The document discusses preparing for submission of a Drug Master File (DMF) in electronic common technical document (eCTD) format. It provides an agenda for a presentation on the topic including an overview of FDA requirements for eCTD, a checklist for DMF readiness, and tips for transitioning from paper to eCTD format. The presentation will also include a demonstration of the Cunesoft software for assembling eCTD submissions and managing electronic document lifecycles.
Good day everybody! My name is Jim Nichols and I’d like to welcome you to Cunesoft’s webinar about a journey many of you are about to take – a journey on the road to DMF readiness.
Along the DMF road to readiness, we will discuss several key points along the way. First we will review the FDA mandate that has brought us all here, we’ll then talk about what makes the eCTD format unique and different from your traditional DMF submissions and then we’ll have a product demonstration of cune-eCTD. Following the demonstration, we’ll share with you a comprehensive readiness checklist that you can use as a guide on your own journey followed by our recommended next steps. Finally, we’ll wrap up with a Q&A session. Overall, this session will last about 45 minutes and we certainly hope that you will find the information useful as you consider your plans for eCTD submission compliance in a few months.
Along the DMF road to readiness, we will discuss several key points along the way. First we will review the FDA mandate that has brought us all here, we’ll then talk about what makes the eCTD format unique and different from your traditional DMF submissions and then we’ll have a product demonstration of cune-eCTD. Following the demonstration, we’ll share with you a comprehensive readiness checklist that you can use as a guide on your own journey followed by our recommended next steps. Finally, we’ll wrap up with a Q&A session. Overall, this session will last about 45 minutes and we certainly hope that you will find the information useful as you consider your plans for eCTD submission compliance in a few months.
Before we get started, we do have a quick poll that we’d like to share with you. Basically, we would like to know which of our topics has brought you here to our webinar today. You’ll see the poll question on your screen and you can simply click on your response.
AFTER POLL: I want to thank all of you for sharing your opinion here today. I certainly hope that we meet your expectations and should you have any questions, please remember that we will have a q&a session at the end of the webinar today.,
So why are we on this journey? Well, it basically comes down to a mandate handed down by the FDA stating that as of May 5 2018 – less than 3 months from today – all submission types must be in eCTD format.
As you can see, this goes well beyond typical new drug applications, but specifically includes Drug Master File submissions. What’s more, if companies don’t adhere to this, their submissions will be subject to rejection.
As for DMFs specifically, there is some further guidance: you will use your existing DMF number as the application number (you may need to add a zero in the front of the number to make sure it is 6 digits long).
With regard to FDA, you are NOT required to resubmit all of the materials of your existing DMF but, IF you do choose to do so, you can… and you just need to be clear in your cover letter regarding which information may have also been updated since the original submission.
And to further reinforce the reality of this, we have included just a few pieces of an FDA webinar from August of last year. Here you see the reinforcement of the eCTD requirement as well as their position on waivers and exemptions… and that position is that there are no waivers or exemptions as many had hoped there may be. We have also included the URL to this entire presentation in case you’d like to see it in its entirety.
There are some key suggestions, tips and guidance included in several different documents available from the FDA.
What we have done here and in the next few slides is summarize them to give you an idea of the types of things you will want to be thinking about and paying attention to. Starting with your documents, there are requirements about how tables of contents and the bookmarks in your PDFs should appear, about page orientation, and how to handle documents created via scanning.
With eCTD, considering and planning the names of your leaf titles is important as they should be clear and indicative of the nature of the document. And here, I’ll stop and point out that you’ll hear new terms like ‘Leaf’ and ‘Backbone’. In the world of eCTD, a ‘Leaf’ is essentially one PDF document in your eCTD submission. The ‘Backbone’ or ‘XML Backbone’ as it’s sometimes called, is a file that essentially helps organize these Leaf files in a structure and with the context of how they’re being provided in the submission. One thing you don’t need to worry about is this Backbone file… an eCTD technology like cune-eCTD is designed specifically to handle this for you and will get created automatically.
And because we’re talking about a process that not only produces your submission in electronic format, but one that also involves sending it electronically, there are additional (and potentially new) pieces of information you need to consider. Information such as different contacts and contact information will need to be provided in the submission in case the FDA needs to reach out to you about possible questions.
