Author: Brandon Miller

EU Regulatory Update

Posted on by Brandon Miller

The European Commission’s formal pitch for revising the medicines legislative & EU regulatory framework was recently released. The new European regulatory documents targeting pharmaceutical industry reform & regulation law have been uploaded to the EU’s website. Multiple documents are included to help industry participants better understand the proposed regulatory compliance initiatives.

 

Regulatory Framework

 

The current European regulatory system is responsible for the evaluation & assessment of medicinal products. This regulatory process involves the European Medicines Agency (EMA), the competent authority of each EU member state, and subject matter experts on EMA scientific committees.

 

The proposed measures are designed to update the regulatory framework to accommodate the increase in EU pharmaceutical new product development. This includes requirements related to both clinical trials & real-world evidence. Additionally, secondary use of health data & regulatory sandboxes are also a focus of the legislation.

 

Regulatory Legislation

 

The new legislation draft mentions COVID-19 & the reduced availability of scientific resources has led to capacity constraints becoming more common. Further, this problem would continue without changes based on the current regulatory submission volume from drug companies.

 

Finally, the proposal mentions the current inefficiency of pharmaceutical product submissions. Regulatory submissions currently going through as many as five scientific committees to receive marketing authorization. A simplified regulatory framework is proposed to add flexibility so committee members have more time to concentrate on evolving pharmaceutical drug priorities.

 

Scientific Committees

 

The regulatory legislation draft proposes to reduce the number of scientific committees to just two:

 

  • Committee for Medicinal Products for Human Use (CHMP)
  • Pharmacovigilance Risk Assessment Committee (PRAC)

 

The CHMP & PRAC would continue to include pharmaceutical chemistry subject matter experts from each EU member state. The CHMP would also incorporate patient representatives on the new committee, a first of its kind for the European Commission. This representation of patients & health care professionals would consist of individuals with expertise in all areas, including rare & pediatric diseases.

 

Regulatory Training

 

New members of scientific committees from all EU member states would be offered different types of regulatory training opportunities. The goal for the EU regulatory training is to increase expertise in new areas of science & technology by partnering with top pharmaceutical companies & industry experts. This would help to relieve the current bandwidth issues many regulatory agencies & committees encounter, directly impacting new committee members who can contribute.

 

Further, training programs would be designed to help individuals assess & monitor pharmaceutical products. In fact, the proposal specifically mentions the speed of researching & approving cutting edge medicinal products from drug manufacturers.

 

Regulatory Procedure

 

The regulatory proposal continues by documenting the need for a reduction of regulatory burden on the committees. The opportunity to simplify regulatory procedures & increased digitalization are both mentioned as European Medicines Agency priorities. Additionally, this regulation meaning could influence electronic submission of applications & electronic product information (ePI) for approved pharmaceuticals.

 

Sunset Clause

 

Two measures designed to shrink the EU regulatory committee responsibility are the elimination of the renewal and the sunset clause. The EMA legal framework states the pharmaceutical research leading to marketing authorization of a medicine will:

 

  • Cease to be valid if the medicine is not on the market within three years of approval
  • Cease to be valid if the medicine is removed from the market for three consecutive years

 

While this does not represent a majority of pharmaceutical regulatory approvals, it does show the goal of the proposal is simplification. By reducing the regulatory burden of unnecessary policy, pharmaceutical companies should hopefully be able to expedite their dealings with the EMA. This will also amplify the streamlining of the new scientific committee structure. Finally, a more efficient regulatory process should help new pharmaceuticals move toward approval quicker and deliver product to patients sooner.

 

Paediatric Investigation Plans (PIPs)

 

Paediatric drug development is also evolving per the regulatory proposal draft. Clinical development plans for children at a young age currently requires pharmaceutical manufacturers to make statements about the anticipated results. As a result, regulatory teams submitting approval for novel therapies will be given more freedom to introduce a high level clinical development plan. Subsequently, this could help pharma manufacturing companies working on multiple novel treatments at the same time during the pharmaceutical product development process. 

