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DRUG MASTER FILES
1
Prepared by
Dr. Jigar Vyas
Professor
Sigma Institute of Pharmacy
1
CONTENTS:-
Introduction
Some basic terminologies.
Types of DMFS with their contents.
Submissions to drug master files
Authorization to refer to a drug master file
Processing and reviewing policies
Holder obligations
Major reorganization of a drug master file
Closure of a drug master file
2
2
DRUG MASTER FILES
A Drug Master File (DMF) is a submission to the FDA of
information, usually concerning the confidential detailed
information about Chemistry, Manufacturing and Controls
(CMC) of a drug product or a component of a drug Product.
Other non CMC – information (like packaging, storing)
may also be filed in a DMF.
3
I. Introduction
3
TYPES OF DMFS
Originally Five Types…
I Plant information
and material used in
II Drug substance, drug product, intermediates
their manufacturing.
III. Packaging
IV. Excipients.
V. Other information which is generally not covered by type I to type
IV drug master files.
(Usually clinical, toxicity data are covered.)
4
4
CURRENT TYPES OF DMFS
Now Four Types:
TYPE I DMF WITHDRAWN.
(Numbering retained to avoid confusion)
II.Drug substance, drug product, intermediates and material used
in their manufacturing.
III.Packaging IV Excipients
V Other information which is generally not coverd by type I to
type IV drug master files. 5
5
RATE OF DMF FILING AS OF MARCH 2007
6
6
WHO MUST FILE ADMF?
7
NOBODY
There is no legal or regulatory requirement
to file a DMF. A DMF may be filed to
provide CMC information that the FDA
reviews.
The information contained in DMF may be
used to support an IND / NDA /ANDA
,another DMF,an export application or
amendments and supplements of any of
these.
Remember that,
DMF is NOT a substitute for IND / NDA /
ANDA or export application.
review of IND /NDA /ANDA or an export application.
7
II. SOME BASIC TERMINOLOGIES
HOLDER: The person /company who submits DMF.
AGENT : The person / company who represents a DMF HOLDER. (Also called
Representative.)
APPLICANT / CUSTOMER / AUTHORISED PARTY (AP ) :The person / company
who references the DMF.
APPLICATION:Investigational New Drug Application (IND), New Drug Application
(NDA), Abbreviated New Drug Application (ANDA)
SUPPLEMENT TO AN ANDA / NDA: A report of change in an approved ANDA /
NDA.
AMENDMENT TO AN APPLICATION: Additional information to… an existing IND,
a pending ANDA / NDA
a pending ANDA / NDAsupplement.
8
8
III. TYPES OF DMFS WITH THEIR
CONTENTS
Type I : plant information
Points included:
Manufacturing site Equipment capabilities Operational layout
Actual site address
A map showing its location with respect to the nearest city
Corporate headquarters
As per Jan. 12, 2000 FR notice : Elimination of Type I DMFs
done by July 10, 2000.
9
9
TYPE II DMF
10
CONTENTS:
(1)Drug Substance Intermediates, Drug Substances, and Material Used in Their
Preparation.
It Summarizes all significant steps in the manufacturing and controls of
the drug intermediate or substance.
Detailed guidance on what should be included in a Type II DMF for drug substances
and intermediates may be found in the following guidelines:
1.Guideline for Submitting Supporting Documentation in Drug
Applications for the Manufacture of Drug Substances.
2.Guideline for the Format and Content of the Chemistry, Manufacturing,
and Controls Section of an Application.
10
(2) Drug Product (finished dosage forms)
11
Manufacturing procedures and
controls for finished dosage
forms
should
ordinarily be
submitted in an
IND, NDA,
ANDA, or
Export
Application.
If can not be
submitted to
above
documents
It should be submitted in a DMF
11
For a drug product, the applicant/sponsor should follow
the guidance provided in the following guidelines:
1.Guideline for the Format and Content of the Chemistry,
Manufacturing, and Controls Section of an Application.
2.Guideline for Submitting Documentation for the
Manufacture of and Controls for Drug Products.
3.Guideline for Submitting Samples and Analytical Data for
Methods Validation.
