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Pharmaceutical Registration In India
       DIA – Training Course
           Surya Chitra, Savio Group Inc
      Sunder Venkatraman, Asian Clinical Trials
Regulations in India


Central Governments        State Governments
 Statutory Functions       Statutory Functions
Major Regulatory Bodies


DCGI: Drugs Controller General of India

DGFT: Directorate-General of Foreign Trade

DBT:Department of Biotechnology

GEAC: Genetic Engineering Approval Committee

RDAC: Recombinant DNA Advisory Committee

IBSC: Institutional Biological Safety Committees

RCGM: Review Committee on Genetic Manipulation
State Government Statutory Functions

  Licensing of Drug testing labs
  Approval of drug formulations for manufacture
  Monitoring for quality of drugs and cosmetics, manufactured by
      respective states units and those marketed in India
  Recall of substandard drugs
  Investigation and prosecution in respect to contravention of legal
       provisions
  Pre and Post licensing inspection

  Administrative actions
Central Government Statutory Functions



 Approve licenses to manufacture certain categories of drug as Central
       License Approving
 Regulate CR in India
 Establish regulatory measures, amendments to acts and rules
 Screening drug Formulations available in Indian Market
 Regulate MA of new drug
 Regulate the standards of imported drugs
 Conduct training programs for regulatory officials and catalyst In India
 Publication of Indian Pharmacopoeia
The Regulatory Affairs Organization Chart

                                            National Government



            Ministry of health and                                    Ministry of Chemicals &
                    welfare                 Ministry of Environment       Petrochemicals




                                                   GEAC                                         DCP
                                                                      NPPA
Central Drug Standard&
 Control Organization


                         Drug Controller
                         General of India




           HQ                          Zonal Offices
Beyond Guidelines


   Trial can be initiated only after
permission from Licensing Authority
and approval from ethics committee.
Drug Registration and Biologics/Pharmaceuticals
                        in India


Drugs are registered with DCGI( Drug Controller
General of India) which is the main regulatory
body.
Clinical Research Guidelines/Regulations in India

   Drugs & Cosmetics Act & Rules (Schedule Y1988)
   GCP Guidelines, 2001
   National Pharmacovigilance Programme, 2004

   Schedule Y, 2005
   ICMR Guidelines, 2000 (being revised)
New Regulations Governing Clinical Research in
                   India

    In keeping with

  Global regulatory standards
 India specific cultural, social, political and administrative
     condition
Sponsor’s Responsibilities

Protocol
Reporting timelines
Adequate Training
Sponsor’s Study team, Investigators team
Resources /Infrastructure
Insurance/Expenses for medical management of AEs
Monitoring
Sponsor’s Responsibilities

Compilation /Evaluation of safety reports

Dissemination

    •Information (AEs /Safety Updates/ PSURs)

    •All concerned parties (Regulators/ Investigators/ Ecs)

Generate “Investigator Notifications” when required

Generate periodic safety update reviews and submit to DCGI
Investigator’s responsibilities

Understand Protocol requirements
Training of his team members
Provision of necessary resources & infrastructure
Monitor, capture & documents ALL AEs
Medical care including follow up AE
Report to sponsor and IEC
Archives
Responsibilities of Ethics Committees and
                        DSMBs
ECs

  Review: safeguard rights, safety and well-being of participant
  Monitor: SAE reports, annual reports, project reports


DSMBs

  Ongoing Review
Schedule Y(2005 Amendment) -Statute

Guidelines:
    Declaration of Helsinki
    ICH-E6 GCP Guidelines
    ICMR Guidelines
Schedule Y


Ethics Committee
– Composition, quorum prescribed
– SOPs mandatory
– Amendment approvals
– Review of agreements
– Approval format prescribed
(http:// www.cdsco.nic.in)
Ethical Issues

Freely given, informed, written consent in
  prescribed form Appendix V

Constitution, quorum and approval    format
  as per Appendix VIII
Provisions for Using Independent EC


Investigators may accept Approval granted
by EC of another site or approval granted by
an independent ethics committee
Sponsors

Roles and Responsibilities
PSUR mandatory
Protocol Format (Appendix X)
Report format (Appendix II)
Reporting Timelines specified: Unexpected SAEs within14
  days to DCGI and other investigators
Stability testing
Investigators

Training/Qualifications
Investigators to document SOPs for all tasks performed by
   them
Responsible for conduct of trial according to protocol and GCP
Compliance as per undertaking
Medical care for AEs
SAE reporting to EC (7days) and Sponsor (24hrs)
Informed consent
PSURs


6 monthly for 2 years; annually for 2 years
Within 30 calendar days
Different dosage forms/formulations/ indications in one report
New studies planned for safety to be described
Pharmacovigilance in India

1998:
•India established national centre at AIIMS
•Joined Uppsala programme
•WHO Special Centre at KEM Hospital
2004:
•National Pharmacovigilance Programme launched
     on 23rd November 2004
National Pharmacovigilance Advisory Committee



  Advisory Committee to Government
  16 members
  Supervise activities of National Pvig Program
Protocol Amendments
    Amendments which do not require notification or permission of the Licensing
    Authority

        Administrative and logistic changes,
        Minor protocol amendment and additional safety assessments


    Amendments which require notification to Licensing Authority, but sponsor need
    not wait for permission.