 

Pharmaceutical Companies

 

So, who exactly does this proposed legislation help & would it impact pharmaceutical sales? According to the EMA, the reduction of administrative burden should benefit small & medium-sized EU pharmaceutical companies who have more challenges bringing new products to market. The regulatory legislation would also help not-for-profit bodies participating in pharmaceutical manufacturing research & development of new therapeutic products.

 

Industry Reaction

 

As anticipated, reaction from big pharma leaders has been swift & mixed. Martuscelli reports that policymakers want to tackle the uneven rollout of drugs across the EU. However, the proposed rules would remove two years of data protection from all new medicines launched in the European Union.

 

This would allow unbranded competitors to enter the market more quickly. Cutting drug market exclusivity for new medicines from ten to eight years will not go over well with pharmaceutical industry executives. Billions of dollars are spent annually on pharmaceutical technology & developing new products to address unmet needs of the patient. 

 

Stella Kyriakides, European Commissioner for Health and Food Safety, commented the proposal would help regulatory process by offering incentives for novel drugs & providing concrete action toward reducing drug shortages.  Additionally, transparent supply chains & leaner regulatory approval rules could increase the speed of pharmaceutical science programs. This is an important step as pharmaceutical supply chain members recover from the COVID-19 pandemic & drug shortages associated with the outbreak. 

 

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Food And Drug Administration

Posted on by Brandon Miller

The Food and Drug Administration (FDA) Commissioner, Dr. Robert Califf, recently testified in front of a Senate Appropriations subcommittee about core programs for the 2025 budget process. Executives at FDA are asking for a $341 million increase in the annual budget (currently proposed at $7.22 billion) compared to the previously approved FY 2024 budget.

 

Drug Shortage

 

One topic that received significant interest was drug shortages. Dr. Califf confirmed there are still over 200 drugs classified as in shortage. FDA has requested over $12 million to help rectify the problem and bring greater predictability to supply chain problems. Additionally, the ability to clarify pharmaceutical manufacturing problems that may arise appears to be a priority to FDA.

 

Regulatory Affairs

 

The Office of Regulatory Affairs (FDA ORA) has asked for an additional $2.7 million to be added to the proposed budget. Specifically, ten new full-time employees are proposed as headcount to address issues with both drug shortages and problems inside the supply chain. $3 million is specifically proposed to recruit new FDA inspection resources who can help identify these types of scenarios in advance during routine FDA inspections.

 

Further, continued growth in regulatory applications for both medical device manufacturing and biologic manufacturing facilities was mentioned as critical to keep pace with the industry’s need for FDA approval inspections. For life science industry employees, the slowdown in FDA inspections has had mixed reactions.

 

Michael Rogers, associate commissioner for regulatory affairs at the FDA’s Office of Regulatory Affairs, has also recently commented about the need for more FDA auditors due to investigators who have recently retired. According to Rogers, FDA investigators “have been underrecognized and underappreciated”, which may have led to attrition over time at the agency.

 

Avian Influenza Virus

 

Dr. Califf continued the discussion with lawmakers about the potential dangers of avian influenza (or bird flu) and vaccine production. Commentary revolved around how prepared the United States government is in responding to virus mutations if bird flu could spread to humans. Further, Dr. Califf elaborated on how investments in personal protective equipment (PPE) & funding for vaccine manufacturing could help the potential problem.

 

Finally, short-term solutions focused on the safety of dairy workers if the virus infected the U.S. milk supply, and new research options to study how quickly the avian influenza virus may evolve. 

 

IT Infrastructure

 

Finally, FDA has requested over $8 million to improve critical infrastructure and upgrade technology across the agency. The goal is to modernize many of the legacy workflows the regulatory agency uses and increase the analytical potential of data analysis.

 

The entire presentation can be found at this link. 