12
12
GENERAL POINTS INCLUDED IN TYPE II DMF
13
Manufacturing Quality
Controls
Validations Stability
data
Impurities Packaging &
Labeling
Inputs Finished Drug
Substance
Raw
materials
Packaging
materials
(1) (2) (3) (4) (5) (6)
Section
a. b. c.
a.1
Intermediates
a.2 & In-process
13
TYPE III: PACKAGING MATERIAL
Contents:-
Packaging material intended for which use.
Its components and composition.
Names of the suppliers or fabricators of the components
used in preparing the packaging material.
Acceptance specifications.
Toxicological data on these materials.
 FOLLOW THE GUIDELINE: "Guideline for Submitting
Documentation for Packaging for Human Drugs and Biologics."
14
14
BUT REMEMBER THAT,
Responsibility for compatibility and safety of packaging components
in finished drug product is the responsibility of the AUTHORISED
PARTY(AP).
It is not the responsibility of DMF HOLDER.
15
15
EXCIPIENTS
 CMC for a compendial excipient is usually not
reviewed and therefore a DMF is not necessary.
 Exceptions: New route of administration or total
dosing that may affect safety and efficacy.
E.G..RESPITOSE, lactose for dry powder inhalation
products.
 CMC requirements for a novel excipient should be
submitted same as type II DMF.
16
16
TYPE V DMF
FDA discourages the use of Type V DMFs for
miscellaneous information, duplicate information, or
information that should be included in one of the other
types of DMFs.
TO SUBMIT THE DATA
WHICH IS NOT COVERED
IN TYPE I TO IV DMF
(CLINICAL / TOXICITY DATA)
A holder
must first submit
a letter of intent
to the drug master file staff
FDA will then contact the
holder to discuss the17
proposed submission.
17
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DRUG MASTER FILES
 Holder sends the DMF (NO FEE two copies) to Central
Document Room
Center for Drug Evaluation and Research 5901-B
Ammendale Road
Beltsville, MD 20705-1266
 Containing:
1 – Transmittal (cover) letter
2 – Administrative information 3 – Technical
information
Follow the Guideline at www.fda.gov/cder/guidance/dmf.htm
Binders recommended
http://www.fda.gov/cder/ddms/binders.htm18
NEW ADDRESS
18
1. TRANSMITTAL (COVER) LETTER
19
Original Submissions and Amendments
Identification of submission.
(Original /supportive to original DMF / Amendment)
Type of DMF and subject (update, revised formula, or revised
process)
The name and address of each sponsor, applicant, or holder, and
all relevant document numbers.
Signature of the holder or the authorized representative.
 Typewritten name and title of thesigner
19
2. ADMINISTRATIVE INFORMATION
Original Submissions:
a. Names and addresses of the following:
(1)DMF holder.
(2)Corporate headquarters.
(3)Manufacturing/processing facility.
(4)Contact for FDA correspondence.
(5)Agent(s), if any.
b.The specific responsibilities of each person listed in any of the categories in
Section a.
c.Statement of commitment.
A signed statement by the holder certifying that the DMF is current and that the
DMF holder will comply with the statements made in it.
20
20
2 – ADMINISTRATIVE INFORMATION
21
Amendments
a.Name of DMF holder.
b.DMF number.
c.Name and address for correspondence.
d.Affected section and/or page numbers of the DMF.
e.The name and address of each person whose IND, NDA, ANDA, DMF, or
Export Application relies on the subject of the amendment for support.
f.The number of each IND, NDA, ANDA, DMF, and Export Application that
relies on the subject of the amendment for support, if known.
g. Particular items within the IND, NDA, ANDA, DMF, and Export
Application that are affected, if known.
21
DMF reviewed for administrative purposes ONLY
by Central Document Room (CDR) staff.
DMF entered into DMF DATABASE, assigned a
number, and a letter sent to the HOLDER.
If no response from FDA side,…
DMF HOLDER can put a query on the e-mail:
dmfquestion@cder.fda.gov
22
22
Letter sent by FDA to DMF HOLDER consists of …
• Number given to DMF in database and Type.
• Reminder of obligations (responsibilities) of holder :
–Submit all changes as amendments.
–Notify FDA of change in holder name or address.
–Notify FDA of change in agent/representative.
–SUBMIT ANNUAL UPDATE (Annual Report).
–Submit Letter of Authorization (LOA) for each item
referenced.
