New UK National Procedure – Expedited 150 day procedure

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There are now several routes to obtain a marketing authorisation in the United Kingdom (UK), Great Britain (England, Scotland and Wales) or Northern Ireland. The options available will be determined by the intended market and the type of application. In this article we will discuss the purely National procedure.

To help you to decide what type of license you will require, here is a brief explanation of the new types of MA you can obtain:

MA prefix for UK Possible MA types Territory Leg & Guidance
PL UK wide Authorised for use in United Kingdom (Great Britain & Northern Ireland) EU & MHRA rules apply
PLGB GB Authorised for use in Great Britain only (England, Scotland and Wales only) MHRA rules apply
PLNI NI Authorised for use in Northern Ireland only EU rules apply

One option you can pursue is the National procedure (a 150-day procedure) to obtain a marketing authorisation (MA) in the UK, Great Britain or/in Northern Ireland. The MHRA has introduced this accelerated procedure aimed at expediting the availability of medicines for patients in the UK and proposes to reach its opinion on marketing authorisation applications (MAAs) within 150 days of filing an application (excluding the time taken to provide further information or data required).

Applications should be submitted via the MHRA Submission Portal, and the appropriate national fee will apply.

The accelerated assessment is available for all high-quality new MAAs for both new, and existing active substances, as well as orphan designations. Interested applicants should contact the MHRA in advance of submitting the application.

For medicines containing new active substances or biosimilar products, the MHRA encourages applicants to provide a summary of the dossier to share their intentions and to verify the new active substance status.

The pre-submission meeting offers the opportunity to discuss the arrangements for the UK Compliance Check (CC) on Paediatric Investigation Plans (PIPs). Additionally, it also offers the opportunity to enhance joint discussion with National Institute for Health and Care Excellence (NICE) Health Technology Assessment (HTA) evaluation process.

The MHRA will operate a ‘fixed submission date’ system to facilitate consultation with the Commission on Human Medicines (CHM) and will publish a set of dates to facilitate planning the submissions to coordinate with appropriate meeting dates of CHM. The submission slots will be linked to the dates of CHM meetings.

The assessment timetable will begin after the validation of the application. The assessment process will run in two phases totalling 150 days like so:

  • Phase I: completed 80 days after the clock starts. Issues that arose or requiring clarification from the initial assessment will be raised with the applicant and should be addressed within the clock off period of 60 days.
  • Phase II: commence on receipt of the applicant’s responses. The MHRA will provide a decision on the acceptability of the product by day 150.

If the MHRA refuses to grant the MA-based on advice from CHM, there is an opportunity for the applicant to request a review of the decision.

The conclusion of the assessment will lead to the publication of a UK Public Assessment Report for the product.

Here are some useful links to obtain further information:

https://www.gov.uk/guidance/apply-for-a-licence-to-market-a-medicine-in-the-uk#national-procedure

https://www.gov.uk/guidance/guidance-note-on-new-assessment-routes

https://www.gov.uk/guidance/guidance-on-150-day-assessment-for-national-applications-for-medicines

https://services.intralinks.com/branding/3997623225/?clientID=3997623225

https://www.gov.uk/government/publications/mhra-fees

https://www.gov.uk/government/organisations/commission-on-human-medicines/about/membership

https://www.gov.uk/guidance/marketing-authorisation-application-submission-dates-for-150-days-national-and-european-commission-decision-reliance-procedures

If you need any clarification or support to help you to navigate the new post Brexit procedures, please contact us and Ivowen will gladly assist you in a timely manner.

BREXIT – MHRA post-transition period information

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The UK has left the EU and the transition period after Brexit comes to an end this year.

The MHRA have issued new guidance for industry and organisations effective from 01st January 2021.  From this date the MHRA will be the UK’s standalone medicines and medical devices regulator.

