1
5.3.1.2 Studies
Note 1
5.3.1.3 Studies
Note 1
5.3.1.4 Studies
Note 1
5.3.2 5.3.2.1 Studies
Note 1
5.3.2.2 Studies
Note 1
5.3.2.3 Studies
Note 1
5.3.3 5.3.3.1 Studies
Note 1
5.3.3.2 Studies
Note 1
5.3.3.3 Studies
Note 1
5.3.3.4 Studies
Note 1
5.3.3.5 Studies
Note 1
5.3.4 5.3.4.1 Studies
Note 1
5.3.4.2 Studies
Note 2 Note 1
5.3.5 5.3.5.1 Studies
Note 1
5.3.5.2 Studies
Note 1
5.3.5.3 Studies
Note 1
5.3.5.4 Studies
5.3.6
Note 1
5.3.7 Studies
5.4 One file per
reference Note 3
Key
Documents rolled up to this level are not considered appropriate
One document can be submitted at this level
One or multiple documents can be submitted at this level
Note 1 : The applicants should ordinarily provide the study reports as multiple documents (a
synopsis, a main body of the study report and appropriate appendices). Appendices should be
organized in accordance with the ICH E3 guideline, which describes the content and format of
the clinical study report. In choosing the level of granularity for reports the applicant should
consider that, when relevant information is changed at any point in the product's lifecycle,
replacements of complete documents/files should be provided.
Note 2 : For applications in support of more than one indication, this section should be repeated
for each indication.
7
Contains Nonbinding Recommendations
Every document should be numbered starting at page one, except for individual literature
references, where the existing journal page numbering is considered sufficient. Applicants need
not display the number as '1 of n' where n is the total number of pages in the document.
Additionally, all pages of a document should include a unique header or footer that briefly
identifies its subject matter. In a paper-based drug submission, a similar identifier should be
used on a tab that precedes the document, to facilitate finding that document within the dossier.
An abbreviation of the full section number and title can be used.
If a section contains more than one document, a specific Table of Contents for that section can be
included to identify the chronology and titles of the documents contained therein, e.g.,
• Tab with “3.2.S.4.2 Analytical Procedures”
o Table of Contents, listing the title of Procedure A, Procedure B, Procedure
C
• Tab with “3.2.S.4.2 “Procedure A”;
o Procedure A (i.e. document, page 1-n)
• Tab with “3.2.S.4.2 “Procedure B”;
o Procedure B (i.e. document, page 1-n)
• Tab with “3.2.S.4.2 “Procedure C”;
o Procedure C (i.e. document, page 1-n)
If a section contains only a single document (e.g. 3.2.S.1.1 Nomenclature), only a tab identified
by “3.2.S.1.1 Nomenclature” should precede the document.
In order to avoid 5th, 6th, etc., level subheading numbering (e.g., 2.6.6.3.2.1) within a document,
the applicant can use a shortened numbering string. In this case, the document number and the
name (e.g., 2.6.6 Toxicology Written Summary) should appear in page headers or footers and
then section numbering within the document can be used, for example, 1, 1.1, 2, 3, 3.1, 3.2. Use
of the full numbering string (e.g., 2.6.6.3.2.1) is also considered acceptable.
Module 2
The 2.1 CTD Table of Contents should go down to the third (e.g., 2.3.S) or fourth (e.g., 2.3.S.1)
level, depending on how a document is defined for the Quality Overall Summary. (See
Definition of a document for Module 2.)
8
Contains Nonbinding Recommendations
Module 3
The Table of Contents provided under 3.1 should cover the high-level section numbering, the
associated section heading and the Volume number in the order that they appear in the drug
submission. This Table of Contents would be used to identify the contents of Module 3 as
defined in the M4Q guideline. It should go down to the fifth level only (e.g., 3.2.P.2.1). Note
that additional subsections and subheadings are defined in the M4Q guideline beyond this level
(e.g., under 3.2.P.2) and this formatting should be used within the dossier, despite not being
included in the 3.1 Table of Contents. The lower level Table of Contents described under
Document Pagination and Segregation should be excluded from the 3.1 Table of Contents.
At the applicant’s discretion, a Table of Contents can also be included for a particular section
that contains multiple documents, in order to identify the chronology and the document subject
matter. If there is a desire to introduce additional headers or subsection numbering beyond those
which are defined in the M4Q guideline, these should only be included within a document and
should be created neither as a separate document nor as a new subsection. In this case, a specific
Table of Contents for that document can be included to identify the chronology and titles of the
subsections contained therein. These documents and subsections should not appear in the 3.1
Table of Contents.
All Table of Contents title entries should either correspond to heading names and section
numbering as defined in the M4Q guideline or to identifiers appearing on tabs (for a paper-based
drug submission only), preferably by their full title, which should easily identify any abbreviated
title that might be used on the corresponding tab. The Table of Contents should not specify any
page numbers.
Literature References should be listed in a Table of Contents specific for this section.
Module 4
The Table of Contents for Module 4 should include all of the numerical items listed in the CTD
guideline in order to identify all of the important components of the application (for example,
4.2.3.5.1 Fertility and early embryonic development) and should continue down to at least the
level of the study report. Thus, each study report should be identified in the table of contents.
The sections of a study report could be identified in the Module 4 Table of Contents of the
dossier or only in the Table of Contents of the individual study report.
9
Contains Nonbinding Recommendations
4.2.3.3 Genotoxicity
4.2.3.3.1 In vitro
Study ee-eee: Ames test with Drug C
etc.
Module 5
The Table of Contents for Module 5 should include all of the numerical items listed in the CTD
guideline in order to identify all of the important components of the application (for example,
5.3.5.1.1 Placebo Controlled Trials) and should continue down to at least the level of the clinical
study report. Thus each clinical study report should be identified in the table of contents. The
sections of a clinical study report (E3) could be identified in the Module 5 Table of Contents of
the dossier or only in the Table of Contents of the individual clinical study report.
10
SECTION 18
<!ATTLIST m5-3-5-reports-of-efficacy-and-safety-studies
%att;
indication CDATA #REQUIRED
End of changes
-->
<!ENTITY % att " ID ID #IMPLIED
xml:lang CDATA #IMPLIED">
<!--
============================================================= -->
<!-- Top-level element -->
<!--
============================================================= -->
<!ELEMENT ectd:ectd (m1-administrative-information-and-prescribing-information?,
m2-common-technical-document-summaries?, m3-quality?, m4-nonclinical-study-
reports?, m5-clinical-study-reports?)>
<!ATTLIST ectd:ectd
xmlns:ectd CDATA #FIXED "http://www.ich.org/ectd"
xmlns:xlink CDATA #FIXED "http://www.w3c.org/1999/xlink"
xml:lang CDATA #IMPLIED
dtd-version CDATA #FIXED "3.2"
>
<!--
============================================================= -->
<!-- Leaf content -->
<!--
============================================================= -->
<!ELEMENT leaf (title, link-text?)>
<!ATTLIST leaf
ID ID #REQUIRED
application-version CDATA #IMPLIED
version CDATA #IMPLIED
font-library CDATA #IMPLIED
operation (new | append | replace | delete) #REQUIRED
modified-file CDATA #IMPLIED
checksum CDATA #REQUIRED
checksum-type CDATA #REQUIRED
keywords CDATA #IMPLIED
xmlns:xlink CDATA #FIXED "http://www.w3c.org/1999/xlink"
xlink:type CDATA #FIXED "simple"
xlink:role CDATA #IMPLIED
xlink:href CDATA #IMPLIED
xlink:show (new | replace | embed | other | none) #IMPLIED
xlink:actuate (onLoad | onRequest | other | none) #IMPLIED
xml:lang CDATA #IMPLIED
>
<!ELEMENT title (#PCDATA)>
<!ATTLIST title
ID ID #IMPLIED
>
<!ELEMENT link-text (#PCDATA | xref)*>
<!ATTLIST link-text
ID ID #IMPLIED
>
<!ELEMENT xref EMPTY>
<!ATTLIST xref
ID ID #REQUIRED
xmlns:xlink CDATA #FIXED "http://www.w3c.org/1999/xlink"
xlink:type CDATA #FIXED "simple"
xlink:role CDATA #IMPLIED
xlink:title CDATA #REQUIRED
xlink:href CDATA #REQUIRED
xlink:show (new | replace | embed | other | none) #IMPLIED
xlink:actuate (onLoad | onRequest | other | none) #IMPLIED
>
<!ELEMENT node-extension (title, (leaf | node-extension)+)>
<!ATTLIST node-extension
ID ID #IMPLIED
xml:lang CDATA #IMPLIED
>
<!--
============================================================= -->
<!-- CTD Backbone structures -->
<!--
============================================================= -->
<!ELEMENT m1-administrative-information-and-prescribing-information (leaf*)>
<!ATTLIST m1-administrative-information-and-prescribing-information
%att;
>
<!ELEMENT m2-common-technical-document-summaries (leaf*, m2-2-introduction?,
m2-3-quality-overall-summary?, m2-4-nonclinical-overview?, m2-5-clinical-overview?,
m2-6-nonclinical-written-and-tabulated-summaries?, m2-7-clinical-summary?)>
<!ATTLIST m2-common-technical-document-summaries
%att;
>
<!ELEMENT m2-2-introduction ((leaf | node-extension)*)>
<!ATTLIST m2-2-introduction
%att;
>
<!ELEMENT m2-3-quality-overall-summary (leaf*, m2-3-introduction?, m2-3-s-drug-
substance*, m2-3-p-drug-product*, m2-3-a-appendices?, m2-3-r-regional-information?)>
<!ATTLIST m2-3-quality-overall-summary
%att;
>
<!ELEMENT m2-3-introduction ((leaf | node-extension)*)>
<!ATTLIST m2-3-introduction
%att;
>
<!ELEMENT m2-3-s-drug-substance ((leaf | node-extension)*)>
<!ATTLIST m2-3-s-drug-substance
%att;
substance CDATA #REQUIRED
manufacturer CDATA #REQUIRED
>
<!ELEMENT m2-3-p-drug-product ((leaf | node-extension)*)>
<!ATTLIST m2-3-p-drug-product
%att;
product-name CDATA #IMPLIED
dosageform CDATA #IMPLIED
manufacturer CDATA #IMPLIED
>
<!ELEMENT m2-3-a-appendices ((leaf | node-extension)*)>
<!ATTLIST m2-3-a-appendices
%att;
>
<!ELEMENT m2-3-r-regional-information ((leaf | node-extension)*)>
<!ATTLIST m2-3-r-regional-information
%att;
>
<!ELEMENT m2-4-nonclinical-overview ((leaf | node-extension)*)>
<!ATTLIST m2-4-nonclinical-overview
%att;
>
<!ELEMENT m2-5-clinical-overview ((leaf | node-extension)*)>
<!ATTLIST m2-5-clinical-overview
%att;
>
<!ELEMENT m2-6-nonclinical-written-and-tabulated-summaries (leaf*, m2-6-1-
introduction?, m2-6-2-pharmacology-written-summary?, m2-6-3-pharmacology-
tabulated-summary?, m2-6-4-pharmacokinetics-written-summary?, m2-6-5-
pharmacokinetics-tabulated-summary?, m2-6-6-toxicology-written-summary?, m2-6-7-
toxicology-tabulated-summary?)>
<!ATTLIST m2-6-nonclinical-written-and-tabulated-summaries
%att;
>
<!ELEMENT m2-6-1-introduction ((leaf | node-extension)*)>
<!ATTLIST m2-6-1-introduction
%att;
>
<!ELEMENT m2-6-2-pharmacology-written-summary ((leaf | node-extension)*)>
<!ATTLIST m2-6-2-pharmacology-written-summary
%att;
>
<!ELEMENT m2-6-3-pharmacology-tabulated-summary ((leaf | node-extension)*)>
<!ATTLIST m2-6-3-pharmacology-tabulated-summary
%att;
>
<!ELEMENT m2-6-4-pharmacokinetics-written-summary ((leaf | node-extension)*)>
<!ATTLIST m2-6-4-pharmacokinetics-written-summary
%att;
>
<!ELEMENT m2-6-5-pharmacokinetics-tabulated-summary ((leaf | node-extension)*)>
<!ATTLIST m2-6-5-pharmacokinetics-tabulated-summary
%att;
>
<!ELEMENT m2-6-6-toxicology-written-summary ((leaf | node-extension)*)>
<!ATTLIST m2-6-6-toxicology-written-summary
%att;
>
<!ELEMENT m2-6-7-toxicology-tabulated-summary ((leaf | node-extension)*)>
<!ATTLIST m2-6-7-toxicology-tabulated-summary
%att;
>
<!ELEMENT m2-7-clinical-summary (leaf*, m2-7-1-summary-of-biopharmaceutic-
studies-and-associated-analytical-methods?, m2-7-2-summary-of-clinical-pharmacology-
studies?, m2-7-3-summary-of-clinical-efficacy*, m2-7-4-summary-of-clinical-safety?,
m2-7-5-literature-references?, m2-7-6-synopses-of-individual-studies?)>
<!ATTLIST m2-7-clinical-summary
%att;
>
<!ELEMENT m2-7-1-summary-of-biopharmaceutic-studies-and-associated-analytical-
methods ((leaf | node-extension)*)>
<!ATTLIST m2-7-1-summary-of-biopharmaceutic-studies-and-associated-analytical-
methods
%att;
>
<!ELEMENT m2-7-2-summary-of-clinical-pharmacology-studies ((leaf | node-
extension)*)>
<!ATTLIST m2-7-2-summary-of-clinical-pharmacology-studies
%att;
>
<!ELEMENT m2-7-3-summary-of-clinical-efficacy ((leaf | node-extension)*)>
<!ATTLIST m2-7-3-summary-of-clinical-efficacy
%att;
indication CDATA #REQUIRED
>
<!ELEMENT m2-7-4-summary-of-clinical-safety ((leaf | node-extension)*)>
<!ATTLIST m2-7-4-summary-of-clinical-safety
%att;
>
<!ELEMENT m2-7-5-literature-references ((leaf | node-extension)*)>
<!ATTLIST m2-7-5-literature-references
%att;
>
<!ELEMENT m2-7-6-synopses-of-individual-studies ((leaf | node-extension)*)>
<!ATTLIST m2-7-6-synopses-of-individual-studies
%att;
>
<!ELEMENT m3-quality (leaf*, m3-2-body-of-data?, m3-3-literature-references?)>
<!ATTLIST m3-quality
%att;
>
<!ELEMENT m3-2-body-of-data (leaf*, m3-2-s-drug-substance*, m3-2-p-drug-product*,
m3-2-a-appendices?, m3-2-r-regional-information?)>
<!ATTLIST m3-2-body-of-data
%att;
>
<!ELEMENT m3-2-s-drug-substance (leaf*, m3-2-s-1-general-information?, m3-2-s-2-
manufacture?, m3-2-s-3-characterisation?, m3-2-s-4-control-of-drug-substance?, m3-2-s-
5-reference-standards-or-materials?, m3-2-s-6-container-closure-system?, m3-2-s-7-
stability?)>
<!ATTLIST m3-2-s-drug-substance
%att;
substance CDATA #REQUIRED
manufacturer CDATA #REQUIRED
>
<!ELEMENT m3-2-s-1-general-information (leaf*, m3-2-s-1-1-nomenclature?, m3-2-s-
1-2-structure?, m3-2-s-1-3-general-properties?)>
<!ATTLIST m3-2-s-1-general-information
%att;
>
<!ELEMENT m3-2-s-1-1-nomenclature ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-1-1-nomenclature
%att;
>
<!ELEMENT m3-2-s-1-2-structure ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-1-2-structure
%att;
>
<!ELEMENT m3-2-s-1-3-general-properties ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-1-3-general-properties
%att;
>
<!ELEMENT m3-2-s-2-manufacture (leaf*, m3-2-s-2-1-manufacturer?, m3-2-s-2-2-
description-of-manufacturing-process-and-process-controls?, m3-2-s-2-3-control-of-
materials?, m3-2-s-2-4-controls-of-critical-steps-and-intermediates?, m3-2-s-2-5-process-
validation-and-or-evaluation?, m3-2-s-2-6-manufacturing-process-development?)>
<!ATTLIST m3-2-s-2-manufacture
%att;
>
<!ELEMENT m3-2-s-2-1-manufacturer ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-2-1-manufacturer
%att;
>
<!ELEMENT m3-2-s-2-2-description-of-manufacturing-process-and-process-controls
((leaf | node-extension)*)>
<!ATTLIST m3-2-s-2-2-description-of-manufacturing-process-and-process-controls
%att;
>
<!ELEMENT m3-2-s-2-3-control-of-materials ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-2-3-control-of-materials