23
23
LETTER OF AUTHORIZATION (LOA)
The DMF will be reviewed ONLY when it is referenced in an Application or
another DMF.
24
DMF HOLDER
US FDA Send a letter to
remind holder
obligations
Send 2 copies of LOA to the FD A
1 copy of LOA to the APPLICANT
The applicant submits THIS copy
of LOA in their Application.
24
IMPORTANCE OF LOA
 Sending LOA is the only mechanism which triggers the review
procedure of DMF.
 A letter of authorization permits the FDA to reference the
DMF.
 If the holder cross references its own DMF, the holder should
supply following information in a LOA.
-DMF number
-Specific product(s) covered by the DMF
-Section numbers and/or page numbers to be referenced
In Europe, the permission to reference a DMF is called a Letter of
Access. 25
25
REVIEW OF THE DMF
REVIEWER
When reviewer receives an application
(IND/NDA/ANDA) that
references a DMF
Requests the DMF from
the CDR (central document room)
but Delivery of DMF
can take a couple of days.
This review procedure of DMF
is in Contrast with
APPLICATION, where
document is delivered
automatically to reviewer.
26
Next slide
26
27
After getting DMF,the
Reviewer starts the
review procedure
If Reviewer found
any deficiency in the
content of DMF,
The DETAILED DEFICIENCIES
are communicated to the holder.
The APPLICANT is also notified
but, the nature of the deficiencies is
not communicated to the applicant.
If no deficiencies, no letter, applicant not notified.
HOLDER should submit the
REQUESTED INFORMATION to
the DMF in response to the
agency's
deficiency letter along with
transmittal letter having subject
matter.
27
28
Differences between Applications
and DMFs
28
Applications DMFs
1. COMES UNDER REGULATORY
STATUS.MUST BE FILED BY
APPLICANT.
1.NOT COME UNDER REGULATORY
STATUS.IT IS NOT MANDATORY
TO FILE A DMF.
2. EACH APPLICATION AND ITS
SUPPLEMENT ARE ENTERED
INTO A COMMON DATABASE.
2. DMFs ARE ENTERED IN TO
DATABASE AS PER THEIR TYPES.
(SEPARATE DATABASE FOR EACH
TYPE OF DMF)
3.SUBMITTED TO A PARTICULAR
REVIEW DIVISION.
3.SUBMITTED TO CDR.
4. ASSIGNMENT TO A REVIEWERAND
EACH SUBMISSION HAS A DUE DATE.
4.NO ASSIGNMENT TO A REVIEWER,
NO DUE DATE.
5.REVIEW PROCEDURE QUITE
DIFFERENT THAN DMF.
5.DMFs ARE REVIEWED ONLY WHEN
REFERENCED BY APPLICATION
OR ANOTHER DMF
6.IF THE ANNIVERSARY DATE FOR
ANNUAL UPDATE IS MISSED
F2D9A WILL NOT SEND A
REMINDER.
6.IF THE ANNIVERSARY DATE FOR
ANNUAL UPDATE IS MISSED FDA
SENDS A REMINDER.
29
ANNUAL UPDATE OF DMF
 The holder should provide an annual report on the
anniversary date of the original submission.
 If the subject matter of the DMF is unchanged, the DMF
holder should provide a statement that the subject matter
of the DMF is current.
 Failure to update can cause delays in FDA review of a
pending IND, NDA, ANDA or any amendment or
supplement to such application; and FDA can initiate
procedures for closure of the DMF.
30
30
RETIRING DMFS
If a DMF has no activity (amendment or
annual report) in three years FDA will initiate
retirement procedure.
Note: LOA is not counted for activity.
31
31
DMF RETIREMENT PROCEDURE
 FDA sends overdue notice letter (ONL) to holder and/or
agent using most recent address.
 If no response in 90 days, one copy of DMF is sent to
Federal Records Center (FRC) and the other is
destroyed.
32
32
CHANGES IN DMF SYSTEM
 Over the past decade, there have been some changes in
the DMF system to help make it work better.
 However some things remain the same.