Areas covered in the new guidance include:

Clinical Trials

From 1 January 2021, for registering clinical trials, existing and established international registers will still be used, such as ISRCTN registry (UK), or ClinicalTrials.gov (USA), to ensure the public is aware of your trial. For trials involving both UK and EU sites a record in the EU Clinical Trials Register will exist (other than adult Phase 1 studies).  In the UK, any favourable opinion given by a research ethics committee is subject to the condition that the clinical trial is registered on a publicly accessible database. The time frame for publishing the summary of results is within 6 months of the end of trial for paediatric clinical trials or within one year of the end of trial for non-paediatric clinical trials. You do not need to submit this clinical trial summary report to the MHRA as well; however, you must send a short confirmatory email to CT.Submission@mhra.gov.uk once the result-related information has been uploaded to the public register and provide a link.

 

Pharmacovigilance

Guidance on qualified person responsible for pharmacovigilance (QPPV) including pharmacovigilance system master files (PSMF) from 1 January 2021

From 1 January 2021, the following legal obligations will apply to holders of UK marketing authorisations (MA). These include those that cover the whole of the UK, or are specific to Northern Ireland or to Great Britain (England, Wales and Scotland):

  • To operate a pharmacovigilance system for UK authorised products.
  • To have an appropriately qualified person responsible for pharmacovigilance (QPPV) that resides and operates in the EU or the UK and is responsible for the establishment and maintenance of the pharmacovigilance system for UK authorised products.
  • To maintain and make available upon request a pharmacovigilance system master file (PSMF) that describes the pharmacovigilance system for UK authorised products. The PSMF must be accessible electronically or physically from the UK at the same site at which reports of suspected adverse reaction may be accessed.

Statutory guidance concerning the QPPV for UK authorised products is described in the Good Pharmacovigilance Practices (GVP) Module I. This guidance will be supplemented by the ‘Exceptions and modifications to the EU guidance on good pharmacovigilance practices that apply to UK marketing authorisation holders’, which will be published in due course.

Updated guidance on pharmacovigilance procedures

Detailed guidance on pharmacovigilance procedures from 1 January 2021 is published on the MHRA website: https://www.gov.uk/government/publications/guidance-on-pharmacovigilance-procedures-in-the-event-from-1-january-2021/updated-guidance-on-pharmacovigilance-procedures

 

Marketing Authorisations

New guidelines have been outlined for Marketing Authorisations, to include Conditional MAs, registering new packaging information, guidance on the handling of applications for Centrally Authorised Products (CAPs),  Article 29 applications, converting parallel distribution notices to UK parallel import licences, handling of ASMFs and CoS from January 2021, reference medicinal products, converting CAPs to UK MAs, guidance on licencing biosimilars, bioequivalence/therapeutic equivalence studies and renewing marketing authorisations.

 New Submission Registrations

For planned applications for submission to the UK (for example, a Marketing Authorisation for the UK market), you will need to submit the information through the MHRA national portals.

All current Eudravigilance Gateway users who wish to gain access to the new MHRA Gateway will need to first gain access to MHRA Submissions. The steps for gaining MHRA Gateway access are contained within MHRA Submissions.  MHRA Submissions will not be used to send or receive ICSRs.

A useful webinar on how to gain access to MHRA submissions portal is available on the MHRA website at the following link https://www.gov.uk/government/publications/webinars-preparing-to-make-submissions-to-the-mhra-from-1-january-2021

Within the recent MHRA guidelines, the following areas are also covered:

  • Devices
  • Importing and Exporting
  • IT Systems
  • Paediatrics

IN DEPTH DETAILS ON THE NEW MHRA GUIDANCE CAN BE FOUND ON THE LINK BELOW:-

https://www.gov.uk/government/collections/mhra-post-transition-period-information

 

If you need any clarification or support to help you to navigate the end of transition period please contact us and Ivowen will gladly assist you in a timely manner.

 

Written by Mary Canning

BREXIT – No extension to the transition period

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It seems that Brexit is on course for 1st January 2021….