 

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Inshoring Strategy

Posted on by Brandon Miller

As with many industries these days, pharmaceutical manufacturers are now reevaluating the structure of their manufacturing operations. A specific focus area is whether returning some or all production processes to American shores (inshoring) is a more practical and cost-effective alternative to the offshoring trend that’s been prevalent for several decades. 

 

Are you Considering In-Shoring your Pharmaceuticals?  Talk to our Experts →

 

Factors That Impact the Inshoring/Off-Shoring Decision

 

Examples of crucial considerations when in-shoring pharma include:

 

Manufacturing

 

If yours is like many pharma operations, you chose to outsource due to the lower production and labor costs available overseas. If it’s been a while since you’ve compared manufacturing abroad vs. at home, consider conducting a comprehensive cost analysis. You might be surprised to learn that you can now produce a pharma product in the U.S. more cheaply than before. In some cases, the costs are now nearly as low as in China.

 

Suppose your manufacturing cost analysis yields favorable results and you determine to move forward with in-shoring. The next step is to decide the type of manufacturing facility that makes the most sense for your operation. Specifically, you should determine whether a brownfield (existing) or greenfield (brand-new) site is the better option. 

 

Technology

 

If you’re evaluating an existing structure, take a look at the current equipment and technology. Are they compatible with your projects’ demands? If not, can you make cost-effective upgrades or modifications to bring them up to speed? If these hurdles are prohibitive, building a greenfield facility will likely provide a more practical and affordable long-term solution. 

 

A greenfield site enables you to customize your manufacturing processes more effectively since you are building and equipping the facility from scratch. On the downside, the costs of a new building, compatible machinery, and hiring and training fresh personnel may not be affordable for some pharma operations. And constructing a new facility from the ground up takes time — a commodity that’s often in short supply in today’s ultra-competitive pharma industry. 

 

Supply Chain

 

Supply chain access is another vital factor when in-shoring pharma operations. Given that many of the raw materials and ingredients used to manufacture pharma products and medical devices come from outside the U.S., finding acceptable substitutes at home can pose a challenge. If you must import them, you’ll need to consider the added transportation and costs of these components.

 

You’ll also need to account for all applicable supply chain qualifications. For instance, if you’re partnering with new suppliers, you must ensure they meet your company’s unique qualification and quality criteria. Transportation concerns are another issue to evaluate. Will you be able to get the materials to your facility reliably on time to accommodate your production schedules? You’ll need to implement a qualified transportation system for certain essential ingredients and finished goods. 

 

Operations

 

From a business/operational perspective, consider how in-shoring pharma will impact your personnel. For instance, if you decide to move into an existing facility, determine if there will be sufficient space for your workers and any new equipment you add. Also, can the facility accommodate essential areas such as clean rooms, warehousing, waste treatment systems, and cold storage spaces?

 

If you’re relying on outdated technology systems, you’ll likely need to make upgrades to meet the changes in demand. Examples of systems that require careful evaluation include ERP, CAPA management, and eDoc, to name a few. 

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

The Regulatory Impact of EUAs

Posted on by Brandon Miller

Emergency Use Authorization (EUA) is a valuable asset that the FDA uses to make exceptions for unapproved medical devices during public health crises. It has brought up some controversy since COVID-19 started making its way around the globe. Regardless, there is little doubt that it has had a major impact on the regulatory policies of industries everywhere. EUAs are affecting more industries than just the medical device manufacturers. They’re also playing a role in speeding up approvals for other manufactured products.

 

Regulatory Impact of EUA Authority

 

Since just February 2020, the FDA has issued EUAs for more than 100 different elements, including drugs, devices and biologics. Other organizations, like those making personal protective equipment, ventilators and hand sanitizers, have gone through the EUA process for distribution approval.

 

At the beginning of the global pandemic, hand sanitizer started flying off of retail shelves due to the increase in COVID-19 fears. Doctors became desperate for PPE and respirators as patients entered hospitals in critical condition from the illness. Pharmaceutical manufacturers that produced these types of products wanted to make sure their goods reached the market faster. The quicker they were available for sale, the more patients and doctors could start reaping the medical benefits. As a result, it became more common to use EUA’s to skip over the lengthy 510(k) submission processes.