33
33
CHANGES IN THE DMF
SYSTEM AND PROCEDURES
(INTERNAL)
Creation of Review Cover Form
Creation of Type II Review Format
Implementation of Re-review Policy
Creation of Central Review File
Revision of Database View
34
34
CHANGES IN THE DMF SYSTEM AND
PROCEDURES (EXTERNAL)
 Elimination of Type I DMFs
 Post-Approval Changes Guidance and
 Creation of DMF List Website
 Creation of DMFQUESTION
 Establish Position of DMF Expert 35
35
UNCHANGED THINGS OF DMF
 No review of DMFon receipt of it.
 Review only when referenced in application.
 All of the DMF is still confidential.
 DMFs are neither approved nor disapproved.
 The holder still has the responsibility to notify
customer of changes.
36
36
SUMMARY
 The DMF system presents challenges for both the
industry and the FDA.
 Some of the changes have made the system
smoother
(hopefully for both industry and FDA).
 Problems can be minimized:
–With full understanding of their responsibilities and adherence
to Guidances on the part of holders and applicants.
–With adherence to policies and procedures on the part of
reviewers.
37
37
NOW,…
WHAT EUROPEAN DRUG MASTER FILE
PROCEDURE FOR ACTIVE SUBSTANCES SAYS
ABOUT THE DMF…
39
CONTENT OF DRUG MASTER FILE
APPLICANT’S PART OF DMF
F
ASM RESTRICTED PART OF DM
2
PARTS
OPEN PART CLOSED PART
38
APPLICANT’S PART OF DMF
OPEN PART
( AVAILABLE TO APPLICANT)
40
ACTIVE SUBSTANCE
MANUFACTURER
SUPPLIES INFORMATION
TO THE APPLICANT
THIS INFORMATION INCLUDES:
-outline of the manufacturing method
-impurities originating from the manufacturing method,
isolation procedure and degradation
-information on the toxicity of specific impurities
39
 The applicant’s part of a DMF is provided by the ASM to the
applicant directly and becomes part of the application for
marketing authorization.
 The applicant’s part of the DMF is still a confidential
document which cannot be submitted to third parties without
the written agreement of the ASM.
41
40
ASM RESTRICTED PART OF
42
DMF
CLOSED PART
( NOT AVAILABLE TO THE APPLICANT)
IT INCLUDES:
Detailed information about…
Individual steps of the manufacturing method such
as reaction conditions, temperature,
Validation and evaluation data for certain critical
steps of the manufacturing method,etc.
Such information is supplied to the authorities only.
41
43
42

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Drug Master Files Guide

  • 1. DRUG MASTER FILES 1 Prepared by Dr. Jigar Vyas Professor Sigma Institute of Pharmacy 1
  • 2. CONTENTS:- Introduction Some basic terminologies. Types of DMFS with their contents. Submissions to drug master files Authorization to refer to a drug master file Processing and reviewing policies Holder obligations Major reorganization of a drug master file Closure of a drug master file 2 2
  • 3. DRUG MASTER FILES A Drug Master File (DMF) is a submission to the FDA of information, usually concerning the confidential detailed information about Chemistry, Manufacturing and Controls (CMC) of a drug product or a component of a drug Product. Other non CMC – information (like packaging, storing) may also be filed in a DMF. 3 I. Introduction 3
  • 4. TYPES OF DMFS Originally Five Types… I Plant information and material used in II Drug substance, drug product, intermediates their manufacturing. III. Packaging IV. Excipients. V. Other information which is generally not covered by type I to type IV drug master files. (Usually clinical, toxicity data are covered.) 4 4
  • 5. CURRENT TYPES OF DMFS Now Four Types: TYPE I DMF WITHDRAWN. (Numbering retained to avoid confusion) II.Drug substance, drug product, intermediates and material used in their manufacturing. III.Packaging IV Excipients V Other information which is generally not coverd by type I to type IV drug master files. 5 5
  • 6. RATE OF DMF FILING AS OF MARCH 2007 6 6
  • 7. WHO MUST FILE ADMF? 7 NOBODY There is no legal or regulatory requirement to file a DMF. A DMF may be filed to provide CMC information that the FDA reviews. The information contained in DMF may be used to support an IND / NDA /ANDA ,another DMF,an export application or amendments and supplements of any of these. Remember that, DMF is NOT a substitute for IND / NDA / ANDA or export application. review of IND /NDA /ANDA or an export application. 7