%att;
>
<!ELEMENT m3-2-s-2-4-controls-of-critical-steps-and-intermediates ((leaf | node-
extension)*)>
<!ATTLIST m3-2-s-2-4-controls-of-critical-steps-and-intermediates
%att;
>
<!ELEMENT m3-2-s-2-5-process-validation-and-or-evaluation ((leaf | node-
extension)*)>
<!ATTLIST m3-2-s-2-5-process-validation-and-or-evaluation
%att;
>
<!ELEMENT m3-2-s-2-6-manufacturing-process-development ((leaf | node-
extension)*)>
<!ATTLIST m3-2-s-2-6-manufacturing-process-development
%att;
>
<!ELEMENT m3-2-s-3-characterisation (leaf*, m3-2-s-3-1-elucidation-of-structure-and-
other-characteristics?, m3-2-s-3-2-impurities?)>
<!ATTLIST m3-2-s-3-characterisation
%att;
>
<!ELEMENT m3-2-s-3-1-elucidation-of-structure-and-other-characteristics ((leaf | node-
extension)*)>
<!ATTLIST m3-2-s-3-1-elucidation-of-structure-and-other-characteristics
%att;
>
<!ELEMENT m3-2-s-3-2-impurities ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-3-2-impurities
%att;
>
<!ELEMENT m3-2-s-4-control-of-drug-substance (leaf*, m3-2-s-4-1-specification?, m3-
2-s-4-2-analytical-procedures?, m3-2-s-4-3-validation-of-analytical-procedures?, m3-2-s-
4-4-batch-analyses?, m3-2-s-4-5-justification-of-specification?)>
<!ATTLIST m3-2-s-4-control-of-drug-substance
%att;
>
<!ELEMENT m3-2-s-4-1-specification ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-4-1-specification
%att;
>
<!ELEMENT m3-2-s-4-2-analytical-procedures ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-4-2-analytical-procedures
%att;
>
<!ELEMENT m3-2-s-4-3-validation-of-analytical-procedures ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-4-3-validation-of-analytical-procedures
%att;
>
<!ELEMENT m3-2-s-4-4-batch-analyses ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-4-4-batch-analyses
%att;
>
<!ELEMENT m3-2-s-4-5-justification-of-specification ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-4-5-justification-of-specification
%att;
>
<!ELEMENT m3-2-s-5-reference-standards-or-materials ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-5-reference-standards-or-materials
%att;
>
<!ELEMENT m3-2-s-6-container-closure-system ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-6-container-closure-system
%att;
>
<!ELEMENT m3-2-s-7-stability (leaf*, m3-2-s-7-1-stability-summary-and-conclusions?,
m3-2-s-7-2-post-approval-stability-protocol-and-stability-commitment?, m3-2-s-7-3-
stability-data?)>
<!ATTLIST m3-2-s-7-stability
%att;
>
<!ELEMENT m3-2-s-7-1-stability-summary-and-conclusions ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-7-1-stability-summary-and-conclusions
%att;
>
<!ELEMENT m3-2-s-7-2-post-approval-stability-protocol-and-stability-commitment
((leaf | node-extension)*)>
<!ATTLIST m3-2-s-7-2-post-approval-stability-protocol-and-stability-commitment
%att;
>
<!ELEMENT m3-2-s-7-3-stability-data ((leaf | node-extension)*)>
<!ATTLIST m3-2-s-7-3-stability-data
%att;
>
<!ELEMENT m3-2-p-drug-product (leaf*, m3-2-p-1-description-and-composition-of-
the-drug-product?, m3-2-p-2-pharmaceutical-development?, m3-2-p-3-manufacture?,
m3-2-p-4-control-of-excipients*, m3-2-p-5-control-of-drug-product?, m3-2-p-6-
reference-standards-or-materials?, m3-2-p-7-container-closure-system?, m3-2-p-8-
stability?)>
<!ATTLIST m3-2-p-drug-product
%att;
product-name CDATA #IMPLIED
dosageform CDATA #IMPLIED
manufacturer CDATA #IMPLIED
>
<!ELEMENT m3-2-p-1-description-and-composition-of-the-drug-product ((leaf | node-
extension)*)>
<!ATTLIST m3-2-p-1-description-and-composition-of-the-drug-product
%att;
>
<!ELEMENT m3-2-p-2-pharmaceutical-development ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-2-pharmaceutical-development
%att;
>
<!ELEMENT m3-2-p-3-manufacture (leaf*, m3-2-p-3-1-manufacturers?, m3-2-p-3-2-
batch-formula?, m3-2-p-3-3-description-of-manufacturing-process-and-process-
controls?, m3-2-p-3-4-controls-of-critical-steps-and-intermediates?, m3-2-p-3-5-process-
validation-and-or-evaluation?)>
<!ATTLIST m3-2-p-3-manufacture
%att;
>
<!ELEMENT m3-2-p-3-1-manufacturers ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-3-1-manufacturers
%att;
>
<!ELEMENT m3-2-p-3-2-batch-formula ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-3-2-batch-formula
%att;
>
<!ELEMENT m3-2-p-3-3-description-of-manufacturing-process-and-process-controls
((leaf | node-extension)*)>
<!ATTLIST m3-2-p-3-3-description-of-manufacturing-process-and-process-controls
%att;
>
<!ELEMENT m3-2-p-3-4-controls-of-critical-steps-and-intermediates ((leaf | node-
extension)*)>
<!ATTLIST m3-2-p-3-4-controls-of-critical-steps-and-intermediates
%att;
>
<!ELEMENT m3-2-p-3-5-process-validation-and-or-evaluation ((leaf | node-
extension)*)>
<!ATTLIST m3-2-p-3-5-process-validation-and-or-evaluation
%att;
>
<!ELEMENT m3-2-p-4-control-of-excipients (leaf*, m3-2-p-4-1-specifications?, m3-2-
p-4-2-analytical-procedures?, m3-2-p-4-3-validation-of-analytical-procedures?, m3-2-p-
4-4-justification-of-specifications?, m3-2-p-4-5-excipients-of-human-or-animal-origin?,
m3-2-p-4-6-novel-excipients?)>
<!ATTLIST m3-2-p-4-control-of-excipients
%att;
excipient CDATA #IMPLIED
>
<!ELEMENT m3-2-p-4-1-specifications ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-4-1-specifications
%att;
>
<!ELEMENT m3-2-p-4-2-analytical-procedures ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-4-2-analytical-procedures
%att;
>
<!ELEMENT m3-2-p-4-3-validation-of-analytical-procedures ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-4-3-validation-of-analytical-procedures
%att;
>
<!ELEMENT m3-2-p-4-4-justification-of-specifications ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-4-4-justification-of-specifications
%att;
>
<!ELEMENT m3-2-p-4-5-excipients-of-human-or-animal-origin ((leaf | node-
extension)*)>
<!ATTLIST m3-2-p-4-5-excipients-of-human-or-animal-origin
%att;
>
<!ELEMENT m3-2-p-4-6-novel-excipients ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-4-6-novel-excipients
%att;
>
<!ELEMENT m3-2-p-5-control-of-drug-product (leaf*, m3-2-p-5-1-specifications?, m3-
2-p-5-2-analytical-procedures?, m3-2-p-5-3-validation-of-analytical-procedures?, m3-2-
p-5-4-batch-analyses?, m3-2-p-5-5-characterisation-of-impurities?, m3-2-p-5-6-
justification-of-specifications?)>
<!ATTLIST m3-2-p-5-control-of-drug-product
%att;
>
<!ELEMENT m3-2-p-5-1-specifications ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-5-1-specifications
%att;
>
<!ELEMENT m3-2-p-5-2-analytical-procedures ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-5-2-analytical-procedures
%att;
>
<!ELEMENT m3-2-p-5-3-validation-of-analytical-procedures ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-5-3-validation-of-analytical-procedures
%att;
>
<!ELEMENT m3-2-p-5-4-batch-analyses ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-5-4-batch-analyses
%att;
>
<!ELEMENT m3-2-p-5-5-characterisation-of-impurities ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-5-5-characterisation-of-impurities
%att;
>
<!ELEMENT m3-2-p-5-6-justification-of-specifications ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-5-6-justification-of-specifications
%att;
>
<!ELEMENT m3-2-p-6-reference-standards-or-materials ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-6-reference-standards-or-materials
%att;
>
<!ELEMENT m3-2-p-7-container-closure-system ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-7-container-closure-system
%att;
>
<!ELEMENT m3-2-p-8-stability (leaf*, m3-2-p-8-1-stability-summary-and-conclusion?,
m3-2-p-8-2-post-approval-stability-protocol-and-stability-commitment?, m3-2-p-8-3-
stability-data?)>
<!ATTLIST m3-2-p-8-stability
%att;
>
<!ELEMENT m3-2-p-8-1-stability-summary-and-conclusion ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-8-1-stability-summary-and-conclusion
%att;
>
<!ELEMENT m3-2-p-8-2-post-approval-stability-protocol-and-stability-commitment
((leaf | node-extension)*)>
<!ATTLIST m3-2-p-8-2-post-approval-stability-protocol-and-stability-commitment
%att;
>
<!ELEMENT m3-2-p-8-3-stability-data ((leaf | node-extension)*)>
<!ATTLIST m3-2-p-8-3-stability-data
%att;
>
<!ELEMENT m3-2-a-appendices (leaf*, m3-2-a-1-facilities-and-equipment*, m3-2-a-2-
adventitious-agents-safety-evaluation*, m3-2-a-3-excipients?)>
<!ATTLIST m3-2-a-appendices
%att;
>
<!ELEMENT m3-2-a-1-facilities-and-equipment ((leaf | node-extension)*)>
<!ATTLIST m3-2-a-1-facilities-and-equipment
%att;
manufacturer CDATA #IMPLIED
substance CDATA #IMPLIED
dosageform CDATA #IMPLIED
product-name CDATA #IMPLIED
>
<!ELEMENT m3-2-a-2-adventitious-agents-safety-evaluation ((leaf | node-extension)*)>
<!ATTLIST m3-2-a-2-adventitious-agents-safety-evaluation
%att;
manufacturer CDATA #IMPLIED
substance CDATA #IMPLIED
dosageform CDATA #IMPLIED
product-name CDATA #IMPLIED
>
<!ELEMENT m3-2-a-3-excipients ((leaf | node-extension)*)>
<!ATTLIST m3-2-a-3-excipients
%att;
>
<!ELEMENT m3-2-r-regional-information ((leaf | node-extension)*)>
<!ATTLIST m3-2-r-regional-information
%att;
>
<!ELEMENT m3-3-literature-references ((leaf | node-extension)*)>
<!ATTLIST m3-3-literature-references
%att;
>
<!ELEMENT m4-nonclinical-study-reports (leaf*, m4-2-study-reports?, m4-3-literature-
references?)>
<!ATTLIST m4-nonclinical-study-reports
%att;
>
<!ELEMENT m4-2-study-reports (leaf*, m4-2-1-pharmacology?, m4-2-2-
pharmacokinetics?, m4-2-3-toxicology?)>
<!ATTLIST m4-2-study-reports
%att;
>
<!ELEMENT m4-2-1-pharmacology (leaf*, m4-2-1-1-primary-pharmacodynamics?, m4-
2-1-2-secondary-pharmacodynamics?, m4-2-1-3-safety-pharmacology?, m4-2-1-4-
pharmacodynamic-drug-interactions?)>
<!ATTLIST m4-2-1-pharmacology
%att;
>
<!ELEMENT m4-2-1-1-primary-pharmacodynamics ((leaf | node-extension)*)>
<!ATTLIST m4-2-1-1-primary-pharmacodynamics
%att;
>
<!ELEMENT m4-2-1-2-secondary-pharmacodynamics ((leaf | node-extension)*)>
<!ATTLIST m4-2-1-2-secondary-pharmacodynamics
%att;
>
<!ELEMENT m4-2-1-3-safety-pharmacology ((leaf | node-extension)*)>
<!ATTLIST m4-2-1-3-safety-pharmacology
%att;
>
<!ELEMENT m4-2-1-4-pharmacodynamic-drug-interactions ((leaf | node-extension)*)>
<!ATTLIST m4-2-1-4-pharmacodynamic-drug-interactions
%att;
>
<!ELEMENT m4-2-2-pharmacokinetics (leaf*, m4-2-2-1-analytical-methods-and-
validation-reports?, m4-2-2-2-absorption?, m4-2-2-3-distribution?, m4-2-2-4-
metabolism?, m4-2-2-5-excretion?, m4-2-2-6-pharmacokinetic-drug-interactions?, m4-2-
2-7-other-pharmacokinetic-studies?)>
<!ATTLIST m4-2-2-pharmacokinetics
%att;
>
<!ELEMENT m4-2-2-1-analytical-methods-and-validation-reports ((leaf | node-
extension)*)>
<!ATTLIST m4-2-2-1-analytical-methods-and-validation-reports
%att;
>
<!ELEMENT m4-2-2-2-absorption ((leaf | node-extension)*)>
<!ATTLIST m4-2-2-2-absorption
%att;
>
<!ELEMENT m4-2-2-3-distribution ((leaf | node-extension)*)>
<!ATTLIST m4-2-2-3-distribution
%att;
>
<!ELEMENT m4-2-2-4-metabolism ((leaf | node-extension)*)>
<!ATTLIST m4-2-2-4-metabolism
%att;
>
<!ELEMENT m4-2-2-5-excretion ((leaf | node-extension)*)>
<!ATTLIST m4-2-2-5-excretion
%att;
>
<!ELEMENT m4-2-2-6-pharmacokinetic-drug-interactions ((leaf | node-extension)*)>
<!ATTLIST m4-2-2-6-pharmacokinetic-drug-interactions
%att;
>
<!ELEMENT m4-2-2-7-other-pharmacokinetic-studies ((leaf | node-extension)*)>
<!ATTLIST m4-2-2-7-other-pharmacokinetic-studies
%att;
>
<!ELEMENT m4-2-3-toxicology (leaf*, m4-2-3-1-single-dose-toxicity?, m4-2-3-2-
repeat-dose-toxicity?, m4-2-3-3-genotoxicity?, m4-2-3-4-carcinogenicity?, m4-2-3-5-
reproductive-and-developmental-toxicity?, m4-2-3-6-local-tolerance?, m4-2-3-7-other-
toxicity-studies?)>
<!ATTLIST m4-2-3-toxicology
%att;
>
<!ELEMENT m4-2-3-1-single-dose-toxicity ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-1-single-dose-toxicity
%att;
>
<!ELEMENT m4-2-3-2-repeat-dose-toxicity ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-2-repeat-dose-toxicity
%att;
>
<!ELEMENT m4-2-3-3-genotoxicity (leaf*, m4-2-3-3-1-in-vitro?, m4-2-3-3-2-in-
vivo?)>
<!ATTLIST m4-2-3-3-genotoxicity
%att;
>
<!ELEMENT m4-2-3-3-1-in-vitro ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-3-1-in-vitro
%att;
>
<!ELEMENT m4-2-3-3-2-in-vivo ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-3-2-in-vivo
%att;
>
<!ELEMENT m4-2-3-4-carcinogenicity (leaf*, m4-2-3-4-1-long-term-studies?, m4-2-3-
4-2-short-or-medium-term-studies?, m4-2-3-4-3-other-studies?)>
<!ATTLIST m4-2-3-4-carcinogenicity
%att;
>
<!ELEMENT m4-2-3-4-1-long-term-studies ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-4-1-long-term-studies
%att;
>
<!ELEMENT m4-2-3-4-2-short-or-medium-term-studies ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-4-2-short-or-medium-term-studies
%att;
>
<!ELEMENT m4-2-3-4-3-other-studies ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-4-3-other-studies
%att;
>
<!ELEMENT m4-2-3-5-reproductive-and-developmental-toxicity (leaf*, m4-2-3-5-1-
fertility-and-early-embryonic-development?, m4-2-3-5-2-embryo-fetal-development?,
m4-2-3-5-3-prenatal-and-postnatal-development-including-maternal-function?, m4-2-3-
5-4-studies-in-which-the-offspring-juvenile-animals-are-dosed-and-or-further-
evaluated?)>
<!ATTLIST m4-2-3-5-reproductive-and-developmental-toxicity
%att;
>
<!ELEMENT m4-2-3-5-1-fertility-and-early-embryonic-development ((leaf | node-
extension)*)>
<!ATTLIST m4-2-3-5-1-fertility-and-early-embryonic-development
%att;
>
<!ELEMENT m4-2-3-5-2-embryo-fetal-development ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-5-2-embryo-fetal-development
%att;
>
<!ELEMENT m4-2-3-5-3-prenatal-and-postnatal-development-including-maternal-
function ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-5-3-prenatal-and-postnatal-development-including-maternal-
function
%att;
>
<!ELEMENT m4-2-3-5-4-studies-in-which-the-offspring-juvenile-animals-are-dosed-
and-or-further-evaluated ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-5-4-studies-in-which-the-offspring-juvenile-animals-are-dosed-and-
or-further-evaluated
%att;
>
<!ELEMENT m4-2-3-6-local-tolerance ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-6-local-tolerance
%att;
>
<!ELEMENT m4-2-3-7-other-toxicity-studies (leaf*, m4-2-3-7-1-antigenicity?, m4-2-3-
7-2-immunotoxicity?, m4-2-3-7-3-mechanistic-studies?, m4-2-3-7-4-dependence?, m4-2-
3-7-5-metabolites?, m4-2-3-7-6-impurities?, m4-2-3-7-7-other?)>
<!ATTLIST m4-2-3-7-other-toxicity-studies
%att;
>
<!ELEMENT m4-2-3-7-1-antigenicity ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-7-1-antigenicity
%att;
>
<!ELEMENT m4-2-3-7-2-immunotoxicity ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-7-2-immunotoxicity
%att;
>
<!ELEMENT m4-2-3-7-3-mechanistic-studies ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-7-3-mechanistic-studies
%att;
>
<!ELEMENT m4-2-3-7-4-dependence ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-7-4-dependence
%att;
>
<!ELEMENT m4-2-3-7-5-metabolites ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-7-5-metabolites
%att;
>
<!ELEMENT m4-2-3-7-6-impurities ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-7-6-impurities
