Regulatory Affairs & Regulatory Requirements
Regulatory Affairs & Regulatory Requirements
Regulatory Affairs & Regulatory Requirements
3
REGULATORY AFFAIRS & REGULATORY
REQUIREMENTS FOR DRUG APPROVAL
♦ LEARNING OBJECTIVES ♦
After completing this chapter, students will be able to understand:
Introduction to regulatory affairs which include historical overview and current
scenario.
Regulatory authorities and their role and responsibilities in the RA department.
Various regulatory requirements for drug approval which include Investigational New
Drug (IND) Application and New Drug Application (NDA).
Data Presentation for FDA Submissions, Management of Clinical Studies.
3.1 INTRODUCTION
The present scenario of the pharmaceutical industry is very well co-ordinated, efficient
and docile as per international standards for the manufacturing of various types of Biological
and Chemical drugs (which also include medical devices, traditional herbal products and
cosmetics) used for the human consumption and veterinary purpose. Various challenges
faced by the regulatory system result into current well-defined controlled regulatory
framework. The impact of this framework consequences into systematic manufacturing and
marketing of safe, effective and qualitative drugs. With the vast growth of pharmaceutical
industry, the legislations from each region have become more and more complicated and
created an urgent need for regulatory professionals.
Regulatory affairs is a dynamic and challenging profession which is developed from the
desire of governments and act as an interface between the pharmaceutical company and the
regulatory agencies in order to ensure public health by controlling the safety and efficacy of
products in areas including pharmaceuticals, veterinary medicines, medical devices,
pesticides, agrochemicals, cosmetics and complementary medicines.
and efficacy. This leads to tightening of norms for Marketing Authorization (MA) and Good
Manufacturing Practices (GMPs).
The drug industry in India was at very primitive stage till 20th century. Most of the drugs
were imported from foreign countries.
(a) 1900-1960:
Government passed the Poisons Act, 1919 to check and hold the control on cheap drugs
available in market. This Act helps in the administered possession of substance or sale of
substances as specified as poison. It also stated the safe and protected custody of the
poisons, packaging and labeling of poisons, maximum quantity to be sold and inspection as
well as examination of the poison sold by vendor during the year.
The Poisons Act was followed by The Dangerous Drugs Act, 1930 which includes the
regulation of cultivation, manufacturing, possession and trade of opium.
In 1985, Dangerous Drugs Act, 1930 and Opium Act, 1878 was revoked by passing of the
Narcotics and Psychotropic Substances Act.
Following acts and rules were passed during this era:
• Drugs and Cosmetics Act, 1940: This act regulates the manufacturing, distribution,
import and sale of allopathic, homeopathic, unani and siddha drugs.
• Drugs and Cosmetics Rules, 1945: This act regulates manufacture of Ayurvedic
drugs for sale only, and not for consumption and use or possession.
• Pharmacy Act, 1948: This law was amended in 1986 and it generally controls and
regulates the profession of pharmacy in India.
• Drugs and Magic Remedies (Objectionable Advertisements) Rule, 1955: This rule
regulates the advertisement of drugs in India.
• Drugs Prices Control Order, 1955 (DPCO) (under the essential commodities Act):
DPCO was further amended in 1995. As per this rule, government has a jurisdiction to
review and fix maximum sale price for bulk drugs as well as formulation.
(b) 1960-1970:
The Indian Pharmaceutical industry was not mature enough and major market share was
dominated by MNC and very few Indian manufacturers were in competition. Focus on pure
research and development was very little because of deficiency of patent protection. The low
availability and high drug price is because majority shares depend upon the high drug
import.
(c) 1970-1980:
Government took control for the medicines regulation and issued few acts and rules.
• Indian Patent Act 1970 (which came in force on 20 April 1972 and replaced Indian
Patents and Designs Act of 1911): It serves as the basis for patent protection in India.
Industrial Pharmacy - II 3.3 Regulatory Affairs and ……
Under this Act, product patent was not allowed but the process and method of
manufacturing of Drug substance was allowed to get the patent.
• Drug prices capped: Drug Prices Control Order (DPCO) was introduced to control
the high price against consumers.
(d) 1980-1990:
The Indian industry has started investing in process development of API and created
production infrastructure for the same.
(e) 1990-2000:
A rapid expansion in domestic market has observed in pharmaceutical industry. The
companies have started entering into Research and Development.
(f) 2000-2010:
This period is considered to be the Innovation and Research era. During these years,
innovative research activity, patenting of the drugs formula, process, indication as well as
merger of companies was started.
Patent Amendment Act 2005: Indian Government brought out the Patents
(Amendment) Ordinance, 2004 to address the issues relating to the patent in the country
which was later replaced by the Indian Patent (Amendment) Act, 2005. The new Act brought
some crucial changes on the legal regime of patent protection so as to address patent issues
in technology, chemicals and pharmaceuticals sectors.