The 30th June 2020 came and the legal deadline for agreeing to an extension of the transition period has passed with no request from the UK. Therefore the Brexit trade deal transition phase will come to an end on the 31st December 2020. At this stage there will be one of two possible outcomes:The next important dates are the 15-16th October (European Council Meeting) and 26th November (penultimate plenary session of 2020. European lawmakers have stated that a trade deal must be negotiated, checked, translated and presented to the European Parliament by this date if the transition period is to end by 31 December 2020). If the UK exits without a trade deal, trade between the UK and EU will change immediately on the 1st January 2021 (i.e. Hard Brexit).

The European Commission (EC), European Medicines Agency (EMA) and Heads of Medicines Agencies (HMA) have recently reminded clinical trial sponsors that they must comply with EU clinical trial rules following the Brexit transition period that expires on 31 December 2020 https://ec.europa.eu/health/sites/health/files/files/eudralex/vol-10/brexit_technicalnotice_ct_en.pdf

The UK Government launched a major new public information campaign to give everyone the facts that they will need to be ready for 1 January 2021. A straightforward checker tool at gov.uk/transition will help identify some of the specific steps any business or individual needs to take to be ready, and will allow companies to sign up for bespoke updates.

To keep up to date with all EMA advice on Brexit please refer to the following: https://www.ema.europa.eu/en/about-us/brexit-united-kingdoms-withdrawal-european-union

For more detailed information about how 2020 currently looks with regard to Brexit please see: https://ivowen.com/brexit-everything-stays-the-same-for-2020/

If you require any assistance for UK products please contact us: info@ivowen.com

Written by Emily Fletcher

Emily Flecther

 

European Procedural Guidance during COVID-19 Pandemic

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In response to the significant impact the COVID-19 pandemic is having on European regulatory activity, the European Commission, the European Medicines Agency and the Heads of Medicines Agencies network (EC, EMA and HMA, respectively) have approved a number of measures to help the management of marketing authorisations for human medicinal products considered crucial during the pandemic period.

The objective of these measures agreed at European level is to promote regulatory flexibility, facilitate, simplify and accelerate the administrative procedures, as far as possible, in order to respond more efficiently to emerging needs during this period.

As a result, the EC recently published questions and answers on regulatory expectations for medicinal products for human use during the COVID-19 pandemic:

Questions and Answers on Regulatory Expectations for Medicinal Products for Human Use during the COVID-19 Pandemic

This Q & A document which provides guidance to marketing authorisation holders (MAH) includes the following topics:

  • renewal applications
  • sunset clause
  • an exceptional change management process (ECMP) for crucial medicines for use in COVID-19 patients
  • circumstances under which the validity GMP certificates and authorisations to manufacture/import can be extended
  • circumstances under which the validity GDP certificates and wholesale authorisations can be extended
  • adaptions to the work of a Qualified Person (QP)
  • the possibility of adapting quality requirements for medicines intended to be used for the treatment of COVID-19 patients
  • the impact on reporting into EudraVigilance of Individual Case Safety Reports (ICSRs)
  • flexibility in the labelling and packaging requirements to facilitate the movement of medicinal products within the EU

Further to the European Commission’s Q&A document, the CMDh has agreed additional questions and answers that provide practical information on how to specifically address and apply the provisions determined by the European Commission for MR/DC procedures:

Practical Guidance of the CMDh for facilitating the Handling of Processes during the COVID-19 Crisis

The CMDh document addresses issues such as the impact of COVID-19 on assessment timelines, how to use the ECMP procedure (which is only applicable for products that are crucial for the treatment of COVID-19 patients) and QP declarations based on a desktop audits. It also includes a useful annex that details Member States’ email addresses and links to relevant published guidance on MS websites.

Both documents will be updated and supplemented with additional information, as appropriate during the pandemic.

Everyone at Ivowen is working tirelessly to keep our clients applications on track. We are liaising with the National Competent Authorities all the time to ensure we avoid delays and get the best results possible in these unprecedented times.

If you need any assistance in this regard please don’t hesitate to contact us.

 

 

 

 

 

 

Written by Claire Brown.

Ivowen - Pharmacovigilance

How to get an Assessor’s opinion before you contact the Competent Authorities

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Firstly, in this very unusual time for us all I want to let you know that our dedicated team are all healthy, safe and working from home, business as usual, to ensure that we continue to provide you with the high quality and efficient service you have come to expect from Ivowen.