%att;
>
<!ELEMENT m4-2-3-7-7-other ((leaf | node-extension)*)>
<!ATTLIST m4-2-3-7-7-other
%att;
>
<!ELEMENT m4-3-literature-references ((leaf | node-extension)*)>
<!ATTLIST m4-3-literature-references
%att;
>
<!ELEMENT m5-clinical-study-reports (leaf*, m5-2-tabular-listing-of-all-clinical-
studies?, m5-3-clinical-study-reports?, m5-4-literature-references?)>
<!ATTLIST m5-clinical-study-reports
%att;
>
<!ELEMENT m5-2-tabular-listing-of-all-clinical-studies ((leaf | node-extension)*)>
<!ATTLIST m5-2-tabular-listing-of-all-clinical-studies
%att;
>
<!ELEMENT m5-3-clinical-study-reports (leaf*, m5-3-1-reports-of-biopharmaceutic-
studies?, m5-3-2-reports-of-studies-pertinent-to-pharmacokinetics-using-human-
biomaterials?, m5-3-3-reports-of-human-pharmacokinetics-pk-studies?, m5-3-4-reports-
of-human-pharmacodynamics-pd-studies?, m5-3-5-reports-of-efficacy-and-safety-
studies*, m5-3-6-reports-of-postmarketing-experience?, m5-3-7-case-report-forms-and-
individual-patient-listings?)>
<!ATTLIST m5-3-clinical-study-reports
%att;
>
<!ELEMENT m5-3-1-reports-of-biopharmaceutic-studies (leaf*, m5-3-1-1-
bioavailability-study-reports?, m5-3-1-2-comparative-ba-and-bioequivalence-study-
reports?, m5-3-1-3-in-vitro-in-vivo-correlation-study-reports?, m5-3-1-4-reports-of-
bioanalytical-and-analytical-methods-for-human-studies?)>
<!ATTLIST m5-3-1-reports-of-biopharmaceutic-studies
%att;
>
<!ELEMENT m5-3-1-1-bioavailability-study-reports ((leaf | node-extension)*)>
<!ATTLIST m5-3-1-1-bioavailability-study-reports
%att;
>
<!ELEMENT m5-3-1-2-comparative-ba-and-bioequivalence-study-reports ((leaf | node-
extension)*)>
<!ATTLIST m5-3-1-2-comparative-ba-and-bioequivalence-study-reports
%att;
>
<!ELEMENT m5-3-1-3-in-vitro-in-vivo-correlation-study-reports ((leaf | node-
extension)*)>
<!ATTLIST m5-3-1-3-in-vitro-in-vivo-correlation-study-reports
%att;
>
<!ELEMENT m5-3-1-4-reports-of-bioanalytical-and-analytical-methods-for-human-
studies ((leaf | node-extension)*)>
<!ATTLIST m5-3-1-4-reports-of-bioanalytical-and-analytical-methods-for-human-
studies
%att;
>
<!ELEMENT m5-3-2-reports-of-studies-pertinent-to-pharmacokinetics-using-human-
biomaterials (leaf*, m5-3-2-1-plasma-protein-binding-study-reports?, m5-3-2-2-reports-
of-hepatic-metabolism-and-drug-interaction-studies?, m5-3-2-3-reports-of-studies-using-
other-human-biomaterials?)>
<!ATTLIST m5-3-2-reports-of-studies-pertinent-to-pharmacokinetics-using-human-
biomaterials
%att;
>
<!ELEMENT m5-3-2-1-plasma-protein-binding-study-reports ((leaf | node-extension)*)>
<!ATTLIST m5-3-2-1-plasma-protein-binding-study-reports
%att;
>
<!ELEMENT m5-3-2-2-reports-of-hepatic-metabolism-and-drug-interaction-studies
((leaf | node-extension)*)>
<!ATTLIST m5-3-2-2-reports-of-hepatic-metabolism-and-drug-interaction-studies
%att;
>
<!ELEMENT m5-3-2-3-reports-of-studies-using-other-human-biomaterials ((leaf | node-
extension)*)>
<!ATTLIST m5-3-2-3-reports-of-studies-using-other-human-biomaterials
%att;
>
<!ELEMENT m5-3-3-reports-of-human-pharmacokinetics-pk-studies (leaf*, m5-3-3-1-
healthy-subject-pk-and-initial-tolerability-study-reports?, m5-3-3-2-patient-pk-and-
initial-tolerability-study-reports?, m5-3-3-3-intrinsic-factor-pk-study-reports?, m5-3-3-4-
extrinsic-factor-pk-study-reports?, m5-3-3-5-population-pk-study-reports?)>
<!ATTLIST m5-3-3-reports-of-human-pharmacokinetics-pk-studies
%att;
>
<!ELEMENT m5-3-3-1-healthy-subject-pk-and-initial-tolerability-study-reports ((leaf |
node-extension)*)>
<!ATTLIST m5-3-3-1-healthy-subject-pk-and-initial-tolerability-study-reports
%att;
>
<!ELEMENT m5-3-3-2-patient-pk-and-initial-tolerability-study-reports ((leaf | node-
extension)*)>
<!ATTLIST m5-3-3-2-patient-pk-and-initial-tolerability-study-reports
%att;
>
<!ELEMENT m5-3-3-3-intrinsic-factor-pk-study-reports ((leaf | node-extension)*)>
<!ATTLIST m5-3-3-3-intrinsic-factor-pk-study-reports
%att;
>
<!ELEMENT m5-3-3-4-extrinsic-factor-pk-study-reports ((leaf | node-extension)*)>
<!ATTLIST m5-3-3-4-extrinsic-factor-pk-study-reports
%att;
>
<!ELEMENT m5-3-3-5-population-pk-study-reports ((leaf | node-extension)*)>
<!ATTLIST m5-3-3-5-population-pk-study-reports
%att;
>
<!ELEMENT m5-3-4-reports-of-human-pharmacodynamics-pd-studies (leaf*, m5-3-4-1-
healthy-subject-pd-and-pk-pd-study-reports?, m5-3-4-2-patient-pd-and-pk-pd-study-
reports?)>
<!ATTLIST m5-3-4-reports-of-human-pharmacodynamics-pd-studies
%att;
>
<!ELEMENT m5-3-4-1-healthy-subject-pd-and-pk-pd-study-reports ((leaf | node-
extension)*)>
<!ATTLIST m5-3-4-1-healthy-subject-pd-and-pk-pd-study-reports
%att;
>
<!ELEMENT m5-3-4-2-patient-pd-and-pk-pd-study-reports ((leaf | node-extension)*)>
<!ATTLIST m5-3-4-2-patient-pd-and-pk-pd-study-reports
%att;
>
<!ELEMENT m5-3-5-reports-of-efficacy-and-safety-studies (leaf*, m5-3-5-1-study-
reports-of-controlled-clinical-studies-pertinent-to-the-claimed-indication?, m5-3-5-2-
study-reports-of-uncontrolled-clinical-studies?, m5-3-5-3-reports-of-analyses-of-data-
from-more-than-one-study?, m5-3-5-4-other-study-reports?)>
<!ATTLIST m5-3-5-reports-of-efficacy-and-safety-studies
%att;
indication CDATA #REQUIRED
>
<!ELEMENT m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-
claimed-indication ((leaf | node-extension)*)>
<!ATTLIST m5-3-5-1-study-reports-of-controlled-clinical-studies-pertinent-to-the-
claimed-indication
%att;
>
<!ELEMENT m5-3-5-2-study-reports-of-uncontrolled-clinical-studies ((leaf | node-
extension)*)>
<!ATTLIST m5-3-5-2-study-reports-of-uncontrolled-clinical-studies
%att;
>
<!ELEMENT m5-3-5-3-reports-of-analyses-of-data-from-more-than-one-study ((leaf |
node-extension)*)>
<!ATTLIST m5-3-5-3-reports-of-analyses-of-data-from-more-than-one-study
%att;
>
<!ELEMENT m5-3-5-4-other-study-reports ((leaf | node-extension)*)>
<!ATTLIST m5-3-5-4-other-study-reports
%att;
>
<!ELEMENT m5-3-6-reports-of-postmarketing-experience ((leaf | node-extension)*)>
<!ATTLIST m5-3-6-reports-of-postmarketing-experience
%att;
>
<!ELEMENT m5-3-7-case-report-forms-and-individual-patient-listings ((leaf | node-
extension)*)>
<!ATTLIST m5-3-7-case-report-forms-and-individual-patient-listings
%att;
>
<!ELEMENT m5-4-literature-references ((leaf | node-extension)*)>
<!ATTLIST m5-4-literature-references
%att;
>
SECTION 19
6/30/03
-->
<!-- ===================== TOP LEVEL ELEMENTS
======================= -->
<!ENTITY % att " ID ID #IMPLIED
xml:lang CDATA #IMPLIED">
<!ELEMENT fda-regional:fda-regional (admin, m1-regional?)>
<!ATTLIST fda-regional:fda-regional
xmlns:fda-regional CDATA #FIXED "http://www.ich.org/fda"
xmlns:xlink CDATA #FIXED "http://www.w3c.org/1999/xlink"
xml:lang CDATA #IMPLIED
dtd-version CDATA #FIXED "2.01"
>
<!-- ===================== LEAF CONTENT
============================= -->
<!ELEMENT leaf (title, link-text?)>
<!ATTLIST leaf
ID ID #REQUIRED
application-version CDATA #IMPLIED
version CDATA #IMPLIED
font-library CDATA #IMPLIED
operation (new | append | replace | delete) #REQUIRED
modified-file CDATA #IMPLIED
checksum CDATA #IMPLIED
checksum-type CDATA #IMPLIED
keywords CDATA #IMPLIED
xmlns:xlink CDATA #FIXED "http://www.w3c.org/1999/xlink"
xlink:type CDATA #FIXED "simple"
xlink:role CDATA #IMPLIED
xlink:href CDATA #IMPLIED
xlink:show (new | replace | embed | other | none) #IMPLIED
xlink:actuate (onLoad | onRequest | other | none) #IMPLIED
xml:lang CDATA #IMPLIED
>
<!ELEMENT title (#PCDATA)>
<!ATTLIST title
ID ID #IMPLIED
>
<!ELEMENT link-text (#PCDATA | xref)*>
<!ATTLIST link-text
ID ID #IMPLIED
>
<!ELEMENT xref EMPTY>
<!ATTLIST xref
ID ID #IMPLIED
xmlns:xlink CDATA #FIXED "http://www.w3c.org/1999/xlink"
xlink:type CDATA #FIXED "simple"
xlink:role CDATA #IMPLIED
xlink:title CDATA #REQUIRED
xlink:href CDATA #REQUIRED
xlink:show (new | replace | embed | other | none) #IMPLIED
xlink:actuate (onLoad | onRequest | other | none) #IMPLIED
>
<!ELEMENT node-extension (title, (leaf | node-extension)+)>
<!ATTLIST node-extension
ID ID #IMPLIED
xml:lang CDATA #IMPLIED
>
<!-- ===================== ADMIN
==================================== -->
<!ELEMENT admin (applicant-info, product-description, application-information)>
<!-- ********************* Applicant Information ******************** -->
<!ELEMENT applicant-info (company-name, date-of-submission)>
<!ELEMENT company-name (#PCDATA)>
<!ELEMENT date-of-submission (date)>
<!ELEMENT date (#PCDATA)>
<!ATTLIST date
format (yyyymmdd) #REQUIRED
>
<!-- ********************* Product Description ********************** -->
<!ELEMENT product-description (application-number, prod-name+)>
<!ELEMENT application-number (#PCDATA)>
<!ELEMENT prod-name (#PCDATA)>
<!ATTLIST prod-name
type (established | proprietary | chemical | code) #REQUIRED
>
<!-- ********************* Application Information ****************** -->
<!ELEMENT application-information (submission)>
<!ATTLIST application-information
application-type (nda | anda | bla | dmf | ind | master-file) #REQUIRED
>
<!ELEMENT submission (sequence-number, related-sequence-number*)>
<!ATTLIST submission
submission-type (original-application | amendment | resubmission |
presubmission | annual-report | establishment-description-supplement |
efficacy-supplement | labeling-supplement |
chemistry-manufacturing-controls-supplement | other) #REQUIRED
>
<!ELEMENT sequence-number (#PCDATA)>
<!ELEMENT related-sequence-number (#PCDATA)>
<!-- ===================== M1 REGIONAL STRUCTURE
==================== -->
<!ELEMENT m1-regional (m1-1-forms?, m1-2-cover-letters?,
m1-3-administrative-information?, m1-4-references?, m1-5-application-status?,
m1-6-meetings?, m1-7-fast-track?, m1-8-special-protocol-assessment-request?,
m1-9-pediatric-administrative-information?, m1-10-dispute-resolution?,
m1-11-information-amendment?, m1-12-other-correspondence?,
m1-13-annual-report?, m1-14-labeling?, m1-15-promotional-material?,
m1-16-risk-management-plans?)>
<!ATTLIST m1-regional
%att;
>
<!-- ===================== FORMS
==================================== -->
<!ELEMENT m1-1-forms (m1-1-1-fda-form-1571?, m1-1-2-fda-form-356h?,
m1-1-3-fda-form-3397?, m1-1-4-fda-form-2252?, m1-1-5-fda-form-2253?,
m1-1-6-fda-form-2567?)>
<!ATTLIST m1-1-forms
%att;
>
<!ELEMENT m1-1-1-fda-form-1571 ((leaf | node-extension)*)>
<!ATTLIST m1-1-1-fda-form-1571
%att;
>
<!ELEMENT m1-1-2-fda-form-356h ((leaf | node-extension)*)>
<!ATTLIST m1-1-2-fda-form-356h
%att;
>
<!ELEMENT m1-1-3-fda-form-3397 ((leaf | node-extension)*)>
<!ATTLIST m1-1-3-fda-form-3397
%att;
>
<!ELEMENT m1-1-4-fda-form-2252 ((leaf | node-extension)*)>
<!ATTLIST m1-1-4-fda-form-2252
%att;
>
<!ELEMENT m1-1-5-fda-form-2253 ((leaf | node-extension)*)>
<!ATTLIST m1-1-5-fda-form-2253
%att;
>
<!ELEMENT m1-1-6-fda-form-2567 ((leaf | node-extension)*)>
<!ATTLIST m1-1-6-fda-form-2567
%att;
>
<!-- ===================== COVER LETTERS
============================ -->
<!ELEMENT m1-2-cover-letters ((leaf | node-extension)*)>
<!ATTLIST m1-2-cover-letters
%att;
>
<!-- ===================== ADMINISTRATIVE INFORMATION
=============== -->
<!ELEMENT m1-3-administrative-information (m1-3-1-applicant-information*,
m1-3-2-field-copy-certification*, m1-3-3-debarment-certification*,
m1-3-4-financial-certification-disclosure*, m1-3-5-patent-exclusivity*)>
<!ATTLIST m1-3-administrative-information
%att;
>
<!ELEMENT m1-3-1-applicant-information
(m1-3-1-1-change-of-address-or-corporate-name*, m1-3-1-2-change-contact-agent*,
m1-3-1-3-change-in-sponsor*, m1-3-1-4-transfer-obligation*,
m1-3-1-5-change-application-ownership*)>
<!ATTLIST m1-3-1-applicant-information
%att;
>
<!ELEMENT m1-3-1-1-change-of-address-or-corporate-name ((leaf |
node-extension)*)>
<!ATTLIST m1-3-1-1-change-of-address-or-corporate-name
%att;
>
<!ELEMENT m1-3-1-2-change-contact-agent ((leaf | node-extension)*)>
<!ATTLIST m1-3-1-2-change-contact-agent
%att;
>
<!ELEMENT m1-3-1-3-change-in-sponsor ((leaf | node-extension)*)>
<!ATTLIST m1-3-1-3-change-in-sponsor
%att;
>
<!ELEMENT m1-3-1-4-transfer-obligation ((leaf | node-extension)*)>
<!ATTLIST m1-3-1-4-transfer-obligation
%att;
>
<!ELEMENT m1-3-1-5-change-application-ownership ((leaf | node-extension)*)>
<!ATTLIST m1-3-1-5-change-application-ownership
%att;
>
<!-- ===================== FIELD COPY CERTIFICATION
================= -->
<!ELEMENT m1-3-2-field-copy-certification ((leaf | node-extension)*)>
<!ATTLIST m1-3-2-field-copy-certification
%att;
>
<!-- ===================== DEBARMENT CERTIFICATION
================== -->
<!ELEMENT m1-3-3-debarment-certification ((leaf | node-extension)*)>
<!ATTLIST m1-3-3-debarment-certification
%att;
>
<!-- ===================== FINANCIAL CERTIFICATION DISCLOSURE
======= -->
<!ELEMENT m1-3-4-financial-certification-disclosure ((leaf | node-extension)*)>
<!ATTLIST m1-3-4-financial-certification-disclosure
%att;
>
<!-- ===================== PATENT EXCLUSIVITIY
====================== -->
<!ELEMENT m1-3-5-patent-exclusivity (m1-3-5-1-patent-information*,
m1-3-5-2-patent-certification*, m1-3-5-3-exclusivity-request*)>
<!ATTLIST m1-3-5-patent-exclusivity
%att;
>
<!ELEMENT m1-3-5-1-patent-information ((leaf | node-extension)*)>
<!ATTLIST m1-3-5-1-patent-information
%att;
>
<!ELEMENT m1-3-5-2-patent-certification ((leaf | node-extension)*)>
<!ATTLIST m1-3-5-2-patent-certification
%att;
>
<!ELEMENT m1-3-5-3-exclusivity-request ((leaf | node-extension)*)>
<!ATTLIST m1-3-5-3-exclusivity-request
%att;
>
<!-- ===================== REFERENCES
=============================== -->
<!ELEMENT m1-4-references (m1-4-1-letter-authorization*,
m1-4-2-statement-right-reference*,
m1-4-3-list-of-authorized-persons-to-incorporate-by-reference*,
m1-4-4-cross-reference-other-applications*)>
<!ATTLIST m1-4-references
%att;
>
<!ELEMENT m1-4-1-letter-authorization ((leaf | node-extension)*)>
<!ATTLIST m1-4-1-letter-authorization
%att;
>
<!ELEMENT m1-4-2-statement-right-reference ((leaf | node-extension)*)>
<!ATTLIST m1-4-2-statement-right-reference
%att;
>
<!ELEMENT m1-4-3-list-of-authorized-persons-to-incorporate-by-reference ((leaf |
node-extension)*)>
<!ATTLIST m1-4-3-list-of-authorized-persons-to-incorporate-by-reference
%att;
>
<!ELEMENT m1-4-4-cross-reference-other-applications ((leaf | node-extension)*)>
<!ATTLIST m1-4-4-cross-reference-other-applications
%att;
>
<!-- ===================== APPLICATION STATUS
======================= -->
<!ELEMENT m1-5-application-status (m1-5-1-withdrawal-request*,
m1-5-2-inactivation-request*, m1-5-3-reactivation-request*,
m1-5-4-reinstatement-request*, m1-5-5-withdrawal-unapproved-nda*,
m1-5-6-withdrawal-of-listed-drug*,
m1-5-7-request-withdrawal-application-approval*)>
<!ATTLIST m1-5-application-status
%att;
>
<!ELEMENT m1-5-1-withdrawal-request ((leaf | node-extension)*)>
<!ATTLIST m1-5-1-withdrawal-request
%att;
>
<!ELEMENT m1-5-2-inactivation-request ((leaf | node-extension)*)>
<!ATTLIST m1-5-2-inactivation-request
%att;
>
<!ELEMENT m1-5-3-reactivation-request ((leaf | node-extension)*)>
<!ATTLIST m1-5-3-reactivation-request
%att;
>