Compulsory Licenses: Such licenses can be granted for manufacture and export of the
drug products “to any country having insufficient or no manufacturing capacity, for the said
product, to address public health problems”.
Few names are given below:
• Drugs and Cosmetics (First Amendment) Rules, 2011: It mandates registration of
Clinical Research Organization (CRO) for conducting Clinical Trials (CT).
• Clinical Trial Registry-India (CTRI): It has been set up by the ICMR’s (Indian Council
of Medical Research) National Institute of Medical Statistics (NIMS).
• Pharmacovigilance Program of India (PvPI): The Central Drugs Standard Control
Organization (CDSCO) has launched Pharmacovigilance programme to assure drugs
safety to Indian patients.
favourable evaluation of quality, efficacy and safety to meet the shortest possible
timeline.
Fig. 3.2
• DRA professional plays the crucial role in each phase of drug development and post
marketing activities.
• The pharmaceutical companies (DRA professionals of the company) accumulate all
the date pertains to drug discovery and development stages and uses the same for
the purpose of registration and marketing of drug.
• RA professionals of the company have to abide the array of strict and guidelines
throughout the drug development process, to ensure the drug and efficacy of drugs
in the humans.
• The Regulatory Affairs department also takes part in the drug development,
marketing concepts and is a crucial requirement to approve the packaging and
advertising of drug/product before it is used commercially.
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Drug development is the process of bringing a new pharmaceutical drug to the market
once a lead compound has been identified through the process of drug discovery. It includes
pre-clinical research on microorganisms and animals, filing for regulatory status, for an
investigational new drug to initiate clinical trials on humans, and may include the step of
obtaining regulatory approval with a new drug application to market the drug.
The process of drug discovery and development is very long and needs 10-12 years
which includes the close interaction of large number of scientific disciplines. Most
biotechnology and pharmaceutical companies employ teams to mentor the process of
various stages of drug development and making the drug candidate into therapeutic
products.
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Fig. 3.6
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The primary aims of the non-clinical (or pre-clinical) development phase is to analyze and
determine which candidate has the greatest probability of success, assess its safety, and raise
firm scientific foundations before transition to the clinical development phase. This process
of non-clinical development of medicine is very complex, time consuming and regulatory
driven. The selected candidate compound should also meet non-medical objectives, which
also include defining the IPR and making enough medicinal products available for clinical
trials.
Once identification of candidate compound is completed, the non-clinical development
should start answering the following questions, and answers will come from specific
assessments/studies:
• Does it work? → Assessment of Efficacy
• How will it be delivered and how will the body react? → Profiling
• Is it safe? → Toxicology/safety
• Is the manufacture viable and controllable?
Non-clinical development activities can continue throughout the life-cycle of the product.
3.9 VARIOUS PHARMACOLOGICAL APPPROACHES TO DRUG DISCOVERY
As an academic principle Pharmacology can be loosely defined as the study of effects of
chemical substances on living systems.
This definition is so broad that it holds all the aspects of drug discovery, ranging from
details of interaction between drug molecule and its target to consequences of placing the
drug in the market.
Selectivity Testing: It consists of two main stages i.e. screening for selectivity and
Binding assay. To determine the potency of drug, the selectivity of a compound for a chosen
molecular target needs to be assessed.
Pharmacological Profiling: This includes the determination of pharmacodynamics effect
of new compound, either on in-vitro models (which include cell lines or isolated tissues) or
in-vivo models (which include normal animals, animal models of disease).
Long-Term Toxicity:
• These studies should be carried out in at least two mammalian species and out of
these two mammalian species one should be a non-rodent.
• The duration of study will depend on the factor that whether the application is for
marketing permission or for clinical trial, and in the later case, on the phases of trials.
• If a species is known to metabolize the drug in the same way as humans, it should be
preferred in long-term toxicity studies. The drug should be administered 7 days a
week by the route intended for clinical use in humans.
• A control group of animals, given the vehicle alone, should always be included, and
three other groups should be given graded doses of the drug; the highest dose
should produce observable toxicity, the lowest dose should not cause observable
toxicity, but should be comparable to the intended therapeutic dose in humans or a
multiple of it.
IND Review and Report: During this time, FDA has an opportunity to review the IND
application for safety to assure that research subjects will not be subjected to unreasonable
risk. The report evaluates on the various factors like Medical Review, Chemistry Review,
Pharmacology/Toxicology review, Statistical analysis and Safety review.
• The IB also provides insight to support the clinical management of the study subjects
during the course of the clinical trial. The information should be presented in a
concise and simple manner.
• IB enables a clinician, or potential investigator, to understand it and make his/her
own unbiased risk- benefit assessment of the appropriateness of the proposed trial.
For this reason, a medically qualified person should generally participate in the
editing of an IB.
3.14.2 Contents of Investigator’s Brochure
1. Table of contents.
2. Summary not exceeding 2 pages, highlighting the significant physical, chemical,
pharmaceutical, pharmacological, toxicological, pharmacokinetic, metabolic, and
clinical information available of IP.
