Regulatory affairs Historical overview of Regulatory Affairs, Regulatory authorities, Role of Regulatory affairs department

Historical overview of Regulatory Affairs, Regulatory authorities, Role of Regulatory affairs department

1. Regulatory affairs Introduction , Historical overview of Regulatory Affairs, Regulatory authorities, Role of Regulatory affairs department, Responsibility of Regulatory Affairs Professionals

2. Regulatory affairs is a profession within regulated industries namely - pharmaceuticals, medical devices, energy and banking. It has specific meaning within health care industries namely - pharmaceuticals, medical devices and functional foods . Definition: Drug Regulatory Affairs is a function which regulates the pharmaceutical science in order to facilitate trade / business in and outside the country of origin for public interest. Introduction

3. Regulatory Network ASEAN- Association of South East Asian Nations SADC- South African Development Community APEC- Asia Pacific Economic Cooperation GCC- Gulf Cooperative Countries PANDRH- Pan American Network on Drug Regulatory Harmonization

4. Regulatory authorities

5. During 1950s, multiple tragedies i.e. sulfanilamide elixir, vaccine tragedy and thalidomide tragedy have resulted in substantial increase of legislations for drug products quality, safety 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. Historical overview of Regulatory Affairs

6. 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 In 1985, Dangerous Drugs Act, 1930 and Opium Act, 1878 was revoked by passing of the Narcotics and Psychotropic Substances Act. 1900-1960

7. 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. Following acts and rules were passed during this era:

8. 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

9. 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. 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. Local companies begin to make an impact: Since the product patent was allowed by Indian Patent Act 1970; local companies began manufacturing products/ drugs using different manufacturing process by reverse engineering. Due to this new drugs were available cheaply as well as many more substitute drugs were available in the market against costly imported new drugs. This has resulted in Increase the exports to countries like Russia, Africa, China, and South America. Export of Bulk drug post patent expiry 1970-1980:

10. 1980-1990: The industry has started investing in API process development and created production infrastructure. Government has also issued export incentives. The Narcotic Drugs and Psychotropic Substances Act, 1985 was issued which regulates the operation of narcotic drugs and substances. 1990-2000 : The pharmaceutical industry has observed a rapid expansion of domestic market and during same era globalization happened. The companies have entered into research activity. India joined Paris Cooperation Treaty (PCT) in 1999 and implemented product patent effective from Jan 1, 2005.

11. 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: With this act, provision for Black Box Application made, as per that if patent application is filed before Jan 1, 2005, then under the transit provision of Trade Related aspects of Intellectual Property Rights (TRIPS), manufacturer can market this product post 2005 without infringing product patent, if manufacturer has made significant investment in manufacturing of the product, produced and marketed on or before Jan 1, 2005. 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”. 2000-2010:

12. Herbal preparations having medicinal values can be patented under new amended law. Major regulatory changes in terms of marketing authorization process as well guidelines have come into effect. Few to name are as below : Drugs and Cosmetics (First Amendment) Rules, 2011: It mandates registration of Clinical Research Organization (CRO) for conducting Clinical Trials (CT). Schedule Y1 suggests requirements and guidelines for registration of Clinical Research Organizations.

13. 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). India has developed on-line registry system and mandated registration of CRO before the enrolment of first patient for clinical trials. CRO needs to disclose mandatory items as mentioned under WHO International Clinical Trials Registry Platform (ICTRP) dataset. Pharmacovigilance Programme of India ( PvPI ): The Central Drugs Standard Control Organization (CDSCO) has launched Pharmacovigilance programme to assure drugs safety to Indian patients. This will help monitoring adverse drug reactions to Indian patients, as well as monitoring of benefit-risk ratio. Guidance documents: CDSCO has issued guidance for Industry for Fixed Dose Combinations (FDCs) registration as well as Guidance for preparation of Common Technical Document for Import/manufacture and Marketing Approval of New drugs for Human Use (New Drug Application-NDA). With this CDSCO has implemented system for preliminary scrutiny at the time of application receipt for marketing approval of Fixed Dose Combinations (FDCs).