Now, some more tips may sound even more ominous because we start hearing the words ‘metadata’ and ‘lifcycle’. Not to worry but I will explain these briefly
The metadata is basically the attributes you will be associating with different sections of your submission. Things like product name and manufacturer are pieces of information that will help to have the correct folders created for your submission.
The term ‘lifecycle’ really pertains to one of the most important concepts of the eCTD. You’ll remember I mentioned that Backbone file earlier… in that file, for each Leaf that is getting submitted, there is an attribute referred to as the lifecycle operator. This is an indicator to the receiving agency’s system about each of those Leaf files: NEW meaning that this is a Leaf that’s being submitted for the first time, REPLACE meaning that this Leaf is replacing a previously submitted Leaf, and so on.
Again, these should be things you worry too much about if you’re using something like cune-eCTD because the solution takes care of these things for you and makes it very easy for you to understand.
Now I mentioned before that not only are you creating an electronic submission, but you’ll also be sending it to the FDA electronically.
This will be done by using the FDA’s electronic submission gateway or ESG. There are several tips here as well. The biggest and most important tip is that you should sign up for your account as soon as possible. The reason being that things operate on a first come/first served basis and for some of the steps I this process, the FDA has set the expectation that their responses may take as long as 4 weeks.
Now, when we’re less than 3 months away from that key date in May, 4 weeks can fly by very quickly.
Now here we get into some pretty specific details about how to fill out your submission envelope information. You will see two scenarios here: one in the event that your first eCTD is an amendment to a DMF, and the other for the case where your first eCTD is an annual report for your DMF. Again, solutions like cune-eCTD will guide you through filling out your submission envelope as you create your eCTD.
So, if all of this has you worried, don’t be! Why? Because by working with Cunesoft, you can rest assured that we have the People, Products and Process to help you on your road to DMF submissions.
Cunesoft’s people are experts and experienced. We know the eCTD and we know the challenges you’re facing.
Cunesot’s products are purpose-built for these requirements. They’re easy to use and always compliant with regulatory requirements.
And Cunesoft’s processes are tried and proven. From getting your system set up, to providing live training, and to having a support team operating in North America, Europe and India
Combined, we firmly believe this gives Cunesoft a unique value to you and our customers.
Next I’d like to talk about our DMF Readiness Checklist. I’ll step through the key 5 steps of the checklist in a moment but would also like to let everybody know that you can also download this checklist from our website.
As I mentioned, there are 5 key steps to ensure you’re ready for submitting your DMFs as eCTDs:
Identifying your requirements and next steps,
understanding the eCTD and the submission process,
preparing your sample submission for the electronic submissions gateway (or ESG) and submitting it,
creating your actual DMF submission,
and finally managing your DMF’s lifecycle in eCTD
I’ll review each of these steps in a bit more detail…
Some of the key things to consider in this first step is your plan.
You should understand the types of DMFs you’ll be preparing, assessing your documents in terms of format (are they in Word, PDF, paper) and if you’re using a document management system, is it properly organized.
Obviously, knowing if your company may already have software to handle these submissions would be useful but also thinking about if you plan to handle these eCTD submissions in-house or if you’ve thought about outsourcing them.
And next, do you know which eCTD validation tool to use? Do you have it or know where to get it.
Finally, have you started the process for signing up for the ESG. As I mentioned earlier, some of the steps in this process can take some time while waiting for responses from the FDA.
Next, you’ll want to make sure you understand these new requirements along with these new concepts and terminology.
For example, if your documents are primarily in paper, how will you make them electronic and compliant with requirements?
You should make sure you understand which sections – or modules – of the eCTD are applicable to your time of DMF. Type II and Type III DMFs will typically use different sections of the eCTD, for example.
And I can’t say this enough: get yourself set up for the gateway. Give yourself time to do things like get your digital certificate, sign up for your test account and understand how to interpret the possible responses you can get back from the gateway after sending a submission.
Now here at step 3, the assumption is that you have by this point selected an eCTD solution.
Why? Because one of the very first things you’ll need to do is submit what is called a sample ESG submission. In order for you to actually send real submissions through the gateway, the FDA requires you to submit a sample ESG submission through your Test account – this is the first ESG account you’ll get.
The goal of this sample ESG submission is to assure the FDA that your actual submissions will comply with the technical requirements and expectations they have. Until you have a successful sample ESG submission, the FDA will not promote your test account to a production account.