  • 8. II. SOME BASIC TERMINOLOGIES HOLDER: The person /company who submits DMF. AGENT : The person / company who represents a DMF HOLDER. (Also called Representative.) APPLICANT / CUSTOMER / AUTHORISED PARTY (AP ) :The person / company who references the DMF. APPLICATION:Investigational New Drug Application (IND), New Drug Application (NDA), Abbreviated New Drug Application (ANDA) SUPPLEMENT TO AN ANDA / NDA: A report of change in an approved ANDA / NDA. AMENDMENT TO AN APPLICATION: Additional information to… an existing IND, a pending ANDA / NDA a pending ANDA / NDAsupplement. 8 8
  • 9. III. TYPES OF DMFS WITH THEIR CONTENTS Type I : plant information Points included: Manufacturing site Equipment capabilities Operational layout Actual site address A map showing its location with respect to the nearest city Corporate headquarters As per Jan. 12, 2000 FR notice : Elimination of Type I DMFs done by July 10, 2000. 9 9
  • 10. TYPE II DMF 10 CONTENTS: (1)Drug Substance Intermediates, Drug Substances, and Material Used in Their Preparation. It Summarizes all significant steps in the manufacturing and controls of the drug intermediate or substance. Detailed guidance on what should be included in a Type II DMF for drug substances and intermediates may be found in the following guidelines: 1.Guideline for Submitting Supporting Documentation in Drug Applications for the Manufacture of Drug Substances. 2.Guideline for the Format and Content of the Chemistry, Manufacturing, and Controls Section of an Application. 10
  • 11. (2) Drug Product (finished dosage forms) 11 Manufacturing procedures and controls for finished dosage forms should ordinarily be submitted in an IND, NDA, ANDA, or Export Application. If can not be submitted to above documents It should be submitted in a DMF 11
  • 12. For a drug product, the applicant/sponsor should follow the guidance provided in the following guidelines: 1.Guideline for the Format and Content of the Chemistry, Manufacturing, and Controls Section of an Application. 2.Guideline for Submitting Documentation for the Manufacture of and Controls for Drug Products. 3.Guideline for Submitting Samples and Analytical Data for Methods Validation. 12 12
  • 13. GENERAL POINTS INCLUDED IN TYPE II DMF 13 Manufacturing Quality Controls Validations Stability data Impurities Packaging & Labeling Inputs Finished Drug Substance Raw materials Packaging materials (1) (2) (3) (4) (5) (6) Section a. b. c. a.1 Intermediates a.2 & In-process 13
  • 14. TYPE III: PACKAGING MATERIAL Contents:- Packaging material intended for which use. Its components and composition. Names of the suppliers or fabricators of the components used in preparing the packaging material. Acceptance specifications. Toxicological data on these materials.  FOLLOW THE GUIDELINE: "Guideline for Submitting Documentation for Packaging for Human Drugs and Biologics." 14 14
  • 15. BUT REMEMBER THAT, Responsibility for compatibility and safety of packaging components in finished drug product is the responsibility of the AUTHORISED PARTY(AP). It is not the responsibility of DMF HOLDER. 15 15
  • 16. EXCIPIENTS  CMC for a compendial excipient is usually not reviewed and therefore a DMF is not necessary.  Exceptions: New route of administration or total dosing that may affect safety and efficacy. E.G..RESPITOSE, lactose for dry powder inhalation products.  CMC requirements for a novel excipient should be submitted same as type II DMF. 16 16
  • 17. TYPE V DMF FDA discourages the use of Type V DMFs for miscellaneous information, duplicate information, or information that should be included in one of the other types of DMFs. TO SUBMIT THE DATA WHICH IS NOT COVERED IN TYPE I TO IV DMF (CLINICAL / TOXICITY DATA) A holder must first submit a letter of intent to the drug master file staff FDA will then contact the holder to discuss the17 proposed submission. 17