Have you ever wished you could get the opinion of an Assessor before you go to the National Competent Authorities with your queries? 

Well, I am delighted to introduce you to to our newest team member Claire Brown.

Claire has come directly to Ivowen from the Health Products Regulatory Authority (HPRA) and brings with her a wealth of experience as a pharmaceutical assessor of human medicinal products. Claire has been part of the team here in Ivowen since 2019 and has more than 12 years experience working in the HPRA. She started there as a Scientific Officer working mostly on veterinary medicinal products and was promoted to Pharmaceutical Assessor after 3 years.

Claire completed her undergraduate work in Chemistry and her postgraduate work in Neuropharmacology and Industrial Pharmaceutical Science.

Claire adds her extensive experience to our knowledgeable team so that we can enhance the services we provide to you and continue to give you an ‘Assessor’s eye’ opinion on your applications before you submit them.

I invite you to visit our updated Meet the Team page to see all the talented people who enable us to guide you through all aspects of regulatory strategy, dossier preparation, MA submissions through to national phase, post-approval variations, product development, quality overviews, medical devices and much much more.

If you could use some assistance to navigate the complex world of regulatory, please feel free to contact us for further information.

Written by Alice D’Alton.

Nitrosamines and responsibilities of MAHs – Deadline is approaching

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As an MAH, do any of your authorised human medicinal products contain chemically synthesised active substances? If so, read the following to identify what your responsibilities are with regard to reporting results of risk analysis to the appropriate Competent Authorities by 26 March 2020 deadline.

On 20th December 2019, the EMA published a Q & A on the document entitled ‘Information on nitrosamines for MAHs’ which includes new and updated information. This Q & A document should be read in conjunction with the document Information on nitrosamines for marketing authorisation holders (dated Sept 2019).

Further information for companies in relation to centrally and non-centrally authorised medicines is available from the EMA website and CMDh website.

Background:

In June 2018, authorities in the EU became aware of the presence of a nitrosamine, N-nitrosodimethylamine (NDMA), in valsartan from one manufacturer of active pharmaceutical ingredients (APIs). Subsequently another nitrosamine, N-nitrosodiethylamine (NDEA), was detected and other sartans from more API manufacturers were later implicated.

NDMA and NDEA are classified as probable human carcinogens (substances that could cause cancer) and their presence in sartans was, at the time, unexpected.

An Article 31 review of sartans at risk of containing nitrosamine impurities (i.e. sartans with a tetrazole ring) concluded that manufacturers must review and make necessary changes to their manufacturing processes to minimise nitrosamine impurities as much as possible. In addition, strict limits were set for nitrosamines in these products. The Article 31 review of sartans identified a number of root causes of nitrosamine formation and contamination.

A review was performed which indicated there is a potential for nitrosamines to be present in APIs for other medicines (i.e. non-sartans APIs), depending on the API and the finished product manufacturing processes.

While Nitrosamines are not expected to be formed during the manufacture of the vast majority of APIs outside the class of sartans with a tetrazole ring, it is now known that these impurities can form during production under certain conditions and when certain solvents, reagents and other raw materials are used. In addition, impurities can be carried over during the manufacturing process when using already-contaminated equipment or reagents.

Responsibilities of MAH: 

Despite the low risk of nitrosamines being present, Marketing Authorisation Holders (MAHs) are asked to take precautionary measures to mitigate the risk of nitrosamine formation or presence during the manufacture of ALL authorised human medicinal products containing chemically synthesised APIs  including generics and over-the counter (OTC) products. However, in view of the large number of authorised products, MAHs should use a risk-based approach and prioritize their evaluations and confirmatory testing.

The EMA’s human medicines committee (CHMP) requested in September 2019 that MAHs for human medicines containing chemically synthesised active substances, review their medicines for the possible presence of nitrosamines and test all products at risk.