14. List of Major Acts, Rules or System in USA .

15. ROLE OF REGULATORY AFFAIRS DEPARTMENT

16. ROLE OF REGULATORY AFFAIRS DEPARTMENT

17. ROLE OF REGULATORY AFFAIRS DEPARTMENT

18. Role of Regulatory Affairs Professionals in Health Authorities (HA ): Evaluation of Marketing Authorization Application Issuance of Evaluation comments/ Exigencies to Manufacturers Managing variation application, post approval changes and keeping record of annual update Post Marketing Approval Management Issuance of Marketing Authorization Approval, GMP, and GCP approval certificate Managing MAA On-line and up-gradation towards common technical document format Responsibility of Regulatory Affairs Professionals

19. Issuance of guidelines & guidance documents for Quality, Safety, Efficacy and Pricing Control as well as CTD for implementation Collaboration with Global and Regional Harmonization units for exchange of technical knowledge, developing guidelines as well as allotting mutual recognition status for technical documents, GMP status and product approval Part of foreign trade delegation to facilitate smooth management of Pharmaceutical business within countries and minimizing barrier by reducing duplicate generation of technical data and timeline for evaluation and approval by respecting each other regulatory framework Performing GMP Audit for Drug Manufacturing Site, GCP Audit for Clinical Study Site and Bio-equivalence Centre, and issuing certification confirming approval status Responsibility of Regulatory Affairs Professionals

20. Supporting Manufacturer in defining drug development pathway during Pre-NDA meeting and providing comments / confirming development pathway Monitoring Drug Safety by collecting Pharmacovigilance data and reviewing drugs in markets time to time by reviewing labels and taking appropriate action accordingly Monitoring Clinical Trials as well as approving study results for next phase of study Allowing speedy or fast track designation for essential drug to patient population ROLE OF REGULATORY AFFAIRS DEPARTMENT Responsibility of Regulatory Affairs Professionals

21. 2. Role of Regulatory Advisor in Pharmaceutical Industry: Define Regulatory Strategy for drug development: Critical role during selection of Drug products for specific market Be a part of Business development, Marketing and Project team meeting Defines the type of application in consultation with specified Health Authority i.e. New Drug or Generic Application Meet Health Authority/ ies to define Clinical Regulatory Pathway Based on that prepares Global Regulatory Plan (GRP) defining Chemistry, Manufacturing and Control (CMC), Clinical and Non-Clinical Requirements Advise Research and Development (R&D) team to develop product at laboratory scale matching regulatory criteria. In case of Generic drug, regulatory strategist advise which Reference Listed Drug (RLD) to be used, Test Criteria and Specifications for Active Pharmaceutical Ingredient (API) and Drug Support in terms of executing validation batches at manufacturing location, defining batch size, number of batch sizes, criteria and justification for specification, evaluation of technical data Bio-equivalence (BE) or Bio-Availability (BA) criteria- defining study protocol and getting concurrence from respective health authority Labeling Requirement- for Generic submission, replica of innovator labeling information. In case of new drug, labeling to be based on actual Clinical and non clinical study ROLE OF REGULATORY AFFAIRS DEPARTMENT Responsibility of Regulatory Affairs Professionals

22. Marketing Authorization Application: Deciding the submission type- New Drug Application (NDA), New Biologic Application (NBA), Clinical Trial Application (CTA), Generic Application, Branded Generic Application, Post Approval Changes, Variation Application Type of Drug Master files (Type I-IV) – Active Substance Drug Master File (DMF), Site Master File (SMF), Packaging Material Master File and Excipient Master files Preparing Dossier in acceptable national format or Common Technical Dossier (CTD) format for Global submission Justifying dossier application with Other Regulatory Agency’s recommendation and precedence as well as Global and regional requirement Formal application to respective Health Authority for MAA Technical evaluation and support to manufacturing location and clinical sites during authority inspection Drafting Query/Exigency’s response to HA in time with prior discussion, need base Support for Drug submission /approval calendar preparation and predicting Approval timeline for Drug Product and aligning marketing department for launch schedule Managing Drug Product Registration Life Cycle by timely submission of post approval changes, Annual Update and Renewal submission Submitting Pharmacovigilance data to Health Authority for already marketed drug Withdrawal or cancellation application for drug, in case mandatory

23. Health Authority relationship: Part of Health Authorities meeting to play advisory role in terms of defining guidelines from Industry point of view Comments and suggestions for draft guidelines and circular, as applicable Develop good working relationship with evaluators of Health Authority Keeping updated about latest regulatory guidelines and upcoming changes to take proactive steps for alignment of manufacturers with regulations

24. Regulatory systems and processes: Keeping records for Drug Product Submission and Approval database Preparing Standard Operating Procedure (SOP) for efficient management of drug regulatory affairs department Providing internal training to staff to keep up breast about regulatory environment Be part of Regulatory forums/ conferences/ webinars / seminars to exchange regulatory knowledge Organize proper storage of submission documents through Information Technology (IT) Arrange software for on-line submission in Common Technical Dossier (CTD) format

25. file:///C:/Users/admin/Downloads/historical-overview-of-pharmaceutical-industry-and-drug-regulatory-affairs-2167-7689.S11-002.pdf References