3. Introduction: Chemical name, active ingredients, pharmacological class, anticipated
– therapeutic/diagnostic indication(s). General approach to be followed in evaluating
the IP.
4. Description of I.P.: Physical, chemical and pharmaceutical properties of I.P. Storage
and handling of I.P. Any structural similarity with the other known compound given.
5. Non-clinical studies: The results of all relevant non-clinical pharmacology,
toxicology, pharmacokinetic, and investigational product metabolism studies should
be provided in summary form. The information provided may include: Species tested,
Number of sex in each group, Unit dose (e.g., milligram/kilogram (mg/kg), Dose
interval, Route of administration and Duration of dosing.
5.1 Non-clinical Pharmacology: A summary of the pharmacological aspects of the
investigational product studied in animals should be included.
5.2 Pharmacokinetics and Product Metabolism in Animals: A summary of the
pharmacokinetics (ADME) and biological transformation and disposition (getting
a drug into its appropriate position in the body and in an appropriate
concentration) of the investigational product in all species studied should be
given.
5.3 Toxicology: (The study of the adverse effects of chemicals on animals): A
summary of the toxicological effects found in relevant studies conducted in
different animal species. (Single dose, Repeated dose, Carcinogenicity, Special
studies (irritancy, sensitization), Reproductive toxicity).
6. Effects in Humans: A thorough discussion of the known effects of the investigational
product(s) in humans should be provided, including information on
pharmacokinetics, metabolism, Pharmacodynamics, dose response, safety, efficacy,
and other pharmacological activities. (a) Pharmacokinetics and Product Metabolism
in Humans.
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7. Summary of Data and Guidance for the Investigator: This section should contain
non-clinical and clinical data of IP. IB provides the investigator a clear understanding
of the possible risks, adverse reactions, observations and precautions needed for the
clinical trial.
3.15 NEW DRUG APPLICATION (NDA)
The vehicle through which drug sponsors formally propose that the regulatory body
approves a new pharmaceutical for sale and marketing, and the data gathered during the
animal studies and human clinical trials of an investigational new product becomes a part of
the NDA.
• The clinical trial design and objectives are written into a document called a clinical
trial protocol. It is a document that states the background, objectives, rationale,
design, methodology (including the methods for dealing with AEs, withdrawals etc.)
and statistical considerations of the study. It also states the conditions under which
the study shall be performed and managed.
• Look for better ways to prevent disease in people who never had the disease or to
prevent a disease from returning.
• The protocols means:
- To clarify the research question.
- To compile existing knowledge.
- To formulate a hypothesis and objectives.
- To decide about a study design.
- To clarify ethical considerations.
- To apply for funding.
- To have a guideline and tool for the research team.
Parts of the Protocol:
1. Title Page.
2. Signature Page.
3. Content Page.
4. List of Abbreviations.
5. Introduction/Abstract.
6. Objectives.
7. Background/Rationale.
8. Eligibility Criteria.
9. Study Design/Methods (Including Drug/Device Info).
10. Safety/Adverse Events.
11. Regulatory Guidance.
12. Statistical Section (Including Analysis and Monitoring).
13. Human Subjects Protection/Informed Consent.
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Fig. 3.14
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Study data standards describe a standard way to exchange clinical and non-clinical study
data. These standards provide a consistent general framework for organizing study data,
including templates for datasets, standard names for variables; identify appropriate
controlled terminology and standard ways of doing calculations with common variables. Data
standards also help FDA receive, process, review, and archive submissions more efficiently
and effectively.
• FDA has been working towards a standardized approach to capture, receive and
analyze study data.
• Standardization of study data is vital to integrate pre-marketing study data and
post-marketing safety data to improve public health and patient safety.
• Central to this vision is the creation of an enterprise data infrastructure (Janus) within
FDA to improve the management of all structured scientific data.
Data Standards: Data standards can be divided into two categories:
1. Exchange Standards: Exchange standards provide a consistent way to exchange
information. Exchange standards help to ensure that the sending and the receiving
systems both understand unambiguously what information is being exchanged.
2. Terminology Standards: Terminology standards provide a consistent way to
describe concepts. For example, the Unique Ingredient Identifiers (UNII), developed
by the FDA, provides a consistent way to describe substances in foods and drugs.
Vocabulary developed National Institute of Cancer describes terminology related to
cancer.
3.19 MANAGEMENT OF CLINICAL STUDIES
Clinical trial management is most simply defined as the process that an organization
follows to ensure that quality (defined as minimized risks and clean data) is delivered
efficiently and punctually. It refers to a standards-driven process that a project manager
initiates and follows in order to successfully manage clinical trial sites, clinical research
associates, and workflow by using clinical trial management tools or software prolonged
timelines and heavy costs related to large trials have been prompted a new focus on more
efficient clinical trial management. It is possible to dramatically reduce the total cost of a
clinical trial by 60% - 90% without compromising the scientific validity of the results.