It is the responsibility of MAHs to work closely with the manufacturers of APIs and finished products to perform risk evaluation and report this to the Competent Authorities where the products are authorised within 6 months of the guideline on “Information on nitrosamines for marketing authorisation holders”. This guideline was published on 26 September 2019, thus MAHs should supply complete risk evaluations to the respective Competent Authorities by 26 March 2020.

In summary MAHs must perform the following steps:

Step 1: Risk Evaluation

MAH’s should perform risk analysis of their medicinal products containing chemically synthesised API. The MAHs should prioritise products in order to establish the sequence in which their products are to be evaluated. The factors to be taken into account are outlined in the dedicated Q&A document on the EMA & CMDh websites. For products of high priority the risk evaluation should be done immediately. The risk evaluation of all products should be concluded at the latest with 6 months of the publication of Information on Nitrosamines for Marketing Authorisation Holders.

If a risk of presence of nitrosamine is identified as a result of the evaluation, the MAH should proceed to step 2 below.

After the individual risk evaluation is finished send the appropriate template for the outcomes of “no risk identified” or “risk identified” including the required email headings and details. The guidance given by the relevant national competent authorities’ website also has to be regarded, refer to Annex 1 in CMDh practical guidance for MAH of nationally authorised products (including MRP/DCP in relation to Art. 5 (3) Referral for Nitrosamines.

For MRP/DCP Products refer to:

https://www.hma.eu/fileadmin/dateien/Human_Medicines/CMD_h_/Advice_from_CMDh/CMDh_404_2019_Rev.0_2019_09_-_Nitrosamines_-_Information_on_nitrosamines_for_MAHs_.pdf

For Centrally Authorised Products refer to:

https://www.ema.europa.eu/en/documents/referral/nitrosamines-emea-h-a53-1490-information-nitrosamines-marketing-authorisation-holders_en.pdf

It is also very useful to refer to the Question & Answer Documents and the templates on the following links:

For MRP/DCP Products refer to:

https://www.ema.europa.eu/en/documents/referral/nitrosamines-emea-h-a53-1490-questions-answers-information-nitrosamines-marketing-authorisation_en.pdf

https://www.hma.eu/fileadmin/dateien/Human_Medicines/CMD_h_/Advice_from_CMDh/CMDh_400_2019_Rev_1_09_2019_clean_-_Q_A_on_sartans_referral.pdf

For Centrally Authorised Products refer to:

https://www.ema.europa.eu/en/documents/referral/nitrosamines-emea-h-a53-1490-questions-answers-information-nitrosamines-marketing-authorisation_en.pdf

Step 2: Conformity Testing

If the presence of nitrosamine is identified as a result of the risk evaluation, confirmatory testing should be carried out using appropriately validated and sensitive methods. Products identified as high priority should be tested as soon as possible.

Confirmatory testing of all medicinal products identified to be at risk of presence of nitrosamines and submission of required changes in the Marketing Authorisations should be concluded within 3 years (by 26/02/2022) of the publication of Information on Nitrosamines for Marketing Authorisation Holders or at an earlier time if otherwise justified.

MAHs should inform the relevant Competent Authorities immediately if tests confirm the presence of nitrosamines impurity irrespective of the amount detected.

Templates:

MAHs must test in accordance to

https://www.hma.eu/fileadmin/dateien/Human_Medicines/CMD_h_/Advice_from_CMDh/Nitrosamins/CMDh_412_2019_Rev.2_2019_12_clean_-_PG_to_MAHs_on_nitrosamines.pdf and report the results to the relevant National Competent Authority using the Templates on:

https://www.hma.eu/226.html

https://www.ema.europa.eu/en/search/search?search_api_views_fulltext=nitrosamine

Step 3: Changes to the Marketing Authorisation

MAHs should apply for a variation in a timely manner to introduce any required changes, such as amendment to the manufacturing process or changes to product specifications.

Refer to Templates on the EMA and CMDh websites to report results to the relevant Competent Authorities. It is also advised to view the relevant Competent Authorities websites to view national requirements on submitting this information.

If you need any clarification or support to help implement the responsibilities of a MAH with regard to Nitrosamines reporting contact us and we will gladly assist you in a timely manner.