<!ELEMENT m1-5-4-reinstatement-request ((leaf | node-extension)*)>
<!ATTLIST m1-5-4-reinstatement-request
%att;
>
<!ELEMENT m1-5-5-withdrawal-unapproved-nda ((leaf | node-extension)*)>
<!ATTLIST m1-5-5-withdrawal-unapproved-nda
%att;
>
<!ELEMENT m1-5-6-withdrawal-of-listed-drug ((leaf | node-extension)*)>
<!ATTLIST m1-5-6-withdrawal-of-listed-drug
%att;
>
<!ELEMENT m1-5-7-request-withdrawal-application-approval ((leaf |
node-extension)*)>
<!ATTLIST m1-5-7-request-withdrawal-application-approval
%att;
>
<!-- ===================== MEETINGS
================================= -->
<!ELEMENT m1-6-meetings (m1-6-1-meeting-request*,
m1-6-2-meeting-background-materials*,
m1-6-3-correspondence-regarding-meetings*)>
<!ATTLIST m1-6-meetings
%att;
>
<!ELEMENT m1-6-1-meeting-request ((leaf | node-extension)*)>
<!ATTLIST m1-6-1-meeting-request
%att;
>
<!ELEMENT m1-6-2-meeting-background-materials ((leaf | node-extension)*)>
<!ATTLIST m1-6-2-meeting-background-materials
%att;
>
<!ELEMENT m1-6-3-correspondence-regarding-meetings ((leaf | node-extension)*)>
<!ATTLIST m1-6-3-correspondence-regarding-meetings
%att;
>
<!-- ===================== FAST TRACK
=============================== -->
<!ELEMENT m1-7-fast-track (m1-7-1-fast-track-designation-request*,
m1-7-2-fast-track-designation-withdrawal-request*, m1-7-3-rolling-review-request*)>
<!ATTLIST m1-7-fast-track
%att;
>
<!ELEMENT m1-7-1-fast-track-designation-request ((leaf | node-extension)*)>
<!ATTLIST m1-7-1-fast-track-designation-request
%att;
>
<!ELEMENT m1-7-2-fast-track-designation-withdrawal-request ((leaf |
node-extension)*)>
<!ATTLIST m1-7-2-fast-track-designation-withdrawal-request
%att;
>
<!ELEMENT m1-7-3-rolling-review-request ((leaf | node-extension)*)>
<!ATTLIST m1-7-3-rolling-review-request
%att;
>
<!-- ===================== SPECIAL PROTOCOL ASSESSMENT REQUEST
====== -->
<!ELEMENT m1-8-special-protocol-assessment-request (m1-8-1-clinical-study*,
m1-8-2-carcinogenicity-study*, m1-8-3-stability-study*)>
<!ATTLIST m1-8-special-protocol-assessment-request
%att;
>
<!ELEMENT m1-8-1-clinical-study ((leaf | node-extension)*)>
<!ATTLIST m1-8-1-clinical-study
%att;
>
<!ELEMENT m1-8-2-carcinogenicity-study ((leaf | node-extension)*)>
<!ATTLIST m1-8-2-carcinogenicity-study
%att;
>
<!ELEMENT m1-8-3-stability-study ((leaf | node-extension)*)>
<!ATTLIST m1-8-3-stability-study
%att;
>
<!-- ===================== PEDIATRIC ADMINISTRATIVE INFORMATION
===== -->
<!ELEMENT m1-9-pediatric-administrative-information
(m1-9-1-request-waiver-pediatric-studies*,
m1-9-2-request-deferral-pediatric-studies*,
m1-9-3-request-pediatric-exclusivity-determination*,
m1-9-4-proposed-pediatric-study-request-amendments*,
m1-9-5-proposal-written-agreement*,
m1-9-6-other-correspondence-regarding-pediatric-exclusivity-study-plans*)>
<!ATTLIST m1-9-pediatric-administrative-information
%att;
>
<!ELEMENT m1-9-1-request-waiver-pediatric-studies ((leaf | node-extension)*)>
<!ATTLIST m1-9-1-request-waiver-pediatric-studies
%att;
>
<!ELEMENT m1-9-2-request-deferral-pediatric-studies ((leaf | node-extension)*)>
<!ATTLIST m1-9-2-request-deferral-pediatric-studies
%att;
>
<!ELEMENT m1-9-3-request-pediatric-exclusivity-determination ((leaf |
node-extension)*)>
<!ATTLIST m1-9-3-request-pediatric-exclusivity-determination
%att;
>
<!ELEMENT m1-9-4-proposed-pediatric-study-request-amendments ((leaf |
node-extension)*)>
<!ATTLIST m1-9-4-proposed-pediatric-study-request-amendments
%att;
>
<!ELEMENT m1-9-5-proposal-written-agreement ((leaf | node-extension)*)>
<!ATTLIST m1-9-5-proposal-written-agreement
%att;
>
<!ELEMENT m1-9-6-other-correspondence-regarding-pediatric-exclusivity-study-plans
((leaf | node-extension)*)>
<!ATTLIST m1-9-6-other-correspondence-regarding-pediatric-exclusivity-study-plans
%att;
>
<!-- ===================== DISPUTE RESOLUTION
======================= -->
<!ELEMENT m1-10-dispute-resolution (m1-10-1-request-for-dispute-resolution*,
m1-10-2-correspondence-related-to-dispute-resolution*)>
<!ATTLIST m1-10-dispute-resolution
%att;
>
<!ELEMENT m1-10-1-request-for-dispute-resolution ((leaf | node-extension)*)>
<!ATTLIST m1-10-1-request-for-dispute-resolution
%att;
>
<!ELEMENT m1-10-2-correspondence-related-to-dispute-resolution ((leaf |
node-extension)*)>
<!ATTLIST m1-10-2-correspondence-related-to-dispute-resolution
%att;
>
<!-- ===================== INFORMATION ADMENDMENT
=================== -->
<!ELEMENT m1-11-information-amendment
(m1-11-1-quality-information-amendment*,
m1-11-2-safety-information-amendment*,
m1-11-3-efficacy-information-amendment*,
m1-11-4-multiple-module-information-amendments*)>
<!ATTLIST m1-11-information-amendment
%att;
>
<!ELEMENT m1-11-1-quality-information-amendment ((leaf | node-extension)*)>
<!ATTLIST m1-11-1-quality-information-amendment
%att;
>
<!ELEMENT m1-11-2-safety-information-amendment ((leaf | node-extension)*)>
<!ATTLIST m1-11-2-safety-information-amendment
%att;
>
<!ELEMENT m1-11-3-efficacy-information-amendment ((leaf | node-extension)*)>
<!ATTLIST m1-11-3-efficacy-information-amendment
%att;
>
<!ELEMENT m1-11-4-multiple-module-information-amendments ((leaf |
node-extension)*)>
<!ATTLIST m1-11-4-multiple-module-information-amendments
%att;
>
<!-- ===================== OTHER CORRESPONDENCE
===================== -->
<!ELEMENT m1-12-other-correspondence (m1-12-1-pre-ind-correspondence*,
m1-12-2-request-charge*, m1-12-3-notification-charging-under-treatment-ind*,
m1-12-4-request-comments-advice-ind*, m1-12-5-request-waiver*,
m1-12-6-exemption-informed-consent-emergency-research*,
m1-12-7-public-disclosure-statement-emergency-care-research*,
m1-12-8-correspondence-regarding-emergency-care-research*,
m1-12-9-notification-discontinuation-clinical-trial*,
m1-12-10-generic-drug-enforcement-act-statement*,
m1-12-11-basis-submission-statement*,
m1-12-12-comparison-generic-drug-reference-listed-drug*,
m1-12-13-request-waiver-in-vivo-studies*, m1-12-14-environmental-analysis*,
m1-12-15-request-waiver-in-vivo-bioavailability-studies*,
m1-12-16-field-alert-reports*)>
<!ATTLIST m1-12-other-correspondence
%att;
>
<!ELEMENT m1-12-1-pre-ind-correspondence ((leaf | node-extension)*)>
<!ATTLIST m1-12-1-pre-ind-correspondence
%att;
>
<!ELEMENT m1-12-2-request-charge ((leaf | node-extension)*)>
<!ATTLIST m1-12-2-request-charge
%att;
>
<!ELEMENT m1-12-3-notification-charging-under-treatment-ind ((leaf |
node-extension)*)>
<!ATTLIST m1-12-3-notification-charging-under-treatment-ind
%att;
>
<!ELEMENT m1-12-4-request-comments-advice-ind ((leaf | node-extension)*)>
<!ATTLIST m1-12-4-request-comments-advice-ind
%att;
>
<!ELEMENT m1-12-5-request-waiver ((leaf | node-extension)*)>
<!ATTLIST m1-12-5-request-waiver
%att;
>
<!ELEMENT m1-12-6-exemption-informed-consent-emergency-research ((leaf |
node-extension)*)>
<!ATTLIST m1-12-6-exemption-informed-consent-emergency-research
%att;
>
<!ELEMENT m1-12-7-public-disclosure-statement-emergency-care-research ((leaf |
node-extension)*)>
<!ATTLIST m1-12-7-public-disclosure-statement-emergency-care-research
%att;
>
<!ELEMENT m1-12-8-correspondence-regarding-emergency-care-research ((leaf |
node-extension)*)>
<!ATTLIST m1-12-8-correspondence-regarding-emergency-care-research
%att;
>
<!ELEMENT m1-12-9-notification-discontinuation-clinical-trial ((leaf |
node-extension)*)>
<!ATTLIST m1-12-9-notification-discontinuation-clinical-trial
%att;
>
<!ELEMENT m1-12-10-generic-drug-enforcement-act-statement ((leaf |
node-extension)*)>
<!ATTLIST m1-12-10-generic-drug-enforcement-act-statement
%att;
>
<!ELEMENT m1-12-11-basis-submission-statement ((leaf | node-extension)*)>
<!ATTLIST m1-12-11-basis-submission-statement
%att;
>
<!ELEMENT m1-12-12-comparison-generic-drug-reference-listed-drug ((leaf |
node-extension)*)>
<!ATTLIST m1-12-12-comparison-generic-drug-reference-listed-drug
%att;
>
<!ELEMENT m1-12-13-request-waiver-in-vivo-studies ((leaf | node-extension)*)>
<!ATTLIST m1-12-13-request-waiver-in-vivo-studies
%att;
>
<!ELEMENT m1-12-14-environmental-analysis ((leaf | node-extension)*)>
<!ATTLIST m1-12-14-environmental-analysis
%att;
>
<!ELEMENT m1-12-15-request-waiver-in-vivo-bioavailability-studies ((leaf |
node-extension)*)>
<!ATTLIST m1-12-15-request-waiver-in-vivo-bioavailability-studies
%att;
>
<!ELEMENT m1-12-16-field-alert-reports ((leaf | node-extension)*)>
<!ATTLIST m1-12-16-field-alert-reports
%att;
>
<!-- ===================== ANNUAL REPORT
============================ -->
<!ELEMENT m1-13-annual-report (m1-13-1-summary-nonclinical-studies*,
m1-13-2-summary-clinical-pharmacology-information*,
m1-13-3-summary-safety-information*, m1-13-4-summary-labeling-changes*,
m1-13-5-summary-manufacturing-changes*,
m1-13-6-summary-microbiological-changes*,
m1-13-7-summary-other-significant-new-information*,
m1-13-8-individual-study-information*, m1-13-9-general-investigational-plan*,
m1-13-10-foreign-marketing-history*, m1-13-11-distribution-data*,
m1-13-12-status-postmarketing-study-commitments*,
m1-13-13-status-other-postmarketing-studies*,
m1-13-14-log-outstanding-regulatory-business*)>
<!ATTLIST m1-13-annual-report
%att;
>
<!ELEMENT m1-13-1-summary-nonclinical-studies ((leaf | node-extension)*)>
<!ATTLIST m1-13-1-summary-nonclinical-studies
%att;
>
<!ELEMENT m1-13-2-summary-clinical-pharmacology-information ((leaf |
node-extension)*)>
<!ATTLIST m1-13-2-summary-clinical-pharmacology-information
%att;
>
<!ELEMENT m1-13-3-summary-safety-information ((leaf | node-extension)*)>
<!ATTLIST m1-13-3-summary-safety-information
%att;
>
<!ELEMENT m1-13-4-summary-labeling-changes ((leaf | node-extension)*)>
<!ATTLIST m1-13-4-summary-labeling-changes
%att;
>
<!ELEMENT m1-13-5-summary-manufacturing-changes ((leaf | node-extension)*)>
<!ATTLIST m1-13-5-summary-manufacturing-changes
%att;
>
<!ELEMENT m1-13-6-summary-microbiological-changes ((leaf | node-extension)*)>
<!ATTLIST m1-13-6-summary-microbiological-changes
%att;
>
<!ELEMENT m1-13-7-summary-other-significant-new-information ((leaf |
node-extension)*)>
<!ATTLIST m1-13-7-summary-other-significant-new-information
%att;
>
<!ELEMENT m1-13-8-individual-study-information ((leaf | node-extension)*)>
<!ATTLIST m1-13-8-individual-study-information
%att;
>
<!ELEMENT m1-13-9-general-investigational-plan ((leaf | node-extension)*)>
<!ATTLIST m1-13-9-general-investigational-plan
%att;
>
<!ELEMENT m1-13-10-foreign-marketing-history ((leaf | node-extension)*)>
<!ATTLIST m1-13-10-foreign-marketing-history
%att;
>
<!ELEMENT m1-13-11-distribution-data ((leaf | node-extension)*)>
<!ATTLIST m1-13-11-distribution-data
%att;
>
<!ELEMENT m1-13-12-status-postmarketing-study-commitments ((leaf |
node-extension)*)>
<!ATTLIST m1-13-12-status-postmarketing-study-commitments
%att;
>
<!ELEMENT m1-13-13-status-other-postmarketing-studies ((leaf | node-extension)*)>
<!ATTLIST m1-13-13-status-other-postmarketing-studies
%att;
>
<!ELEMENT m1-13-14-log-outstanding-regulatory-business ((leaf |
node-extension)*)>
<!ATTLIST m1-13-14-log-outstanding-regulatory-business
%att;
>
<!-- ===================== LABELING
================================= -->
<!ELEMENT m1-14-labeling (m1-14-1-draft-labeling*, m1-14-2-final-labeling*,
m1-14-3-listed-drug-labeling*, m1-14-4-investigational-drug-labeling*,
m1-14-5-foreign-labeling*)>
<!ATTLIST m1-14-labeling
%att;
>
<!ELEMENT m1-14-1-draft-labeling (m1-14-1-1-draft-carton-container-labels*,
m1-14-1-2-annotated-draft-labeling-text*, m1-14-1-3-draft-labeling-text*,
m1-14-1-4-label-comprehension-studies*, m1-14-1-5-labeling-history*)>
<!ATTLIST m1-14-1-draft-labeling
%att;
>
<!ELEMENT m1-14-1-1-draft-carton-container-labels ((leaf | node-extension)*)>
<!ATTLIST m1-14-1-1-draft-carton-container-labels
%att;
>
<!ELEMENT m1-14-1-2-annotated-draft-labeling-text ((leaf | node-extension)*)>
<!ATTLIST m1-14-1-2-annotated-draft-labeling-text
%att;
>
<!ELEMENT m1-14-1-3-draft-labeling-text ((leaf | node-extension)*)>
<!ATTLIST m1-14-1-3-draft-labeling-text
%att;
>
<!ELEMENT m1-14-1-4-label-comprehension-studies ((leaf | node-extension)*)>
<!ATTLIST m1-14-1-4-label-comprehension-studies
%att;
>
<!ELEMENT m1-14-1-5-labeling-history ((leaf | node-extension)*)>
<!ATTLIST m1-14-1-5-labeling-history
%att;
>
<!ELEMENT m1-14-2-final-labeling (m1-14-2-1-final-carton-container-labels*,
m1-14-2-2-final-package-insert-package-inserts*, m1-14-2-3-final-labeling-text*)>
<!ATTLIST m1-14-2-final-labeling
%att;
>
<!ELEMENT m1-14-2-1-final-carton-container-labels ((leaf | node-extension)*)>
<!ATTLIST m1-14-2-1-final-carton-container-labels
%att;
>
<!ELEMENT m1-14-2-2-final-package-insert-package-inserts ((leaf |
node-extension)*)>
<!ATTLIST m1-14-2-2-final-package-insert-package-inserts
%att;
>
<!ELEMENT m1-14-2-3-final-labeling-text ((leaf | node-extension)*)>
<!ATTLIST m1-14-2-3-final-labeling-text
%att;
>
<!ELEMENT m1-14-3-listed-drug-labeling
(m1-14-3-1-annotated-comparison-listed-drug*,
m1-14-3-2-approved-labeling-text-listed-drug*,
m1-14-3-3-labeling-text-reference-listed-drug*)>
<!ATTLIST m1-14-3-listed-drug-labeling
%att;
>
<!ELEMENT m1-14-3-1-annotated-comparison-listed-drug ((leaf | node-extension)*)>
<!ATTLIST m1-14-3-1-annotated-comparison-listed-drug
%att;
>
<!ELEMENT m1-14-3-2-approved-labeling-text-listed-drug ((leaf | node-extension)*)>
<!ATTLIST m1-14-3-2-approved-labeling-text-listed-drug
%att;
>
<!ELEMENT m1-14-3-3-labeling-text-reference-listed-drug ((leaf | node-extension)*)>
<!ATTLIST m1-14-3-3-labeling-text-reference-listed-drug
%att;
>
<!ELEMENT m1-14-4-investigational-drug-labeling
(m1-14-4-1-investigational-brochure*, m1-14-4-2-investigational-drug-label*)>
<!ATTLIST m1-14-4-investigational-drug-labeling
%att;
>
<!ELEMENT m1-14-4-1-investigational-brochure ((leaf | node-extension)*)>
<!ATTLIST m1-14-4-1-investigational-brochure
%att;
>
<!ELEMENT m1-14-4-2-investigational-drug-label ((leaf | node-extension)*)>
<!ATTLIST m1-14-4-2-investigational-drug-label
%att;
>
<!ELEMENT m1-14-5-foreign-labeling ((leaf | node-extension)*)>
<!ATTLIST m1-14-5-foreign-labeling
%att;
>
<!-- ===================== PROMOTIONAL MATERIAL
===================== -->
<!ELEMENT m1-15-promotional-material ((leaf | node-extension)*)>
<!ATTLIST m1-15-promotional-material
%att;
>
<!-- ===================== RISK MANAGEMENT
========================= -->
<!ELEMENT m1-16-risk-management-plans ((leaf | node-extension)*)>
<!ATTLIST m1-16-risk-management-plans
%att;
>
SECTION 20
The CTD summary sections in Module 2 are not the correct location for the
integrated summaries of safety and effectiveness (ISS/ISE) required by 21 CFR
314.50 (see ICH M4: The CTD -- Efficacy Q&As, and presentations from the
2006 Drug Information Association Meeting).
The following table lists the various sections of the CTD that contain summary
and integrated discussions of efficacy and safety and the corresponding FDA
regulations, where applicable, that inform the content of those sections. Any
questions about these matters can be raised with the appropriate reviewing
division at FDA.