 

While this strategy can help manufacturers turn out new products more quickly, what happens after the emergency has passed? Vaccine acceptance rates in many countries are climbing.  If you work in our regulated industry, how will you keep products on the market over the long term?

 

Need help preparing your product for a EUA?  Contact RCA Now →

 

What You Need to Know About the Regulatory Impact

 

Receiving EUA approval provides a faster way for manufacturers to put their products on the shelves, even if those products are still in the experimental phase. The regulatory impact of EUA approval during COVID-19 is that more products are receiving fast approval than ever before. That said, it’s crucial to remember that this approval is only temporary.

 

The government needs to declare a state of defense or public health emergency before an EUA can be issued for a product. After the emergency passes, you’ll have to go through the regulatory approval process to ensure that your product is effective and safe to use. The COVID-19 vaccine has shown high efficacy and social distancing is becoming more relaxed. You need to consider long-term portfolio strategies so your product can continue its first-to-market advantage.

 

Preparation for an EUA submission into the market involves maintaining a consistent pharmaceutical supply chain flow. To have a product authorized, you may need to start gathering relevant information and resources. This can include test data, labeling requirements and clinical support. Going through the full approval process will ensure that your product is fit to serve the public on a long-term basis.

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

Clinical Trials FDA Guidance

Posted on by Brandon Miller

The FDA recently updated guidance for clinical trials & trial design. This update stems from an objective of the 21st Century Cures Act (Cures Act). It includes recommendations for how industry sponsors of pharmaceuticals or biologics should design and conduct clinical trials. The guidance provides a greater explanation of how biologic and oncology trial design can simultaneously evaluate more than one investigational drug.

 

FDA Guidance

 

The guidance goes into depth about the clinical research milestones of master protocol design. Data integrity considerations are also mentioned for biomarker co-development and trial statistical analysis. Traditionally, oncology clinical trials are designed to assess multiple investigational drugs at the same time. Clinical data in this type of design is analyzed across multiple cancer types during the same trial to find all sources of patient efficacy and commercial value.

 

Another primary driver is the CDMO race due to testing multiple drugs and sub-populations under the same protocol. Pharmaceutical consultants like RCA Inc. have witnessed a shortening of client commercialization timelines across the life sciences industry. This directly adds incremental pressure on project sponsors. Clinical teams are being tasked to discover late-stage drug success faster than ever before. Every trial must simultaneously ensure patient safety while producing data that satisfies the regulatory safety and effectiveness.

 

Need help with your Clinical Trials? Talk to our Experts. 

 

Investigational Drugs (IND FDA)

 

The FDA concisely describes this unique protocol design and clinical trial planning for IND filings and multiple sub-studies. Sub-studies may have separate goals and require aligned efforts across the data science team. For example, collaboration is needed in order to appropriately value multiple investigational drugs. Consideration should be given that therapeutic value may be in one or more disease sub-types in the clinical trial.

 

With these considerations in mind, the FDA goes on to describe the benefits of a master protocol across the study design. This provides the project sponsor design flexibility via electronic data capture (EDC) in an EDC system (e.g. shared control arm, adaptive designs, centralized data capture).

 

Clinical Trial Design

 

This new FDA guidance also provides insights on potential challenges the industry should consider when using master protocols. These unintended consequences can include greater difficulty when assigning detailed adverse events to an investigational drug if numerous products are being investigated across the clinical study.

 

Any lack of adverse event reporting clarity can impact the safety profile of an investigational drug. This directly makes the clinical analysis for FDA approval more complicated for the regulatory body. Multiple study groups can also increase the overinterpretation of study findings. For example, signs of positive product efficacy for cardiac biomarkers could be different than from cancer biomarkers. Biomarker discovery for one subpopulation could also be identified as false if based a different ad hoc patient group.