  • 18. I V H . o S w U t h B e M S y I S s t S e I m O W N o S r k O s F ? DRUG MASTER FILES  Holder sends the DMF (NO FEE two copies) to Central Document Room Center for Drug Evaluation and Research 5901-B Ammendale Road Beltsville, MD 20705-1266  Containing: 1 – Transmittal (cover) letter 2 – Administrative information 3 – Technical information Follow the Guideline at www.fda.gov/cder/guidance/dmf.htm Binders recommended http://www.fda.gov/cder/ddms/binders.htm18 NEW ADDRESS 18
  • 19. 1. TRANSMITTAL (COVER) LETTER 19 Original Submissions and Amendments Identification of submission. (Original /supportive to original DMF / Amendment) Type of DMF and subject (update, revised formula, or revised process) The name and address of each sponsor, applicant, or holder, and all relevant document numbers. Signature of the holder or the authorized representative.  Typewritten name and title of thesigner 19
  • 20. 2. ADMINISTRATIVE INFORMATION Original Submissions: a. Names and addresses of the following: (1)DMF holder. (2)Corporate headquarters. (3)Manufacturing/processing facility. (4)Contact for FDA correspondence. (5)Agent(s), if any. b.The specific responsibilities of each person listed in any of the categories in Section a. c.Statement of commitment. A signed statement by the holder certifying that the DMF is current and that the DMF holder will comply with the statements made in it. 20 20
  • 21. 2 – ADMINISTRATIVE INFORMATION 21 Amendments a.Name of DMF holder. b.DMF number. c.Name and address for correspondence. d.Affected section and/or page numbers of the DMF. e.The name and address of each person whose IND, NDA, ANDA, DMF, or Export Application relies on the subject of the amendment for support. f.The number of each IND, NDA, ANDA, DMF, and Export Application that relies on the subject of the amendment for support, if known. g. Particular items within the IND, NDA, ANDA, DMF, and Export Application that are affected, if known. 21
  • 22. DMF reviewed for administrative purposes ONLY by Central Document Room (CDR) staff. DMF entered into DMF DATABASE, assigned a number, and a letter sent to the HOLDER. If no response from FDA side,… DMF HOLDER can put a query on the e-mail: dmfquestion@cder.fda.gov 22 22
  • 23. Letter sent by FDA to DMF HOLDER consists of … • Number given to DMF in database and Type. • Reminder of obligations (responsibilities) of holder : –Submit all changes as amendments. –Notify FDA of change in holder name or address. –Notify FDA of change in agent/representative. –SUBMIT ANNUAL UPDATE (Annual Report). –Submit Letter of Authorization (LOA) for each item referenced. 23 23
  • 24. LETTER OF AUTHORIZATION (LOA) The DMF will be reviewed ONLY when it is referenced in an Application or another DMF. 24 DMF HOLDER US FDA Send a letter to remind holder obligations Send 2 copies of LOA to the FD A 1 copy of LOA to the APPLICANT The applicant submits THIS copy of LOA in their Application. 24
  • 25. IMPORTANCE OF LOA  Sending LOA is the only mechanism which triggers the review procedure of DMF.  A letter of authorization permits the FDA to reference the DMF.  If the holder cross references its own DMF, the holder should supply following information in a LOA. -DMF number -Specific product(s) covered by the DMF -Section numbers and/or page numbers to be referenced In Europe, the permission to reference a DMF is called a Letter of Access. 25 25
  • 26. REVIEW OF THE DMF REVIEWER When reviewer receives an application (IND/NDA/ANDA) that references a DMF Requests the DMF from the CDR (central document room) but Delivery of DMF can take a couple of days. This review procedure of DMF is in Contrast with APPLICATION, where document is delivered automatically to reviewer. 26 Next slide 26
  • 27. 27 After getting DMF,the Reviewer starts the review procedure If Reviewer found any deficiency in the content of DMF, The DETAILED DEFICIENCIES are communicated to the holder. The APPLICANT is also notified but, the nature of the deficiencies is not communicated to the applicant. If no deficiencies, no letter, applicant not notified. HOLDER should submit the REQUESTED INFORMATION to the DMF in response to the agency's deficiency letter along with transmittal letter having subject matter. 27