Written by

2019 – What a year

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Ivowen attended the Medicines for Europe conference in January (Regulatory and Pharmacovigilance), the annual EuDRAcon conference in May, exhibited at TOPRA in October and joined our clients from around the world at CPhI in November.

We all saw Brexit come and go, Twice !! We wait to see what lies in store for the next deadline in January 2020.

The FMD came into effect across Europe in February in most member states.

Bulgaria joined CESP, eCTD became mandatory for all human procedures, lots of new guidance was published (to keep us all on our toes) and Nitrosamines in medicinal products moved to the top of everyone’s agenda.

With the festive season now upon us and 2020 on the horizon, Ivowen are setting our sights on the year ahead.

We will be attending the Medicines for Europe conference in January 2020 (Regulatory and Pharmacovigilance) and we encourage you to contact us before mid-January with any specific questions you might like us to ‘ask the regulators’. This is a great opportunity to ask those difficult questions that you just could not get a straight answer to in 2019, on the ever present grey areas of Regulatory procedures.

To help you to plan ahead here are some helpful updates, in brief, as full articles will be posted in 2020:

Falsified Medicines Directive – Where we are now:

  • Implemented on 9th Feb 2019 in all MS except Greece, Italy and Belgium
  • The European Commission has produced a video to explain more about the safety features.
  • The HPRA have extended the use and learn period, initially to Sep 2019 and extended it again to end on a phased basis starting from 31st January 2020.
  • The MHRA is also taking a pragmatic, flexible approach to how they enforce the new legal requirements.

Nitrosamines

 

Ivowen are here to assist you in 2020 and will continue to provide the top quality service you have come to expect from us.

For more information on Ivowen’s services and how we can help you, contact us.

Written by Alice D’Alton.

News from the HPRA

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The HPRA are always striving to improve their processes and ways of working.  The following updates in the Human Medicines Department should help us all in our dealings with each other.

New electronic workflow system

The human medicines department within the HPRA have transitioned to using a new (internal) electronic workflow system. Due to this the following changes are worth noting for MA (marketing authorisation) applications and the issuing of licences and summary of product characteristics (SmPCs) by the HPRA:

  • Product Specific Details (PSD)

The product specific information (which included the product composition and the manufacturers’ details) will no longer form part of the product licence document that is issued by the HPRA.
Previously the product licence document consisted of the licence cover page, PSD and Summary of Product Characteristics (SmPC). In future, the product licence document will consist of the licence cover page and the SmPC only. The information previously detailed in the PSD will be logged on the HPRA database and remain a registered part of the product marketing authorisation.

  • Summary of Product Characteristics (SmPC)

Updated SmPCs and Package Leaflets will publish on the website 24 hours after case closure.
(For details relating to the font/format of SmPC documents, further details are found in HPRA newsletter number 62).

  • PA numbers 

PA, or Product Authorisation numbers, are the Irish version of the MA number.  Newly allocated PA numbers for new holders will now contain 5 digit prefix.

  • Case Reference Number (CRN)

Previously CRNs were displayed as seven digits. These will now be alpha numerical for any new cases e.g. CRN00011X. The HPRA will still be able to identify any closed or ongoing cases using the old CRN.

  • Digital communications

All cases on the new system will be assigned a dedicated e-mail address e.g. [CaseNumber]@case.hpra.ie. This will enable you to send the HPRA case specific communications directly to the case and the allocated team. E-mail correspondence sent to you from the HPRA that is relevant to the case will come from this dedicated e-mail address. The European e-mail boxes will still be used where applicable.  You should consult with your IT department to ensure that e-mails of this nature are not blocked in your organisation.

 

National Scientific Advice Guide

The HPRA have recently updated their National Scientific Advice Guidance (which commenced in 2017) to include additional therapeutic areas for stakeholders. These areas include: anti-infective products, vaccines, disorders of haemostasis and thrombosis, cardiovascular diseases, common allergic conditions, advanced therapies in certain clinical indications and biostatistics. The updated guidance can be found at the following link:

(Guide for national scientific advice)

 

Written by:

Claire Brown