Now you’re ready! You’re ready to actually create your DMF submission in eCTD format.
Key checklist items here include organizing your documents, constructing your submission and creating a test submission output that you can run through the agency’s validator.
And once you’ve passed those validator tests, you’re ready to produce your final submission and send it through the gateway. Again, knowing the types and the meaning of gateway responses will be important in case you may need to re-submit for some reason.
Finally, you’re ready for managing the lifecycle.
By this I mean handling your subsequent submissions after that first time. It will be important to know things like the schedule for your annual reports, what kinds of amendments are coming and how to organize those documents, handling any health authority correspondence, and of course, submitting your LOAs when and as needed.
So, having reviewed this substantial checklist, how can Cunesoft help you?
Well, we think we can help you in several ways: by ensuring and guaranteeing eCTD compliance with cune-eCTD, offering you our expertise and real-life experience in producing eCTD submissions ourselves, enabling you to control your submission documents with our integrated cune-RDMS module, and finally providing you with smart, responsive support from around the world.
By combining our products, people and process, Cunesoft is uniquely positioned to provide you with the best possible roadmap for your DMF journey. We hope you will allow us to help you!
And before we wrap up with a Q&A session, I did want to share with you a few useful links.
The first is for the Validator tool used by the FDA – you can download it for free and use it just like the FDA does.
We’ve also included a link to the ESG page that gives you lots of information about how to get yourselves set up for the gateway,
and finally, a link to an FDA presentation from last year about the move to eCTD for DMF submissions.
And before we wrap up with a Q&A session, I did want to share with you a few useful links.
The first is for the Validator tool used by the FDA – you can download it for free and use it just like the FDA does.
We’ve also included a link to the ESG page that gives you lots of information about how to get yourselves set up for the gateway,
and finally, a link to an FDA presentation from last year about the move to eCTD for DMF submissions.
And before we wrap up with a Q&A session, I did want to share with you a few useful links.
The first is for the Validator tool used by the FDA – you can download it for free and use it just like the FDA does.
We’ve also included a link to the ESG page that gives you lots of information about how to get yourselves set up for the gateway,
and finally, a link to an FDA presentation from last year about the move to eCTD for DMF submissions.
And before we wrap up with a Q&A session, I did want to share with you a few useful links.
The first is for the Validator tool used by the FDA – you can download it for free and use it just like the FDA does.
We’ve also included a link to the ESG page that gives you lots of information about how to get yourselves set up for the gateway,
and finally, a link to an FDA presentation from last year about the move to eCTD for DMF submissions.
And before we wrap up with a Q&A session, I did want to share with you a few useful links.
The first is for the Validator tool used by the FDA – you can download it for free and use it just like the FDA does.
We’ve also included a link to the ESG page that gives you lots of information about how to get yourselves set up for the gateway,
and finally, a link to an FDA presentation from last year about the move to eCTD for DMF submissions.
And before we wrap up with a Q&A session, I did want to share with you a few useful links.
The first is for the Validator tool used by the FDA – you can download it for free and use it just like the FDA does.
We’ve also included a link to the ESG page that gives you lots of information about how to get yourselves set up for the gateway,
and finally, a link to an FDA presentation from last year about the move to eCTD for DMF submissions.
And before we wrap up with a Q&A session, I did want to share with you a few useful links.
The first is for the Validator tool used by the FDA – you can download it for free and use it just like the FDA does.
We’ve also included a link to the ESG page that gives you lots of information about how to get yourselves set up for the gateway,
and finally, a link to an FDA presentation from last year about the move to eCTD for DMF submissions.
Thank you Daniel. I certainly think that this should give our guests a much better idea about how cune-eCTD can and will make the transition to eCTD much easier when it comes to DMF submissions.
Now we have another quick poll that we’d like to share with you. You’ll see the poll question on your screen and you can simply click on your response.
Basically, we would like to know about your biggest concerns regarding the move to eCTD. You can check all that apply for:
Transitioning from my current documents to eCTD documents
Knowing where to my documents in an eCTD
Planning and managing my eCTD submission activities
Using the FDA Electronic Submission Gateway (ESG)
Validating my submission before sending it to the FDA
AFTER POLL: I want to thank all of you for sharing your opinion here today. I certainly hope that we meet your expectations and should you have any questions, please remember that we will have a q&a session at the end of the webinar today.,