 

Basket Trials

 

Basket trial design includes assessing an investigational drug blend by including a dose-finding or safety lead-in component. The goal is to identify safe quantities of the combination early in the clinical trial before progressing with an efficacy activity-estimating factor. The FDA proposes therapeutic efficacy for sub-studies within basket trials are constructed as single-arm, activity-estimating trial. The primary endpoint would be recorded as total response rate.

 

The guidance goes on to elaborate on sub-study objectives, including study rationale for each population. A comprehensive statistical analysis plan (SAP) with reasoning for sample size and unique stopping rules based on ineffectuality should also be included in the program documentation.

 

Umbrella Trials

 

A master protocol designed to evaluate multiple drugs is commonly referred to as an umbrella trial. These umbrella trials are often administered as a single drug or as a combination product. Umbrella trials are often a randomized controlled trial to evaluate the mechanism of action of the investigational drug/drugs with a common control arm. Study design for an umbrella trial can include sub-studies based on a patient biomarker or to a separate therapeutic sub-study inside the trial.

 

Clinical Study Design

 

As the clinical study focus, the FDA provides a clear understanding of how project sponsors improve the efficiency of master protocols. For example, using a common control arm during an Umbrella Trial has proven to help evaluate multiple drugs simultaneously for a single disease state.

 

Control Arm

 

For clinical trials, the FDA now recommends a project sponsor use a common control arm when numerous drugs are evaluated simultaneously in a single illness (e.g. umbrella trials). The FDA guidance elaborates in the use of a control arm be the current standard of care (SOC) so trial results are understandable from the perspective of the biologic and oncology medical community.

 

Changes in SOC can also take place during the trial because of an FDA approval or the latest scientific data. The Statistical Analysis Plan (SAP) would need to be revised before any data analysis occurs if this is the case.

 

Novel Drugs

 

When a project sponsor uses sub-studies to assess two or more investigational drugs, the FDA advocates for providing a thorough scientific motivation for the combination. This includes the clinical trial sponsor defining the Recommended Phase 2 Dose (RP2D). Analysis should include each novel drug and ensuring the appropriate dosage has been identified for each individual drug.

 

Targeting Biomarkers

 

The FDA goes on to elaborate on digital biomarkers to help validate the patient selection and recruiting for clinical trials. Biomarkers should be clearly identified based on the intended therapeutic response.

 

For example, an oncology biomarker for tumor size can help predict the response to the investigational drug. This type of study biomarker might demonstrate how the mechanism of action succeeded or failed. There needs to be a consensus among the clinical study team on how biomarkers are justified. Understanding study measures for showing marker positivity before patients enter the trial is critical.

 

Data Monitoring

 

One final important note about the master protocol in the updated FDA guidance describes the independent radiologic review committee. This committee medical research should include blinded tumor-based assessments to provide a charter for the independent data monitoring committee (IDMC).

 

The IDMC charter would guide the committee through ad hoc trials, such as patient efficacy and drug futility. The IDMC can also recommend clinical trial protocol actions. This often includes changes in sample size or modification of a sub-study based on overwhelming futility or efficacy evidence.

 

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Medical Device Regulatory Preparation

Posted on by Brandon Miller

What can life science companies do to prepare themselves in the current medical device regulatory environment?

 

 

In this sound bite from RCA Radio, host Brandon Miller is joined by Jordan Elder, RCA’s Director of Regulatory Affairs, and Kinga Demetriou, an Expert Certifier at BSI, as they discuss what companies can do to properly prepare themselves for success in the current regulatory environment.

 

  • Take a look at your product and make sure your regulatory strategy is conducive to your particular product and market. Have a pathway forward
  • Make sure that your strategy implements the most up-to-date guidances and standards. Stay up to date 
  • Get to know your testing laboratory and certifiers early in the design process to ensure no critical milestones are overlooked. Partner up
  • Compliance processes take a considerable amount of time. Early engagement gives you the best chance to meet deadlines. Get a head start

 

Listen to the full Podcast on Global Regulatory Trends –> Click Here

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].