CTD Section U.S. Regulation Comment
2.5 Clinical Overview
(~30 pages)
2.5.3 Overview of n/a Not a U.S.
Efficacy requirement, but
2.5.4 Overview of Safety recommended by
ICH guidance
Portable Document
Format Specifications
● These specifications are for submitting documents in Portable Document Format
(PDF).
Portable Document Format Specifications
Revision History
Date Version Summary of Changes
2005-04-08 1.0 Initial version
Version 1.0 1
Portable Document Format Specifications
These specifications are for submitting documents in Portable Document Format (PDF).
VERSION
Use PDF Version 1.4. PDF version 1.4 is for use with Adobe Acrobat 5.0 or higher1. No
additional software should be needed to read and navigate the PDF files.
FONTS
Embed fonts. PDF viewing software automatically substitutes a font to display text if the font
used to create the text is unavailable on the reviewer’s computer. In some cases, font
substitution can occur even when the fonts are available. For example, Helvetica or Times are
substituted even if available on the reviewer’s computer. Font substitution can affect a
document’s appearance and structure, and in some cases it can affect the information conveyed
by a document. Font availability is not guaranteed. Font availability to the reviewer is ensured
if all fonts are embedded. When fonts are embedded, all characters for the font should be
included not just a subset of the fonts being used in the document.
Limit fonts to those listed in Table 1. Font embedding does not always solve the problems that
occur when a reviewer tries to paste text from a PDF document into another software format. If
the font is not available on the reviewer’s computer, font substitution results even if the fonts are
embedded. This problem is avoided if the fonts are restricted to those listed in Table 1.
1
It should be noted that Acrobat 6 and 7 use pdfa 1.4.
Version 1.0 2
Portable Document Format Specifications
TimesNewRoman
Other Symbo (Symbol)
ZapfDin (Zapf Dingbats)
Font size ranges from 9 to 12 points. Times New Roman, 12-point font is recommended for
reading narrative text. When choosing a point size for tables, a balance should be made between
providing sufficient information on a single page that may facilitate data comparisons while still
achieving a point size that remains legible. Generally, point sizes 9-10 are recommended for
tables; smaller point sizes should be avoided. Ten point fonts are recommended for footnotes.
Black is the recommended font color except that blue can be used for hypertext links. Light
colors do not print well on grayscale printers. The latter can be tested prior to submission by
printing sample pages from the document using a grayscale printer.
PAGE ORIENTATION
Save the page orientation for proper viewing and printing within the document. Proper page
orientation eliminates the need for reviewers to rotate pages. For example, setting page
orientation of landscape pages to landscape prior to saving the PDF document in final form
ensures a correct page presentation.
Set up the print area for pages to fit on a sheet of paper that is 8.5 inches by 11 inches. A margin
of at least ¾ of an inch on the left side of page avoids obscuring information when pages are
subsequently printed and bound. Setting the margin for at least 3/8 of an inch on the other sides
is sufficient. For pages in landscape orientation, a 3/4 of an inch at the top allows more
information to be displayed legibly on the page. Header and footer information should appear
within these same margins (i.e., within 3/8 of an inch of the edge of the 8.5 by 11 inch page), so
the text will not be lost upon printing or being bound. These margins allow printing on A4 as
well. Oversized documents (e.g., CAD drawings) should be created to their actual page size.
Avoid image based PDF files whenever possible. PDF documents created directly from an
electronic source such as a word processing file provides many advantages over PDF documents
created by scanning paper documents. Scanned documents are more difficult to read and do not
allow the reviewer to search or copy and paste text for editing in other documents.
Use the dpi settings in Table 2 for scanning documents. Scanned documents scanned at a
resolution of 300 dots per inch (dpi) ensure that the pages of the document are legible both on the
computer screen and when printed and, at the same time, minimize the file size. A resolution of
300 dots per inch (dpi) is recommended to balance legibility and file size. The use of grayscale
Version 1.0 3
Portable Document Format Specifications
and color significantly increases the file size and is used only when then these features improve
the reviewability of the material. After scanning, avoid resampling to a lower resolution. A
captured image should not be subjected to nonuniform scaling (i.e., sizing). See the following
table for resolutions for various images.
File compression methods include Zip/Flate and CCITT Group 4. File compression is a method
for reducing file size. Some methods of compression can result in loss of data and can introduce
compression artifacts that affect the reviewability of the information. The following two methods
provide lossless compression.
• Zip/Flate (one technique with two names) for lossless compression of color and grayscale
images is specified in Internet RFC 1950 and RFC 1951.
Because color varies from monitor to monitor, it is difficult to ensure that the reviewer will see
exactly the same color as in the actual image. However, for printing, there is more control over
the color by using CMYK (Cyan, Yellow, Magenta, Black) color model as opposed to the RGB
model. Pantone Matching using the color profile provided by CMYK ensure color consistency
for printing. The International Color Consortium (ICC) color profile specification is used when
PDF documents are printed.
Hypertext links and bookmarks improve navigation through PDF documents. For text, hypertext
links throughout the body of the document to supporting annotations, related sections,
references, appendices, tables, or figures that are not located on the same page as the narrative
text are helpful to improve navigation efficiency. Hypertext links in text can be designated by
Version 1.0 4
Portable Document Format Specifications
rectangles using thin lines or by blue text. A consistent method in a document avoids confusion.
Relative paths when creating hypertext linking minimizes the loss of hyperlink functionality
when folders are moved between disk drives. Both absolute links that reference specific drives
and root directories do not work once the submission is loaded onto network servers are to be
avoided.
The document table of contents helps the reviewer navigate to the information of interest within
the document that is not provided in the submission table of contents. For documents with a table
of contents, bookmarks and hypertext links for each item listed in the table of contents including
all tables, figures, publications, other references, and appendices are essential for navigation
through documents. The use of invisible rectangles and blue text in the table of contents for
hypertext links avoids obscuring text. Other help for navigation includes a bookmark hierarchy
identical to the table of contents up to 4 levels in the hierarchy.
When creating bookmarks and hyperlinks, setting the magnification setting Inherit Zoom so that
the destination page displays at the same magnification level that the reviewer is using for the
rest of the document helps with the review.
PAGE NUMBERING
In general, it is easier to navigate through an electronic document if the page numbers for the
document and the PDF file are the same with the initial page of the document numbered as page
one. There is an exception when a document is split because of its size (e.g., > 100 MB) and the
second or subsequent file is numbered consecutively to that of the first or preceding file.
Set the initial view of the PDF files to Bookmarks and Page. The open dialog box sets the
document view when the file is opened. Set the initial view of the PDF files to Bookmarks and
Page to help with the ease of review. If there are no bookmarks, the initial view is set as Page
only. Magnification and Page Layout is set to default.
Use lower case characters and avoid using special characters except hyphens in file names.
Special characters to avoid include punctuation, underscore, spaces, or other nonalphanumeric
symbols (e.g., \ / : * ? < > | “ % # +) . See other specifications for name length limitations.
Version 1.0 5
SECTION 22
Revision History
Date Version Summary of Changes
2005-05-25 1.0 Original version
2005-06-14 1.1 Correction of typographical error in Type of Media table
1
Specification for Transmitting Electronic Submissions using eCTD Specifications
This document provides specification for transmitting electronic submissions using eCTD
specifications. Details are included for transmitting the electronic submission on physical media
or electronically.
I. PHYSICAL MEDIA
CBER
CDER
B. Type of media
2
Specification for Transmitting Electronic Submissions using eCTD Specifications
C. Media preparation
Send all electronic media adequately secured in a standard binder marked clearly on the outside
ELECTRONIC REGULATORY SUBMISSION FOR ARCHIVE. The following information
should be included on the media labels:
Sponsor, applicant or company name
Name of the product, chemical or ingredient
Appropriate regulatory ID number (e.g., IND number)
Submission date (dd-mmm-yyyy)
Media series (e.g., “1 of 1”, “1 of 2”
3
SECTION 23
The Backdrop
• NDAs will have multiple submissions over their life-cycle
– The 10 most active eNDAs ranged from 76 to 202 electronic
submissions:
• 6 had 111 to 139 submissions
• 1 had 185 submissions
• 1 had 202 submissions
• NDA submissions contain thousands of files in a single
submission
– One initial submission in FY 2003 had 5478 files
– One eCTD submission in FY 2004 had over 15000 files in a
supplement
• Typically the majority of files are Study Report Files such as Case
Report Forms (CRFs) and Case Report Tabulations (CRT)
associated with multiple Study Reports
505
Problems
• Computer system limitations
– A maximium of 256 characters can be used
• This is further limited by ICH to 230 characters to permit the
ICH regulatory agencies space for server and folders names
to organize the submission
• ICH guidance recommends that folder names not exceed 64
characters
– Computer Displays can not readily display lengthy
path and filenames.
• In many cases some filenames could be the same up to very
ending making it difficult for reviewers
506
File System Display - Shortcomings
507
File System Display - Shortcomings
508
Or even - for those who prefer the icon view
509
A Better Way to Display
510
• The ICH CTD recommends smaller granular files instead of single large files
encompassing all aspects of the study report
– Changes can be made to individual sections of the study
• Reviewers only need to concentrate on the changed portion
• Each section can result in the creation of one or more files containing
pertinent information
– Multiple Case Report Forms (CRFs) from multiple sites
– Multiple Case Report Datasets from multiple sites
511
Interim Fix
• Several proposals between July 2002 and
March 2003
– Including in the eCTD DTD
– Separate DTD with values included as
elements/attributes
– Separate DTD using the values as “tags” without
validation
• ICH agreement in July 2003 Brussels
– Use separate DTD with values as “tags” with deferred
validation by a stylesheet
512
Synopsis file
Report Body file
Protocols file Rat no-
intravenous
treatment
Case Report
-control
Form files
Data Tabulation
files
dose-response-
without- topical Rabbit
control
517
study-report-body
Synopsis file
Report Body file protocol-or-amendment
intravenous Protocols file
case-report-forms
CRF 1 Site 1 site 1
CRF n Site n
case-report-forms
Data File 1 site n
dose-response- Data File 2
without-
data-tabulation-dataset
control
data-tabulation-dataset
518
dose-response-
Mouse intravenous without-
control
case-report-forms data-tabulation-dataset
site 1
case-report-forms
data-tabulation-dataset
site n
519
Study Report Files and Study
Tagging File
Leaf B
Leaf
Synopsis.pdf A
Body of Report .pdf
Leaf C
Leaf
Protocol.pdf K
CRF.pdf
B
Leaf
O Leaf
CRF.pdf
N dataset.XPT
Leaf E Leaf
dataset.XPT Stf-study-report.xml
520
Workshop Sample
999999/
0000/
m5/
53-clin-study-report/
535-rep-effic-safety-study/
Claimed indication/
5351-study-report-contrib/
xxx394-90-04/
522
Workshop Sample
• Files in Study Report Folder
– XXX394-90-04synopsis.pdf
• ../../../../../../index.xml#ID350438
– XXX394-90-04body-of-report.pdf
• ../../../../../../index.xml#ID350438a
– XXX394-90-04protocol.pdf
• ../../../../../../index.xml#ID350438b
– CRF1site01.pdf
• ../../../../../../index.xml#ID820214
– CRFnsiten.pdf
• ../../../../../../index.xml#ID387525
– Dataset1.xpt
• ../../../../../../index.xml#ID246080
– Dataset2.xpt
• ../../../../../../index.xml#ID382213
523
Note: ../../../ means to use the relative location of the STF file
524
<doc-content >
<property name="leaf-id" info-type=”fda”>
../../../../../../index.xml#ID350438a
</property>
<file-tag name="study-report-body“
info-type=”ich-e3”/>
</doc-content>
527
<doc-content >
<property name="leaf-id" info-type=”fda”>
../../../../../../index.xml#ID820214
</property>
<property name=”site-identifier”
info-type=”fda”>1</property>
<file-tag name="case-report-forms“
info-type=”ich-e3”/>
</doc-content>
528
<doc-content >
<property name="leaf-id" info-type=”fda”>
../../../../../../index.xml#ID387525
</property>
<property name=”site-identifier”
info-type=”fda”>n</property>
<file-tag name="case-report-forms“
info-type=”ich-e3”/>
</doc-content>
529
<doc-content >
<property name="leaf-id" info-type=”fda”>
../../../../../../index.xml#ID246080
</property>
<file-tag name="analysis-dataset“
info-type=”ich-e3”/>
</doc-content>
</document>
</ectd:study>
530
Order of Display
• The Comprehensive Table of Contents
Headings and Hierarchy
– Non-clinical Study Reports
• 4.2.1.1 Primary pharmacodynamics
– Clinical Study Reports
• 5.3.1.1 Bioavailability (BA) Study reports
• http://www.fda.gov/cder/regulatory/ersr/ectd.htm
534
Clinical
Concept
Clinical Study Reports
Reports of Efficacy and Safety Studies
Study Reports of Controlled Clinical Studies Pertinent to Claimed
Indication
Controlled : type-of-control – placebo
doc-id xxx394-90-04 : title - A Parallel Group, Placebo-
Controlled, Modified Double-Blind, Dose-Ranging Study
with XXX 394 in Patients with SLE
Synopsis
synopsis – leaf-id ../../../../../../index.xml#ID350438
Note: the above is defined to mean group the study files under the
heading “Controlled” based on the value “placebo” of the type-of-
control tag. Show the value of the doc-id tag with the value of the title
tag from the STF XML file. Create the heading “Synopsis” based on
the synopsis tag. Display the title of the synopsis file as a hyper-link
using the title and xlink:href values in the index.xml pointed to by the
leaf-id tag value in the STF XML file.
535
Concept - 2
Study Report
study-report-body – leaf-id ../../../../../../index.xml#ID350438a
Protocol and amendments
protocol-or-amendment – leaf-id
../../../../../../index.xml#ID350438b
Documentation of Statistical Methods and Interim Analysis Plans
statistical-methods-interim-analysis-plan – leaf-id
../../../../../../index.xml#ID350438c
Demographic Data
demographic-data - leaf-id ../../../../../../index.xml#ID350438d
Adverse Event Listings
adverse-event-listings – leaf-id
../../../../../../index.xml#ID350438e
536
Concept - 3
Case Report Forms
Site : site-identifier – 01
Note: Use the value provided in the STF file for “01”
Could be any meaningful value to your client such as
Hawaii, X-123, London Site 15, etc.
Concept - 4
Data Tabulation
Data tabulation datasets
data-tabulation – leaf-id ../../../../../../index.xml#ID246080
data-tabulation – leaf-id ../../../../../../index.xml#ID382213
data-tabulation – leaf-id ../../../../../../index.xml#ID547320
data-tabulation – leaf-id ../../../../../../index.xml#ID521586
data-tabulation – leaf-id ../../../../../../index.xml#ID49242
Data Definitions
tabulation-definition leaf-id ../../../../../../index.xml#ID861459
538
Concept - 5
Analysis Datasets
Analysis Datasets
analysis – leaf-id <example for display>
analysis – leaf-id <example for display>
Analysis Programs
analysis-program – leaf-id <example for display>
analysis-program – leaf-id <example for display>
Data Definitions
analysis-definition – leaf-id <example for display>
Annotated CRF
annotated-CRF - leaf-id ../../../../../../index.xml#ID776509
SECTION 25
file://E:\dl\ectd-2-0.xsl 2/6/2007
Part 5
Training
SECTION 26
Presents…
INTRODUCTION .............................................................................................................1
Prerequisites ..................................................................................................................1
Sorting Datasets.........................................................................................................17
Review ........................................................................................................................25
MS Excel Conversion....................................................................................................29
MS Excel Features........................................................................................................32
MS Access Features......................................................................................................36
Review ........................................................................................................................39
Launch JMP.................................................................................................................42
Review ........................................................................................................................51
Subset .........................................................................................................................55
Search Command..........................................................................................................56
Distribution of Y ..........................................................................................................58
Exclude/Include............................................................................................................59
Fit Y by X....................................................................................................................62
LESSON 6 – SUPPORT................................................................................................71
Classes and Documentation ...........................................................................................72
OIT Support.................................................................................................................74
NEDAT provides the information necessary to get you started on reviewing electronic datasets.
The course includes instructions on how to access the data via the Electronic Document Room
(EDR) and convert the files to formats that can be used with a variety of software packages,
including MS Excel and Access. The course also offers an introduction in The SAS System
Viewer and JMP to open datasets and perform some basic data analyses. Instruction is provided
for exporting statistical information to other applications for Word processing and additional
analytical review.
The NEDAT program does not end with in-class instruction. The final lesson includes support
options for reviewers who have taken the class, but require access to additional technical support.
NEDAT incorporates the use of an extensive classroom manual, desktop reference guides, and
software online guides for on-hand desktop support. The course also instructs reviewers how to
access support via OIT and peers within the Center and provides a glossary of NEDAT terms.
Prerequisites
Before beginning these lessons, you should have a working knowledge of Windows 95 and its
conventions. In particular, you should know how to do the following:
For help with any of these techniques, please see your Windows 95 documentation or the CDER
OIT Help Desk. Classes in Windows 95 are offered by OIT.
• 12 MB RAM
• 16 MB RAM
Slide 2 ____________________________
NEDAT Overview
____________________________
❚ Review of “Providing Regulatory
Submissions in Electronic Format - NDAs” ____________________________
Guidance
❚ SAS Transport ____________________________
❚ Blueprint of Guidance
____________________________
❚ NEDAT Objectives
____________________________
____________________________
____________________________
_____________________
❚ Data analysis
____________________________
❚ Publicly available information is on the ____________________________
Internet
____________________________
____________________________
_____________________
Slide 4 ____________________________
SAS Transport File (STX)
____________________________
❚ Flexible format - compatible with multiple ____________________________
formats (SAS, JMP, Access, etc.)