  • 29. Applications DMFs 1. COMES UNDER REGULATORY STATUS.MUST BE FILED BY APPLICANT. 1.NOT COME UNDER REGULATORY STATUS.IT IS NOT MANDATORY TO FILE A DMF. 2. EACH APPLICATION AND ITS SUPPLEMENT ARE ENTERED INTO A COMMON DATABASE. 2. DMFs ARE ENTERED IN TO DATABASE AS PER THEIR TYPES. (SEPARATE DATABASE FOR EACH TYPE OF DMF) 3.SUBMITTED TO A PARTICULAR REVIEW DIVISION. 3.SUBMITTED TO CDR. 4. ASSIGNMENT TO A REVIEWERAND EACH SUBMISSION HAS A DUE DATE. 4.NO ASSIGNMENT TO A REVIEWER, NO DUE DATE. 5.REVIEW PROCEDURE QUITE DIFFERENT THAN DMF. 5.DMFs ARE REVIEWED ONLY WHEN REFERENCED BY APPLICATION OR ANOTHER DMF 6.IF THE ANNIVERSARY DATE FOR ANNUAL UPDATE IS MISSED F2D9A WILL NOT SEND A REMINDER. 6.IF THE ANNIVERSARY DATE FOR ANNUAL UPDATE IS MISSED FDA SENDS A REMINDER. 29
  • 30. ANNUAL UPDATE OF DMF  The holder should provide an annual report on the anniversary date of the original submission.  If the subject matter of the DMF is unchanged, the DMF holder should provide a statement that the subject matter of the DMF is current.  Failure to update can cause delays in FDA review of a pending IND, NDA, ANDA or any amendment or supplement to such application; and FDA can initiate procedures for closure of the DMF. 30 30
  • 31. RETIRING DMFS If a DMF has no activity (amendment or annual report) in three years FDA will initiate retirement procedure. Note: LOA is not counted for activity. 31 31
  • 32. DMF RETIREMENT PROCEDURE  FDA sends overdue notice letter (ONL) to holder and/or agent using most recent address.  If no response in 90 days, one copy of DMF is sent to Federal Records Center (FRC) and the other is destroyed. 32 32
  • 33. CHANGES IN DMF SYSTEM  Over the past decade, there have been some changes in the DMF system to help make it work better.  However some things remain the same. 33 33
  • 34. CHANGES IN THE DMF SYSTEM AND PROCEDURES (INTERNAL) Creation of Review Cover Form Creation of Type II Review Format Implementation of Re-review Policy Creation of Central Review File Revision of Database View 34 34
  • 35. CHANGES IN THE DMF SYSTEM AND PROCEDURES (EXTERNAL)  Elimination of Type I DMFs  Post-Approval Changes Guidance and  Creation of DMF List Website  Creation of DMFQUESTION  Establish Position of DMF Expert 35 35
  • 36. UNCHANGED THINGS OF DMF  No review of DMFon receipt of it.  Review only when referenced in application.  All of the DMF is still confidential.  DMFs are neither approved nor disapproved.  The holder still has the responsibility to notify customer of changes. 36 36
  • 37. SUMMARY  The DMF system presents challenges for both the industry and the FDA.  Some of the changes have made the system smoother (hopefully for both industry and FDA).  Problems can be minimized: –With full understanding of their responsibilities and adherence to Guidances on the part of holders and applicants. –With adherence to policies and procedures on the part of reviewers. 37 37
  • 38. NOW,… WHAT EUROPEAN DRUG MASTER FILE PROCEDURE FOR ACTIVE SUBSTANCES SAYS ABOUT THE DMF… 39 CONTENT OF DRUG MASTER FILE APPLICANT’S PART OF DMF F ASM RESTRICTED PART OF DM 2 PARTS OPEN PART CLOSED PART 38
  • 39. APPLICANT’S PART OF DMF OPEN PART ( AVAILABLE TO APPLICANT) 40 ACTIVE SUBSTANCE MANUFACTURER SUPPLIES INFORMATION TO THE APPLICANT THIS INFORMATION INCLUDES: -outline of the manufacturing method -impurities originating from the manufacturing method, isolation procedure and degradation -information on the toxicity of specific impurities 39
  • 40.  The applicant’s part of a DMF is provided by the ASM to the applicant directly and becomes part of the application for marketing authorization.  The applicant’s part of the DMF is still a confidential document which cannot be submitted to third parties without the written agreement of the ASM. 41 40
  • 41. ASM RESTRICTED PART OF 42 DMF CLOSED PART ( NOT AVAILABLE TO THE APPLICANT) IT INCLUDES: Detailed information about… Individual steps of the manufacturing method such as reaction conditions, temperature, Validation and evaluation data for certain critical steps of the manufacturing method,etc. Such information is supplied to the authorities only. 41
  • 42. 43 42