❚ Archivable ____________________________
❚ defacto Standard
❚ Free viewer (The SAS System Viewer) ____________________________
❚ User-friendly navigation
____________________________
____________________________
____________________________
_____________________
Slide 5 ____________________________
NDA Discipline Folder:
____________________________
____________________________
____________________________
____________________________
____________________________
____________________________
____________________________
_____________________
Slide 7 ____________________________
Each Study Folder Contains:
____________________________
____________________________
____________________________
____________________________
____________________________
____________________________
____________________________
_____________________
Import in JMP
____________________________
Stat/Transfer
Access/Excel ____________________________
Other
____________________________
____________________________
_____________________
Slide 10 ____________________________
NEDAT Objectives
____________________________
❚ NDAs accessed via EDR
____________________________
❚ The SAS System Viewer to open, navigate,
sort, and search SAS Transport files
____________________________
❚ Use Stat/Transfer to convert files to MS Excel
and Access
____________________________
❚ JMP to import, navigate, search, and perform
basic statistical analysis
____________________________
❚ Support Options
____________________________
____________________________
_____________________
Slide 11 ____________________________
NDA Electronic Data Analysis
Training (NEDAT) ____________________________
____________________________
Let’s begin the NDA
Electronic Data ____________________________
Analysis Training.…..
____________________________
____________________________
____________________________
____________________________
_____________________
Windows 95 file management tools, Microsoft’s Internet Explorer, Adobe Acrobat, and The SAS
System Viewer are used to complete the tasks in this chapter.
! In the NDA Quick Search field, remove the 0, enter the sample classroom NDA number,
123456 (Actual NDAs begin with 0) and press the Search button
Address
Field
NDA Search
If the NDA number is valid, the NDA Application #, Trade Name, and Company Name will
appear for each submission. Type, Sequence #, Sup. Mod. Type, Stamp Date, Application Drive
Path (location on the network), and Comments will appear for the NDA and any associated
Amendments or Supplements. Note the sample NDA drive path
(\\cds006\samplenda\n123456), as it will be used in the next section.
NDA
Amendment
To access and display the contents of the main NDA folder, click on Select to view Document
for the respective NDA, Amendment or Supplement. The next window will display a list of
folders and files contained in the electronic NDA.
Submission
Contents
Submission
Location
! Double-click the crt folder. The datasets are contained in the folder datasets.
In the datasets folder, there is a file datatoc.pdf. This file is a table of contents for all of the data
in the crt folder. To access the dataset table of the contents, double-click directly on the
datatoc.pdf file in the EDR window.
! To access these files, click on the Study 09 link in datatoc.pdf. This link points to a file,
define.pdf, in the Study 09 folder that file contains a list of all the datasets in the study.
The first page of the file is the table of contents. Links are established in the table that will
allow you to open the file or the data definition table for each dataset by clicking on the
corresponding links.
Lab1.xpt link
Adobe Acrobat will prompt you to confirm that The SAS System Viewer will launch when you
click on this link.
! Click the Yes button to open the dataset. If you do not receive this message, perform the
steps listed in Associating File Types.
Associating Files
Windows 95 gives you the ability to launch applications by opening an associated file from one
of the Windows file management screens. In order to perform this, Windows 95 must have a
relationship, or association, established between a file type and an application. For example,
after installing MS Word, Windows is setup to open Word by clicking on any file that ends in a
.DOC extension.
If you click on a file and are prompted by Win95 with an Open With window, then the
association of that file type with an application has not been setup in Windows. If this situation
happens after installing The SAS System Viewer, perform the following procedure:
Note: Not all file types can be associated. Make sure you are using the correct software before
performing these steps
• Click on The SAS System Viewer icon, labeled SV, from the list of programs
• If the icon does not appear, click the Other button and navigate to C\:PROGRAM
FILES\SAS SYSTEM VIEWER\SV.EXE
• Click the OK button. The SAS System Viewer This will open automatically when you click
on an associated file
• Double-click My Computer
• On the View menu, click Options, and then click the File Types tab
• To create a new file type, click New Type. To modify the settings for an existing file
type, click the type, and then click Edit
• Specify a description for the file type and the filename extension associated with this
type of file
• Click New to define an action for this file type. If you are modifying an existing type,
you can click the command in the Action box that you want to modify, and then click
Edit
• Specify the action that you want to define, such as Open or Print, and the command that
should run to complete this action
• Repeat the previous two steps for as many actions as you want to define for this file type
Once the file type .XPT has been associated with The SAS System Viewer, you can proceed to
the next section of this lesson
The SAS System Viewer has the following capabilities (NEDAT topics in bold):
• View SAS Datasets • Create new SAS program and text files
1
From Microsoft Windows 95 Help Topics Menu (Start | Help)
• Under the training section, go to the course catalog and click on the NEDAT link
• A page will appear listing the software packages incorporated with NEDAT training. Under
The SAS System Viewer, click the Click Here link and follow the onscreen instructions to
install the software.
Installation
Link
CDER Note: Contact the Help Desk if you experience difficulty in downloading the software
The SAS System Viewer is a Windows based application. The features from the software can be
accessed via the pulldown menu at the top of the screen. Shortcut buttons to common pulldown
menu features are also available on the Toolbar.
Row
Numbers
! If you have not opened define.pdf as of yet, go to File | Open and navigate to the
Z:\N123456\CRT\DATASETS\09 folder
Note: The SAS System Viewer has the ability to open several different dataset types. Consult
the software's Help for a complete listing.
When the lab1.xpt file was clicked, the file opens in the main window. The column headings,
row numbers, and cells appear within the window. Note that the column headers, or variables,
are completely defined. To view the variable name:
The variable names now appear in the column header. Set this Label view to your preference.
Action Result
← or → keys Move one cell left/right
↑ or ↓ keys Move one cell up/down
[CTRL] + ← or [CTRL] + → Move to beginning/end of row
[CTRL] + ↑ or [CTRL] + ↓ Move to beginning/end of column
[CTRL] + [Home] or [CTRL] + [End] Move to first/last cell in Dataset
[Page Up] or [Page Down] Scroll up/down one screen
Consecutive rows can be selected by clicking on a row number, holding down the mouse button
and dragging up/down. Let go of the mouse to finish selecting rows. Non-consecutive rows can
be selected by clicking on a row number, holding down [CTRL], and clicking on another row
number. Use [SHIFT] in the same manner to select a series of rows.
Selected Row
Non- Series
consecutive
Use the same functions to select consecutive, non-consecutive, or a series of columns. Selecting
all of the rows or columns will select all of the cells in the dataset. You can also click the button
above the row numbers/left of the column headers or go to Edit | Select All on the
pulldown menu to select the entire table.
Sorting Datasets
These datasets can be sorted alphabetically in ascending or descending order. To sort by
column:
Selected
Column
Sort
Ascending
The Boolean expression is WHERE. The variable is Age, followed by the mathematical formula.
The above example will display all rows that contain a value above 50 in the Age column.
Query
Results
! Click OK
CDER Note: Consult the Help feature on the pulldown menu for additional information on
Query Language, toolbars, and toolbar options in present and future releases of the software.
! Enter the text you wish to find. Look for patient 0290029043
The SAS System Viewer will find the next instance for patient 0290029043. To search for the
next instance of the patient ID number, click the Find button again.
Before these files can be accessed from StatTransfer, a path must be saved to the shared area
found via the EDR.
! Select Z as the Drive letter and enter \\cds006\samplenda in the Path: field
! Make sure the Reconnect at logon box is not checked (You may wish to check the
box in order to repeat this process with every logon to your Office PC)
! Click the OK button (you should now be mapped to the Sample shared area)
Once you have mapped to the network drive, a window will open displaying the contents of the
shared area. Double-click on the N123456 folder to reveal the contents of our sample NDA.
Sample NDA
Window
As you can see, this window is identical to the EDR. You can now access these files within your
Windows 95 applications. You can also copy specific files or folders related to your discipline
directly to your PC.
! Choose Properties on the pulldown menu. Note the free disk space on the C: drive and
click OK.
Free Disk
Space
Used Space
Free Space
File Size
If the size of the file you are copying is less than the space available on your C: drive, continue
to the next step. If the file is larger, you will not be able to copy the file to your C: drive.
! Click OK
CDER Note: It is recommended that you always keep at least 50mb available space on your
hard drive for optimum PC performance.
! Move your pointer onto the desktop and right-click. A pulldown menu will appear.
File
Copy
! To finish this lesson, close My Computer, any shortcut windows, The SAS System
Viewer, Adobe Acrobat , and MS Internet Explorer.
NOTE: These directions for copying files apply to Amendments and Supplements as well.
Make sure when creating a shortcut or copying a folder to note on your desktop whether that
shortcut points to an Amendment, Supplement, or NDA.
The following lesson will cover using StatTransfer to convert the SAS Transport files to file
types compatible with MS Excel, and MS Access. To test your knowledge of the topics covered
in lesson 1, answer the following questions:
• How do you find the location of and NDA or Review using the EDR?
• What is the name of the table of contents file for the crt folder?
• How much available hard drive space is recommended for optimum PC performance?
• About StatTransfer
NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools 27
About StatTransfer V5
Data created by one program may be needed for analysis within another application. Not only
must the data be transferred, but any supplemental information, such as variable names, missing
values and variable labels must also remain associated with the data in proper format.
StatTransfer is a Windows based tool that allows fast, reliable conversion of data among multiple
formats.
Using a Windows interface, StatTransfer automatically reads data from one program and
transfers the data to the internal format of another supported application. StatTransfer supports
the following formats (NEDAT formats in bold):
• 1-2-3 • ODBC
• Access • OSIRIS
• FoxPro • S-Plus
• LIMDEP • Stata
• Mineset • Statistica
• Minitab • SYSTAT
Consult the HELP button on the Transfer tab in StatTransfer for additional information.
CDER Note: Contact your Focal Point for a licensed StatTransfer installation.
Launching StatTransfer
Electronic NDA datasets arrive in SAS Transport (.xpt) format. The format was chosen based on
the ability to archive and the format’s flexibility. Somest statistical/spreadsheet programs are not
able to open these datasets in their native format. Therefore, StatTransfer must be used to
convert the .xpt files to formats used by some data analysis programs.
28 NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools
To Launch StatTransfer:
Output File
Transfer Type
Button
If you want to select only some of the variables in the input dataset, click on the Variables tab at
the top of the Transfer dialog box. You will be able to select/deselect the variables before
performing the conversion. The Observation tab feature will allow you to select specific
records and cases from your input dataset.
After you have achieved a familiarity with data conversion, you may find the need to change
some of the Options with StatTransfer. The Options dialog box gives you access to changing
the advanced formatting options within the software. Basic Information about the software can
be found in the About dialog box.
Consult the HELP button in the Transfer dialog box for additional information.
MS Excel Conversion
As stated, SAS Transport files are not readily compatible with statistical software used within the
Center. Use StatTransfer to convert these files to formats conducive with Center software.
NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools 29
1. Choose the Input file type and location:
! Use the pulldown arrow in the Input File Type: field to choose the SAS
Transport File option
! Click OK
When the input file has been selected, a message, the Variable Selection Indicator, will appear
displaying that all of the variables in the dataset have been selected.
! In the Output File Type: field, use the pulldown arrow to select the first format
discussed, Excel
! Click the Browse button next to the File Specification: field and navigate to the
folder C:\CLASSES\NEDAT\DATASETS
SAS XPT
Input
Excel Output
Transfer
Button
! Click the Transfer button. (If you need to stop the conversion, the Transfer button is
now labeled Stop. Press the button if you wish to halt the transfer)
30 NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools
! Once the conversion is complete, click the OK button to complete the transfer. The total
number of transferred cases will appear at the bottom of the Transfer dialog box.
MS Excel can now be used to analyze the newly created SAS Dataset.
The MS Excel window is similar to The SAS System Viewer window. There is a pulldown
menu at the top of the screen, with several toolbar options available.
Pulldown Toolbars
Menu
Row Variables
Numbers
Several noticeable differences exist between the MS Excel and The SAS System Viewer
windows. The Variables that were the Column Headers in The SAS System Viewer have been
NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools 31
converted to cells. Also, there is a Formula bar that allows new data entry and formula
calculations.
MS Excel Features
While The SAS System Viewer allows for basic sorting and text searches, Microsoft Excel has
the capabilities to perform the following advanced features (NEDAT in bold):
In order to sample the one of the power analytical tools in MS Excel, perform a quick graphing
of the newly converted data.
Using the Excel graphing features, compare the lab values at baseline and after drug for the first
patient, 0290019584:
! Hold down the mouse and drag down to the last LABCODE value for the patient (row 13 -
SERUM SODIUM)
Selected
Values
! Hold down [CTRL] and select all the lab values (LVALUE column) for the patient
32 NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools
! Since the values were selected, click the Next button three consecutive times until you get to
the last Chart Wizard window
! Since some of the text in the LABCODE column is large, check the As new sheet button to
create a new worksheet with the table
! Click Finish
A new worksheet has been created that shows the baseline value of the lab next to the value after
treatment. As the chart illustrates, there was a slight increase in chloride and a slight decrease in
sodium.
This exercise is a basic example of the charting tools available in MS Excel. Consult the Help
option on the pulldown menu for specific information about these analytical, and additional,
features available in MS Excel.
CDER note: OIT offers an Introduction to Microsoft Excel course. Consult the OIT Home
page (HTTP://OITWEB/OIT) for dates and registration.
While MS Excel offers these advanced analytical features, you may have a need to perform
advanced relational queries and reports. MS Office also have a relational database application,
MS Access, that is compatible with SAS Transport files and Stat Transfer.
NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools 33
! On the Win95 taskbar, click on the Stat Transfer button
! Click the Reset Button at the bottom of the Stat Transfer window
! Make sure to choose Access 95-97 in the Output File Type field
! Repeat the previous conversion steps, this time converting the file
Z:\N123456\CRT\DATASETS\09\DEMOG.xpt
After converting the second table, click the Exit button on StatTransfer.
To open MS Access:
34 NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools
! Make sure the Open an Existing Database radio button is checked and choose the
More Files… option
The datasets we converted are now displayed as icons in the Tables tab of MS Access. To
open a table, double-click the lab1_jmp icon on the Tables tab.
Pulldown
Menu
Variables
Toolbar
As you can see, MS Access maintains the variables as column headings. The Access table is
similar to the Excel Spreadsheet and the two applications share many of the same toolbar
functions.
NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools 35
MS Access Features
When you close the Access table, you will be taken back to the main Access window. From
here, you can access the features of MS Access by clicking on the related tab. Click on the
Queries tab in the MS Access window.
Tab Options
Tables
Similar to the data we have been viewing in The SAS System Viewer and MS Excel, the table
feature is used to provide the data used in the additional MS Access Features.
Queries
Like to SQL string in The SAS System Viewer, queries are used to view, change, and analyze
data in various formats. You can also use them as the source of data for Forms and Reports.
Forms
A form is a customized, visual interface that allows you to access/add to your data in a variety of
ways.
Reports
A report is an effective way to customize the appearance of your data in a your desired output
format (e.g., printed.) Because you have control over the layout of a report, you can tailor the
information specific to your discipline.
In order to sample one of the powerful relational tools available within MS Access; let's take a
look at a sample Query that was previously created, lab1.mdb.
Use the query functions of Access to find any lab values above 140. Display the patient's age,
sex, race and patient ID number:
36 NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools
! Click on the Lab value vs race query that has been created
DEMOG_JM Lab1_JMP
variables variable
The query was set up to first sort the DEMOG_JM table by the PTID, AGE, SEX, and RACE
variables. However, the LVALUE was listed in the LAB1_JMP table. Because the variable
PTID was constant in both tables, the query was able to join the two tables at that variable and
query the last field from the LAB1_JMP table in order to display all LVALUES that are above
144.
Consult the Help feature on the pulldown menu to learn more about Macros, Modules as well as
all additional features of MS Access.
CDER note: OIT offers several introductory and advanced tables and reports classes in MS
Access. See the OIT Home page (HTTP://OITWEB/OIT) for dates and registration
information.
NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools 37
Review
In the previous lesson, we learned how to perform sorting and query functions on datasets using
The SAS System Viewer. This lesson explored how to convert SAS Transport files using
StatTransfer to MS Excel and Access to perform advanced analysis and queries. The next lesson
will cover using an advanced, but user friendly software package, JMP, to consolidate all of the
functions discussed in the three applications covered in the previous two sections.
To test your knowledge of the concepts and techniques you learned in this lesson, answer the
following questions:
• In the Open window of StatTransfer, what field do I need to change to open a SAS
Transport file?
• What is a Variable?
• Can I open the SAS Transport files located on the network to perform my analysis?
NDA Electronic Data Analysis Training – Lesson 3: Conversion and Analysis Tools 39
Lesson 4 – JMP Features
In this lesson, you’ll learn how to do the following:
• Launch JMP
• tools for moving analysis results between applications and for printing
This lesson is an introduction to JMP. Basic JMP navigation, cell selection, and column and row
manipulations is covered. The next lesson will demonstrate how JMP can be used to review data
in much the same way one would use a paper or PDF Case Report Tabulation. In addition,
powerful data manipulation and analysis tools available in JMP will be examined.
CDER note: Contact your Focal Point for JMP license and installation.
Launch JMP
When JMP is installed on your PC, a shortcut to the software can be found in the Programs
section of the Start menu.
To launch JMP:
You may also wish to side step this procedure in the future by creating a desktop shortcut to
JMP.
Either one of these option swill launch JMP and take you to the main JMP screen.
Pulldown Toolbar
Menu
Rows Columns
! Because the .xpt file extension is new, some software versions may not immediately
recognize the file extension. Change the Files of type: field in the bottom left hand corner of
the import window to All Files (*.*)
! Click Open
Cursor
Forms
Scroll Bars
Action Result
← or → keys Move one cell left/right
↑ or ↓ keys Move one cell up/down
[CTRL] + ← or [CTRL] + → Move to beginning/end of visible row
[CTRL] + ↑ or [CTRL] + ↓ Move to beginning/end of visible column
[Home] or [End] Move to first/last cell in dataset
[Page Up] or [Page Down] Scroll up/down one screen
Cursor Forms
Cursor forms are present and can be selected to do the following functions:
arrow - the default cursor form, present when you hover over the deselect areas in the
upper left hand corner or when hovering over the data modeling type box in the column header
cross - when over a column header or a data cell, the cross indicates the ability to select text.
When you click on the cross cursor, the text highlights and can be edited. The cursor then
becomes an I-beam.
I-beam - this is a vertical blinking bar which allows you to edit text in a column header or
data cell
open cross - is present when you move into a column or row selection area. Use the open
cross to select a single row or column. Double-click, using the open cross in the column header
to get additional column information.
Selecting Cells
Before performing any action, you will first need to select the cells involved in the action. As we
have already seen, clicking once on a cell selects that active cell. To select an entire row, click
on the row number. The row number will be highlighted. Click a Column Header to select an
entire column.
Consecutive rows can be selected by clicking on a row number, holding down the mouse button
and dragging up/down. Let go of the mouse to finish selecting rows. Non-consecutive rows can
Deselect
Area
Non-
consecutive
Use the same functions to select consecutive, non-consecutive, and a series of columns.
Selecting all of the rows or columns will select all of the cells in the Dataset. You can also click
the button above the row numbers/left of the column headers or go to Edit | Select All on
the pulldown menu to select the entire table.
Deselecting Cells
To deselect columns, click in the Columns detail area in the top left corner of the dataset. To
deselect rows, click in the Rows detail area in the top left corner of the dataset.
! Highlight PTID
You may also choose a different Move option from the Cols pulldown menu. Repeat the steps to
move the column back
To hide a column:
Those columns now disappear from the table. To view the columns again:
! Click OK
Column
Name
Data Source
Data Type
Notes
Modeling
Type
Field Content
Col Name Contains the column name
Validation set up a table of acceptable values
Data Type Choose numeric or character
Modeling Type Choose Continuous (numbers), Ordinal
(characters or numbers that have an order), or
Nominal (characters or numbers with discrete
values)
Data Source Choose Formula or No Formula
Notes Variable label
To Save:
To test your knowledge of the concepts and techniques you learned in this lesson, answer the
following questions:
• Can JMP view the SAS Transport NDA data files located on the network?
• Subset Command
• Search Command
• Group Summary
• Distribution of Y
• Exclude/Include
• Fit Y by X
Exercise 1: Use the sort command to sort the table by age and sex, in ascending order.
! Click Add
Variables
Ascending/D
escending
Sort By:
variables
You can also sort in ascending/descending sort by clicking on . Add the variables
in order, as procedures in the lesson are order sensitive!
! Click OK
Subset
Use the Subset command if you wish to pull selected records into a separate, but linked table.
Subset
Variable
Only those highlighted serum sodium rows and columns appear in the new table.
Search Command
The Search command is used to find and replace text. This command allows you to search for a
series of words in a character column, or locate strings with unwanted leading or trailing blanks.
Find what:
field
Replace
features
Find features
The first instance of the text, 0000000, is highlighted in the table. To search again, repeat this
process. The Find what: field will automatically contain the previous entered text.
Find Features:
Match whole words only: locates words with at least one leading and one trailing blank
Search by row and Search by column: determine whether the search is performed along rows
or columns.
Exercise 5: Use the Group/Summary command to find the number of tests per lab test
category.
! Click OK
Stats
functions
Variables
Subgroup
The new table shows the lab test categories, as well as the number of rows (tests) for each
category.
You can also group by more than one variable, sub group, and add columns of descriptive
statistics to the summary table for any numeric column in the source table. When selecting
multiple variables, make sure to add them in the same order you wish the variables to appear in
the table.
Exercise 6: Use Group/Summary to find the mean lab value for each test, grouped by
treatment assignment, and subgrouped by study period (baseline vs. treatment).
! Select LVALUE
! Select PHASE
! Click OK
The new summary table lists the mean lab values by treatment group, and is subgrouped by study
period. Take note that in the last few rows, the table displays how the drug affects the serum
sodium Values! Save this table, as it will be used later in this lesson:
! Leave the table open and display the original table by going to Window | LAB1_JMP.
Distribution of Y
The Distribution of Y function is used to provide a partitioning of values with histograms, as
well as other graphic and text reports.
! Click OK
2. Highlight the serum sodium row in the newly created summary table
Selected Row
! Go to Window | LAB1_JMP
! Click on the right square above the variable name LVALUE in the column header
LVALUE
column
5. On the pulldown menu, select Analyze | Distribution of Y (you can also click
on the toolbar)
The histogram, box plot, quintiles, and statistical moments are displayed. The display can be
altered by clicking on the “check” mark that brings up a menu in the lower left of the window.
The graph may not provide the necessary information because the tables used combines baseline
and post treatment values. You will want to exclude all baseline values before performing a
Distribution of Y.
! Return to our serum sodium table (Untitled2) to complete the next task.
Exclude/Include
The Exclude/Include feature allows you to exclude certain rows from statistical analysis.
! Click OK
LVALUE
rows
The excluded rows are marked with . Data will remain excluded until Exclude/Include
is chosen again.
3. Distribute by Y
The chart now excludes the baseline values from the analysis.
Exercise 8: Use the JMP Calculator to find the change from baseline for each lab value.
! In the Data Source: field select Formula from the drop down selection box
Column
Selector List
Formula
Display Area
Keypad
The CHANGE column now displays the change from baseline for each lab value.
Fit Y by X
This function allows the use of statistical tests such as chi-square, T-tests, and ANOVA.
Exercise 9: Use the Fit by X feature of JMP to find if there is a statistically significant
difference in post-treatment serum sodium values across treatment groups.
! Make sure that the data modeling type for TRT is Ordinal and LVALUE is Continuous
Modeling
Types
! Click OK
! Highlight the row where LABCODE is equal to Serum Sodium and PHASE is 1 (this is a
second way to select out post-treatment serum sodium values, The first way was covered in
the distribution of Y - Include/Exclude)
! Go to Window | LAB1_JMP
A new table is created that contains all the rows where LABCODE is equal to Serum Sodium and
PHASE is 1
3. Fit Y by X
Since we have not yet designated our X and Y axis, a JMP window appears asking for the X and
Y columns. We need to designate TRT as X and the LVALUE variable as Y:
! Click X button
! Click OK
Analysis P value
Options
The conclusion is that there is a statistically significant difference in serum sodium values among
the 3 treatment groups.
Let’s go back to the table, labmeans.jmp, saved for serum sodium values.
! Place your cursor over the first cell in the table. Make sure open cross, , is displayed
(click deselect columns/rows if necessary.)
! Click, hold down on the mouse, and drag down to the right over all cells so the selection box
covers all of the cells. All of the column and rows are highlighted.
Selection
Selected Box
Row/Columns
You can now use Excel to enhance the look of the data, or perform additional analysis or
graphing. In order to move to the next Topic, close Excel and do not save any changes.
In additional to pasting the cells of a dataset into Excel, graphics and data can also be exported
into MS Word.
Exercise 11: Copy the scatter plots (Fit y by X) paste the chart into Word.
! Place the cursor at the open end of the scissors on any corner on the chart
Selection
Box
You may wish the chart just pasted into Word to not float over the text. In order to perform this
function, you can use the Paste Special feature in Word:
! Choose Picture from the As: field and uncheck the Float over text box. This will prevent the
picture from floating over the text on the page (you may also use additional Word picture
formatting procedures.)
Although the image looks the same, it will be placed within the text and features such as
justification, tables, etc. can be used to align the graphic.
In addition to the chart, there are several tables located on the JMP window. These tables can be
copied and pasted as graphics in the same manner as the chart. However, since JMP recognizes
the text in these tables, the data can also be copied as text.
Exercise 12: Copy and paste the Analysis of Variance table from JMP to Word.
! Make sure the Scissors tool is selected. Click and drag a box over the Analysis of Variance
table
The text has been pasted into word with tab delimitation separating the columns.
You can use Word formatting and table skills to convert the text, as long as the tab separations
are proportionate, to a table.
You are now ready to write your report and finish for the day!
The next lesson will discuss additional Support for NDA Electronic Data Analysis, from manuals
to OIT support.
To test your knowledge of the concepts and techniques you learned in this lesson, answer the
following questions:
• Where on the pulldown menu do you find the Distribution of Y and Fit Y by X
commands?
• What type of data source in the New Columns window will launch the JMP Calculator?
• What tool is used to rule out the baseline from statistical analysis?
It is likely that a person who can find an answer to their question on their own will not have
that same question again. This lesson covers how to find answers when to access additional
technical and peer support.
This short lesson will instruct you how to access the following types of support in the Center:
• Additional Training
• Help Menu
• OIT Support
• Peer Support
The NDA Electronic Data Analysis Training (NEDAT) class offered by OIT is dependent upon
you to make constructive insights and comments on the course. Please make sure to fill out and
return the OIT Course Evaluations at the end of class. These evaluations will help us shape the
class so it is most beneficial to review staff.
The NEDAT manual can be found on the OIT Web (HTTP://OITWEB/OIT) under the
Documentation/ Applications Training section. Those attending the NEDAT
training have also been asked to bring a formatted, 3 ½” floppy disk to class. PDF copies of the
NEDAT manual and ERSR guidance can be copied to a floppy disk.
! Double-click on My Computer
! Hold [CTRL] down and click on both the nedat.pdf and the 2353dft.pdf files. Both files
should be highlighted.
! Once the files are done being copied, remove the floppy disk
Quick reference desktop trifolds for JMP and NEDAT have been provided in class. Use these
trifolds for answers to frequently asked questions. Additional trifolds for other OIT courses can
be found via the OIT Help Desk.
Additional Training
The following Advanced NEDAT Software courses are currently available, or are being
formulated, within the Center.
OIT offers introductory courses or tutorials for each. Consult the OIT web
(HTTP://OITWEB/OIT) under the Training Schedules area for documentation and class
schedules.
MS Word
OIT Offers Introductory, Formatting, and MS Word Tables Classes. Consult the OIT Web site
for details.
Adobe Acrobat
OIT offers introductory courses, as well as NEST, which incorporates the use of Acrobat in the
Electronic Review process. Consult the OIT Web site for details.
JMP
Medical Officers are currently offering advanced NEDAT courses in JMP per discipline.
Contact Randy Levin (LEVINR), Associate Director for Electronic Review, ORM for details on
attending, or instructing advanced JMP courses.
NEST covers how to search for a specific Electronic NDA. Adobe Acrobat is then used to open,
navigate, view, follow links, create electronic notes, and copy and paste text and graphics into
MS Word. Consult the OIT Web site for details.
OIT offers introductory courses on Excel and Access, as well as advanced query and report
writing courses for Access. OIT and ERSR management are currently formulating advanced
NEDAT courses for both software packages. Contact Randy Levin (LEVINR), Associate
Director for Electronic Review, ORM is you are interesting in attending, or assisting in the
creation of NEDAT Excel ands Access courses.
OIT Support
If you are unable to find the answers you need via class instruction, manuals, or the Online
Guides, please call the Help Desk at X7-0911 or e-mail them at HELPDESK. Please indicate
whether your problem is related to an application or Electronic Submissions feature. Questions
related to MS Windows, MSIE, Adobe Acrobat, The SAS System Viewer, StatTransfer, MS
Excel, MS Access, JMP, and MS Word can be answered by the Help Desk or visited by OIT
Desktop Support. Questions related to Electronic Submissions (missing folders, files, etc.) are
forwarded directly to OIT Level II Support.
Peer Support
Some of the best resources for learning are those who work with us every day. Those of you who
have taken the NEDAT course and have a firm grasp of the Electronic Data Analysis process can
help share your expertise with others by acting as a mentor to those seeking information and
feedback to their ERSR related situations. Also, if you have an interest in contributing to the
additional Excel, Access, and JMP NEDAT courses, contact Randy Levin (LEVINR), Associate
Director for Electronic Review, ORM.
Look for a more formalized Peer Support system as more Center staff become familiar with
NEDAT and ERSR regulations.
Thank you for your participation and please take advantage of all support options available in the
Center.
Presents…
INTRODUCTION ..........................................................................................................................I
Prerequisites.................................................................................................................................. i
Conventions .................................................................................................................................. i
Review ....................................................................................................................................... 15
Following A Link....................................................................................................................... 19
Compare Word........................................................................................................................... 19
Using Bookmarks....................................................................................................................... 22
Review ....................................................................................................................................... 31
CHAPTER 4 – ELECTRONIC REVIEW TOOLS.................................................................. 33
Annotations ................................................................................................................................ 34
Delete, Change Preferences For, Or Change Individual Properties For Notes And Markup
Annotations: ............................................................................................................................... 37
Review ....................................................................................................................................... 45
Peer Support............................................................................................................................... 49
NDA Electronic Submissions Training (NEST) covers how to search for a specific NDA via the
Electronic Document Room (EDR) Intranet site as well as map the drive path of the folder using
Windows 95 (mapping). Adobe Acrobat is then used to open, navigate, view, follow links, create
electronic annotations, mark text, and copy and paste text, tables, and graphics into other
applications from a sample electronic NDA.
The NEST program does not end with in-class instruction. The final chapter includes support
options for reviewers who have taken the NEST class, but require access to additional technical
support. NEST incorporates the use of an extensive classroom manual, desktop reference guides,
and the online guides for on-hand desktop support and also instructs reviewers how to access
support via OIT and peers within the Center.
Prerequisites
Before beginning these chapters you should have a working knowledge of Windows 95 and its
conventions. In particular, you should know how to do the following:
For help with any of these techniques, please see your Windows 95 documentation or the CDER
OIT Help Desk. Classes in Windows 95 are offered by OIT.
Conventions
Variables and commands are in the courier new font. Each topic includes an exercise in
bold. Answers to the exercises can be found in the Appendix at the end of the manual.
Slide 2 _______________________________
NEST Overview
_______________________________
❚ Review of “Providing Regulatory
Submissions in Electronic Format - NDAs” _______________________________
❚ Review of Portable Document Format (PDF) _______________________________
❚ Blueprint of Guidance _______________________________
❚ NEST Objectives
_______________________________
_______________________________
____________________________
Slide 3 _______________________________
CDER’s ERSR Goals for 2002
_______________________________
❚ All submissions can be received and
archived electronically _______________________________
❚ All electronic submissions, reviews, and
other related information can be accessed _______________________________
by the reviewer through a desktop
computer _______________________________
❚ Data analysis
❚ Publicly available information is on the
Internet
_______________________________
_______________________________
____________________________
Slide 9 _______________________________
NEST Objectives
_______________________________
❚ NDAs exist on network
❚ NDAs accessed via Electronic Document _______________________________
Room (EDR)
❚ Map to NDA network area _______________________________
❚ Learn how to copy NDAs to hard drive
❚ Adobe Acrobat Exchange used to open, _______________________________
navigate, note, search, link and copy and
paste from NDA review files _______________________________
_______________________________
____________________________
Windows 95 file management tools and Microsoft’s Internet Explorer are used to complete the
tasks in this chapter.
• In the NDA Quick Search field enter the NDA number and press the Search button
Quick Search
Field
If the NDA number is valid, the NDA Application #, Trade Name, and Company Name will
appear for each submission. Type, Sequence #, Sup. Mod. Type, Stamp Date, Application Drive
Path (location on the network), and Comments will appear for the NDA and any associated
Amendments or Supplements.
NOTE: NDA, Amendment, and Supplement folders may look identical on the network. Use the
EDR to distinguish between the two.
Amendment
To access and display the contents of the main NDA folder, click on Click here for the respective
NDA, Amendment or Supplement. The next window displays a list of folders and files contained
in the electronic NDA. To view these read-only, electronic submission files, click on the PDF
icon or folder. When a PDF icon is clicked, Adobe Acrobat will launch and open the PDF file.
Proceed to Chapter 3 to learn how to use Adobe Acrobat to work with electronic submission
files.
Submission
Contents
Submission
Location
Note the NDA drive path, as it will be used in the next section.
Exercise 2-2: Display the Sample NDA 123456 from the Search Results window in
the EDR.
• Enter the path to the NDA you found in the EDR (e.g., \\cds006\samplenda) in the
Path: field
• Check the Reconnect at logon box if you want to repeat this process every time you
log onto the network from this PC
• Click the OK button (you should now be mapped to the NDA shared area)
Exercise 2-3: Map the drive letter Z: to sample NDA 123456 and DO NOT
reconnect at logon.
• Lift your finger off of the mouse. A pulldown menu will appear.
Create
Shortcut
NDA
Folder
• To change the desktop shortcut label, right-click the shortcut and choose Rename. If you
are creating a shortcut to an Amendment or Supplement, make sure to include this
information when renaming the shortcut
Exercise 2-4: Create a desktop shortcut to the folder for sample NDA 123456 and
close the Samplenda on 'Cds006' (Z:) window
• Choose Properties on the pulldown menu. Note the free disk space on the C: drive and
click OK.
Used Space
Free Space
• If the size of the folder you are copying is less than the space available on your C: drive,
continue to the next step. If the folder is larger, you will not be able to copy the folder to
your C: drive.
Folder Size
• Click OK
NOTE: It is recommended that you always keep at least 50mb available space on your hard drive
for optimum PC performance.
• Move your pointer onto the desktop and right-click. A pulldown menu will appear.
Folder
Folder Copy
Exercise 2-5: Check the size of the N123456\CMC folder and copy it to your
desktop. Close all open windows when complete.
• How do you find the location of and NDA or Review using the EDR?
• How can I tell the difference between an NDA and an Amendment or Supplement?
• How much available hard drive space is recommended for optimum PC performance?
• Access the NDA via the EDR or map to the NDA shared area
A. Navigation Pane button B. Magnification level C. Magnification pop-up menu D. First Page button E. Previous
Page button F. Current page G. Next Page button H. Last Page button I. Page size J. Page Layout pop-up menu
Following A Link
The NDA table of contents contains links to a table of contents file for each main NDA folder.
These links make it easy for you to locate review data by discipline and navigate through the
document.
• Click the hand tool ( ) and move the pointer over the desired section in the table of
contents. The pointer changes to a pointing finger icon (shown below), indicating that you are
positioned over a link.
• Click to jump to the link destination — the table of contents for that discipline.
Exercise 3-1: Open the table of contents for NDA 123456 and go to the Labeling
table of contents.
Compare Word
The Compare Word command compares the text content of text on corresponding pages in two
documents. Differences are identified by:
• If text does not match on the two pages, the text is highlighted on both pages.
• If text is found on only one of the pages, the text is highlighted on that page, and a triangle
marks the place on the corresponding page.
• On the menu bar, go to Tools | Compare Words. The two documents appear side by
side in a new, read-only comparison file.
First File
(right)
Compare File
Second File
(left)
The first page provides an overview of the text discrepancies found in the files. Scroll through
the new comparison file to see the actual changes (marked by highlighting and triangles).
Exercise 3-2: Compare the approved labeling with the proposed labeling file and
browse through the new compare words file. Browse back to the beginning and
then close the new file and proposed.pdf when you are done.
The Go To Previous View button, , is useful for retracing your viewing path through a
document, especially when you have followed a complex series of links and changed
magnification levels several times.
• To retrace your viewing path through other PDF documents, press [SHIFT] and click the
Go Back or Go Forward button. This command opens the other PDF documents if the
documents are closed.
You can click the Go Back button repeatedly to retrace your viewing path, view by view for up to
64 views, through a document. If you have followed a link to another PDF document, the Go
Back button can also return you to your original document.
Magnification tools:
• To resize the page to fit entirely in the window, click the Fit In Window button,
• To resize the page to fit the width of the window, click the Fit Width button,
• To return a page to its actual size, click the Actual Size button,
• Click the zoom tool ( ) in the toolbar. You can either drag a rectangle around the area of
the page you want magnified (this is called marquee zooming) or you can click on an area of
the page to magnify.
Exercise 3-3: Navigate back to the NDA table of contents and go to the Summary
section of the NDA. Display the first page of the summary document at three
different magnifications - 100%, fit the whole page inside the main window, and fit
the width of the page inside the main window.
You can also use the magnification option on the status bar, , at the bottom of the screen
to change the magnification.
Using Bookmarks
A bookmark is a type of link in the navigation pane. Each bookmark in the navigation pane goes
to a different view or page in the document. As part of the comprehensive table of contents,
bookmarks are included in each PDF review document in an electronic NDA. When bookmarks
are included in the PDF review document, the navigation pane should automatically appear when
you open the review file.
To use bookmarks:
• Click the Show/Hide Navigation Pane button, , and then click the Bookmarks tab
• Move your pointer over a bookmark in the navigation pane and click to go that selection
Exercise 3-4: Use the bookmarks to go to the Nonclinical Toxicology section of the
summary document. Go back to the first page of the summary document when
done.
• The find tool lets you search through a single document for occurrences of a specific word or
phrase
• The search query tool lets you search for information in a collection of documents, using an
index that has been created in Acrobat Catalog
• Click the find tool ( ) in the command bar to display the Find dialog box. The Find dialog
box lets you enter the word or phrase you want to find.
• To repeat your find, click the find tool ( ) and press the Find Again button to search
again.
Exercise 3-5: Find the patient deaths in the summary document using the Find tool.
The find tool in Exchange suffices when you want to search for a word or phrase in a single
document. For more sophisticated searching of multiple documents at once, you can use the
Search command.
To search a NDA folder, you first must add the folder’s index files, PDX files, to the index list
using the Search Query tool ( ).
To add indexes:
– Clicking on them
• Click OK
Once you have added the index of the folder you want to search, you can now search the
discipline's folder for a simple word or phrase, search fields associated with each file, or you can
expand your search query by using wild-card characters and operators.
• Type the text you want to search for in the Find Results Containing Text box
If a match is found, the file will appear in the document pane. If multiple files match you search,
the Search Results window appears. Click the View button to open the PDF file. Click the
Info… button to find information related to the location, author, and history of the electronic
submission file.
You can also use the Search Results ( ) button on the toolbar to bring back the Search Results
window. Use the Search Next and Search Previous buttons ( ) to go to other
NDA PDF files also contain valuable information stored with each file in the document
information fields. These fields contain important, searchable information about that file.
Sponsors are asked to include information such as patient ID numbers, site number, studies, etc
in these fields.
• Click OK
Use these fields to search for text associated with that document. The table on the following
pages outlines what you can expect to find in the document information fields for the PDF files
located in electronic NDAs.
CMC Title
drug substance files ds, the name of the active ingredients, brief
description of the document (limited to a
couple of words)
drug product files dp, the name of the drug product, brief
description of the document
animal line listing files the word data should also be added
Clinical Title
patient profiles organized by site pp, the study number, the site identification
and the patient’s unique ID number
patient profiles organized by pp, the study number, and the site
study identification
domain profiles organized by dp, the study number and the appropriate
domain CRF domain name
case report forms organized by crf, the study number and the site
site identification
case report forms organized by crf, the study number, the site number and
case report form the unique patient ID number
When entering text in the document information fields, the full text character string may not be
known. Wild-card characters can be used to find all the words that contain a word fragment or
all the terms that match an arbitrary character pattern:
You can use wild-card characters in a term that is part of a Boolean expression. You can also use
wild cards to specify Document Info field values. You cannot use wild cards to represent
separator characters such as the hyphen [-] and the slash [/].
You can use AND, OR, and NOT operators to build a Boolean expression that will search for
specific words. Using AND between two words returns only documents containing both words.
NOT before a word excludes documents containing the word or search term. Use OR between
two words to return documents containing either word.
Search
Options
Search Options
The options in the Search window expand or limit the results of searches:
• Word Stemming finds words that share a stem with the search word.
• Match Case finds text only when it has the same capitalization as the text you type
• Proximity searches so that words must be within three pages of each other.
Exercise 3-6: Search the CRF index for any file related to 1) patient0000 and 2)
patient 1111 or any patients that start with the numbers 23.
To test your knowledge of the concepts and techniques you learned in this chapter, answer the
following questions:
• What is the difference between the Find tool and the Search command?
• Summarize Annotations
• Copy and Paste Graphics using the ISI Graph Copy Plus lug-in
• Click the location where you want to place the note, or drag to create a custom-sized
window. The maximum size for the note window is 288 pixels high and 432 pixels wide
• Click inside the window, and type the text for the note
Note
Window
• Click the minus bar, , in the upper left corner of the window to close a note
While a note can be closed, a text annotation remains visible above the text or image in a PDF
document.
• Holding down on the mouse, drag to the right to select the Text Annotations tool,
• Click where you want to place the text annotation, or drag a rectangle to create a text field
• Move the cursor where you want to begin drawing. The graphic does not have to be one
consistent stroke. You can let go and draw in as many places as desired.
• Move the cursor over a the pencil line until the cursor changes to a double-headed arrow and
double-click to open the notes window
• Click the minus bar, , in the upper left corner of the window to close a note
Rectangle
Tool
Line Tool
Ellipse Tool
• Click a start point, hold down the mouse button and drag the object to your desired size. Let
go of the mouse when done
• Click and drag to move the object around the page or change its size, if necessary
To associate an annotation:
• Click the minus bar, , in the upper left corner of the window to close a note
Text markup tools can be used by themselves or in with other annotation types. The types of
markups allow you to highlight, strike through, or underline text.
• On the toolbar, select the highlight text tool, , or click and drag to the right to select the
strikethrough text tool, , or the underline text tool,
NOTE: The printed version of a document marked up with highlighted text looks different from
the screen version. Text that is highlighted on-screen prints with a box around it
To associate an annotation:
• Click the minus bar, , in the upper left corner of the window to close a note
• Right-click on the closed noted, then choose the desired option from the menu
or
Summarize Annotations
Summarize Annotations
When you add annotations to your file, you may create a summary PDF file of all the notes
contained in the PDF file. The summary arranges the annotations in order as they appear in the
file with note #, label, create date and time, and full text content.
A new PDF file will be created (e.g., Notes from ndatoc.pdf). You may wish to save these files
on your hard drive or close them without saving.
Annotation Scan
You can also display annotations in the navigation pane on the Annotations palette. Using
the annotation scan feature will allow you to create, or update, a list of annotations in the current
file. The items in the list also contain hyperlinks to that annotation location in the file.
• At the bottom of the Navigation Pane, click on the Start Annotation Scan, , button
Exercise 4-2: Summarize your annotations for the summary document in a new file,
then close the file. Summarize your annotations in the Navigation Pane. Save your
file.
The table/formatted text select tool allows you to select tables and text in a PDF document and
retain the original formatting when the material is copied (or imported) into other applications.
You can specify vertical or horizontal format, the type of text flow, and whether you want ANSI
(simple text) or Rich Text Format (RTF).
Before copying and pasting text into another application, a preference needs to be changed in
Acrobat. The indentation paragraph formatting preference must be turned off to allow the pasted
text to fill the margins in the destination file.
• Click OK
• On the tool bar click on the text select tool, , and drag to the right and select the table/
formatted text select tool,
• Make sure the type is Text-Flow (If not, right-click in the paragraph and choose Text |
Flow from the popup menu)
• On that application’s pulldown menu, go to Edit | Paste or click the paste button on the
toolbar
Exercise 4-3: Change the Acrobat formatted text preferences to remove indentation
paragraph formatting when exporting. Copy the three paragraphs on page 266 of
the summary document to a Microsoft Word document.
• On the tool bar click on the Text Select Tool, , and drag to the right and select the Table/
Formatted Text Select Tool,
• Make sure the type is Table (If not, right-click in the table choose Table from the popup
menu)
• On that application’s pulldown menu, go to Edit | Paste or click the paste button on the
toolbar
Additional cells may be created when the table is pasted. Follow the directions below to merge
the extra cells and recreate the PDF table:
• Use the eraser tool, , or the merge cells tool, , to remove the excess borders
Exercise 4-4: Copy the table on page 265 of the summary document to a Microsoft
Word document. Put borders on the table.
Although Acrobat does contain a graphic copy tool, use the ISI Graph Copy Plus when
copying and pasting graphics from PDF to other applications. Follow the directions below
to copy and past graphics using the ISI Graph Copy Plus plug-in.
NOTE: In order for the ISI Graph Copy Plus plug-in to work, your monitor color palette must be
set to 256 color. To check this setting, go to Start | Settings | Control Panel and
double-click on the Display icon. Click the Settings tab. If you need to change the color
palette to 256 color, close all programs first as the change will require you to restart your
computer.
• On the tool bar, select the ISI Graph Copy Plus button,
• When you let go of the mouse, wait a few moments until the box disappears
ISI Graph
Copy Plus Selection
Box
The ISI Graph Copy Plus plug-in automatically copies the graphic to the clipboard so there is no
need to use the copy feature in Acrobat.
• On that application’s pulldown menu, go to Edit | Paste or click the paste button on the
toolbar
• Click OK
Exercise 4-5: Copy the scatter plot on page 242 of the N123456 summary document
to a Microsoft Word document as a graphic that does not float over text.
To test your knowledge of the concepts and techniques you learned in this chapter, answer the
following questions:
• Can you save notes on the network copies of the electronic submissions files?
• What color palette setting is required to use ISI Graph Copy Plus?
• What Microsoft Word feature allows you to paste graphics that do not “float” over text?
It is likely that a person who can find an answer to their question on their own will not have that
same question again. This chapter covers how to find answers independently and how and when
to access additional technical and peer support.
This short chapter will instruct you how to access the following types of support in the Center:
• Acrobat Preferences
• OIT Support
• Peer Support
The NDA Electronic Submissions Training (NEST) class offered by OIT is dependent upon you
to make constructive insights and comments on the course. Please make sure to fill out and
return the OIT Course Evaluations at the end of class. These evaluations will help us shape the
class so it is most beneficial to review staff.
The NEST manual can be found on the OIT Web (HTTP://OITWEB/OIT) under the
Documentation/ Applications Training section. PDF copies of the NEST manual
and draft Guidance can be copied to your hard drive or floppy disk.
Trifolds
Quick reference desktop trifolds for Adobe Acrobat and NEST are provided in class or can be
accessed and downloaded from the OIT Web. Use these trifolds for answers to frequently asked
questions.
The Acrobat Guide will appear. Use the links on the front page or go to the index and the end of
the file to browse topics alphabetically.
Acrobat Preferences
In order to utilize Acrobat in the electronic review environment and customize features for your
use, preference changes can be made in Adobe Acrobat. Use the File | Preferences feature on the
menu bar to change preferences for text and tables, annotations, page layouts, web integration,
and other tools. Several preference changes are listed in this manual and the documentation
provided when you install Adobe Acrobat from the OIT Web.
OIT Support
If you are unable to find the answers you need via class instruction, manuals, or the Acrobat
Guide, please call the Help Desk at X7-0911 or e-mail them at HELPDESK. Please indicate
whether your problem is related to Adobe Acrobat or electronic submissions (e.g., missing NDA
folder).
Peer Support
Some of the best resources for learning are those who work with us every day. Those of you who
have taken the NEST course and have a firm grasp of the electronic submissions process can help
share your expertise with others by acting as a mentor to those seeking information and feedback
to their ERSR related situations. Look for a more formalized peer support system as more Center
staff become familiar with NEST and ERSR regulations.
• In the NDA Quick Search field, remove the 0, enter the sample classroom NDA number,
987654 (Actual NDAs begin with 0) and press the Search button
Exercise 2 -2: Display the Sample NDA 123456 from the Search Results window in
the EDR.
Exercise 2-3: Map the drive letter Z: to sample NDA 123456 and DO NOT
reconnect at logon.
• Select Z as the Drive letter and enter \\cds006\samplenda in the path field
• Click the OK button (you should now be mapped to the sample shared area)
Exercise 2-4: Create a desktop shortcut to the folder for sample NDA 123456 and
close the Samplenda on 'Cds006' (Z:) window
• Lift your finger off of the mouse. A pulldown menu will appear.
Exercise 2-5: Check the size of the N123456\CMC folder and copy it to your
desktop.
• If the size of the folder you are copying is less than the space available on your C: drive,
continue to the next step. If the folder is larger, you will not be able to copy the folder to
your C: drive. Click OK
• Move your pointer onto the desktop and right-click. A pulldown menu will appear.
Exercise 3-1: Open the table of contents for NDA 123456 and go to the labeling
table of contents.
• Click the Labeling text to jump to the link destination—the Table of Contents for the
Labeling folder.
Exercise 3-2: Compare the approved labeling with the proposed labeling file and
browse through the new compare words file. Browse back to the beginning and
then close the new file and proposed.pdf when you are done.
• Click the last approved labeling link in the labeling table of contents
• While both files are open, go to Tools | Compare Words on the Acrobat menu bar
A new file titled Compare Words proposed.pdf : appoved.pdf appears listing the
changes found in comparison of the two documents
• Click the Next Page button, , to scroll and see how the documents differ
• Click the Last Page button, . You are now at the end of the document
• Click the First Page button, , to return to the start of the document
Exercise 3-3: Navigate back to the NDA table of contents and go to the Summary
section of the NDA. Display the first page of the summary document at three
different magnifications - 100%, fit the whole page inside the main window, and fit
the width of the page inside the main window.
• Click on the Fit Width button, , to fit the width of the page in the window
You can also use the magnification option on the status bar, , at the bottom of the screen
to change the magnification.
Exercise 3-4: Use the bookmarks to go to the Nonclinical Toxicology section of the
summary document. Go back to the first page of the summary document when
done.
• If the overview window is not displayed, click the Show/ Hide Navigation Pane button, ,
or the Navigation Pane button, , at the bottom of the screen
• Click the First Page button ( I!) to return to the start of the document
Exercise 3-5: Find the patient deaths in the summary document using the Find tool.
• Click the find tool ( ) in the command bar to display the Find dialog box. The Find dialog
box lets you enter the word or phrase you want to find.
• Select the Match Whole Word Only option. Selecting this option displays all occurrences of
“death” only as it appears. The Match Case options allows you to look for words as they
appear. Find Backwards lets you search backward starting from the current page in the
document.
The word “death” appears towards the bottom of page 47 but it does not relate to deaths specific
to this submission. To look for the word “death” in the rest of the document, use the Find Again
option.
• To repeat your Find, click the find tool ( ) and press the Find Again button to search
again. As you can see the word “death” appears again on page 265 of the Summary
document. Three deaths related to this submission are listed. It is noted to look in the case
report form section for information on two of the deaths.
1) Patient 7839
• Remove any existing indexes by clicking on them, then clicking on the Remove button
• Click OK
• You will receive the message – No documents were found that matched your query.
• Click OK
• Put a comma (,) after 0000 (you can also use the Boolean expression OR instead of the
comma)
Rectangle Annotation:
• Save the summary document to the C:\Classes\NEST folder (The network copy is read-
only)
• In the current page section of the status bar, type 266 and press [ENTER]
• On the tool bar, press and hold down on the pencil tool, . Drag to the right and select the
rectangle tool,
• Click and drag a rectangle around the first three paragraphs on the page.
• Move your pointer on the rectangle so the arrow, ", appears and double-click
• Type in your note and click the minus bar to close the note field
Pencil Annotation:
• On the tool bar, press and hold down on the rectangle tool. Drag to the right and select the
pencil tool
• Move your pointer on the line around the third paragraph so the arrow, ", appears and
double-click
• Type in your note and click the minus bar to close the note field
• Click and drag over the text in the table at the bottom of the page.
• Move your pointer on the line around the table until the arrow, ", appears and double-click
• Type in your note and click the minus bar to close the note field
Exercise 4-2: Summarize your annotations for the summary document in a new file,
then close the file. Summarize your annotations in the Navigation Pane. Save your
file.
Summarize Annotations:
Annotation Palette:
• At the bottom of the Navigation Pane, click on the Start Annotation Scan button
Exercise 4-3: Change the Acrobat formatted text preferences to remove indentation
paragraph formatting when exporting. Copy the three paragraphs on page 266 of
the summary document to a Microsoft Word document.
• Click OK
• On the tool bar click on the Text Select Tool, , and drag to the right and select the Table/
Formatted Text Select Tool,
• On the pulldown menu, go to Edit | Paste or click the Paste button, , on the Toolbar
Exercise 4-4: Copy the table on page 265 of the summary document to a Microsoft
Word document. Put borders on the table.
• Make sure the type is Table (If not, right-click in the table choose Table from the popup
menu)
• Use the eraser tool, , or the merge cells tool, , to remove the excess borders
Exercise 4-5: Copy the scatter plot on page 242 of the N123456 summary document
to a Microsoft Word document as a graphic that does not float over text.
• On the Tool Bar, select the ISI Graph Copy Plus button,
• Go to Microsoft Word
• Click OK
Exercise 5-1: Look up information about page layouts in the Acrobat Guide.
• Use the index to search for Page layouts. Click the last page button, , on the command
bar
• Make sure the hand tool is selected and click the P hyperlink on the right hand side of the
page
• Page layouts will appear at the bottom of the page and the categories with links can be found
on the next page. Click the next page button, , on the command bar
• Click on the for document viewing 41-43 link at the top left of the page. Browse
through the topic