         Additional investigator sites,
        Change in investigator, with the consent to withdraw from the earlier
        investigator.,
        Amended IB or ICF

•   Amendments which require prior permission of the Licensing Authority

        Additional Patients to be recruited
        Major changes in protocol with respect to study design, dose and treatment .
        Any change in inclusion/exclusion criteria
Global Clinical Trials are classified into 2 categories:

           Category A:                                Category B:


   It includes clinical trials whose
                                        It includes clinical trials whose protocols
  protocols have been approved by
                                        have been approved in other countries
       USA, UK, Switzerland,
                                           which are not listed in category A.
    Australia, Canada,Germany,
                                        The regulatory (DCGI) turnaround time
 South Africa, Japan or the EMEA.
                                                 for these applications
The regulatory (DCGI) will reach to a
                                                   will be 8-12 weeks.
  decision whether to approve the
        trial within 2-4 weeks.
Advances in Schedule Y

Removal of Phase Lag
Statutory support of GCP & GLP Conversion of EC,
   Sponsor, Investigator responsibilities to legal
   requirements
Uniform processes for submission and approval of EC
   documents and Informed Consent
Reinforcement of pharmacovigilance through Phase IV
   studies, SAE reporting, PSUR etc
Future directions


   Implementation of Schedule Y
    GCP: Shared responsibility amongst
different stakeholders in clinical trials
   Need for imparting training to all the
    players
Drugs and Cosmetics Act 1945
  Rule       Permission for

                  Import
   122 A

             Manufacture [except drugs
   122 B
             under schedule C and C(1)]
              Fixed dose combination
   122 D

                Clinical trial
  122 DA

              CT definition
  122 DAA

   122 E    New drug definition
122 E: New drug definition

   Not used in the country

   Approved drug : 1. New claims
                 (Indications, dosage, dosage form, route)
               2. FDCs (New / Modified

   All Vaccines are considered New drugs unless certified
        by Licensing Authority under Rule 21

   A New drug is considered new for the period of 4 years
from the date f its first approval or the date it is included in the
Indian Pharmacopoeia, whichever is earlier
Intent to conduct Phase I*,II or III Pharmaceutical product or Medical
                     Device Clinical Trial in India



                                                        Parallel submission to
                               Determine if
                                                          Ethics Committee
                           Submission to be made
                              under Category
                                  A or B




                          In Case Central lab outside           Category B
Category A
                                  India used




         Note: fill aayat niryath form according to category A or B
In case of category A
                                    Category A
        Clinical trial already approved by other regulatory agencies (US-FDA,
        MRHA etc. as defined in the MoM-DCG(I) Oct-06) and approval letters
                                      are available


                                                          NOC received from
 Application compiled
                                                                  DCG(I)
   per checklist on
                                    APPROVED                if trial approved
  CDSCO website
                                                           (Internal process)
                                                                                         Export
                                                                                         license
Application made to DCGI
                                                                                        received
 for approval in form 44                 Resubmit             Apply to Jt.DGFT
                                                                                          Within
 & import license in                     Application     of the respective city/state
                                                                                         2 weeks
form 12; fees paid                                            with cover letter &
                                                           NOC from DGFT Delhi


Application evaluated for
                                       REJECTED             DGFT (Delhi)
Completeness if found appropriate
                                                            Approval received
approval normally granted in
                                                            within 4-6 weeks
4-6 weeks
In case of category B

                                   Determine if
                               Submission to be made
                                  under Category
                                      A or B
                                                         NOC received from DCG(I)
                                                             if trial approved
            Category B
                                                            (Internal process)



      If study approvals                                      DGFT (Delhi)
  as required for Category A                             approval received within
       are not available                                       4-6 weeks




    Application compiled                                       Apply to Jt.DGFT
    per attached appendix                                 of the respective city/state
                                                               with cover letter &
                                                            NOC from DGFT Delhi
                                 Application evaluated
                                  If found appropriate
Application made to DCGI
                                   approval normally
for approval in form 44 &
                                 granted in 8-12 weeks
Import license in form 12;                                   Export license received
  fees paid as required.                                         within 2 weeks
Medical Device guidelines



   Medical Device guidelines amended in Mar. 1, 2006
       bringing discipline to medical devices sector


    The newly included “drugs” are Cardiac stents, drug
eluting stents, catheters, intraocular lenses, IV Cannulae,
Bone cements, heart valves, scalp vein set, orthopedic
implants and internal prosthetic replacements.
Recombitant Pharma guidelines



New guidelines have been introduced on Recombitant
  Pharma.

There Approval bodies is DCGI but there are asissting
   bodies like GEAC, RCGM, IBSC.
Pharmaceutical Registration and Clinical Trial Regulations in India

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Pharmaceutical Registration and Clinical Trial Regulations in India

  • 1. Pharmaceutical Registration In India DIA – Training Course Surya Chitra, Savio Group Inc Sunder Venkatraman, Asian Clinical Trials
  • 2. Regulations in India Central Governments State Governments Statutory Functions Statutory Functions
  • 3. Major Regulatory Bodies DCGI: Drugs Controller General of India DGFT: Directorate-General of Foreign Trade DBT:Department of Biotechnology GEAC: Genetic Engineering Approval Committee RDAC: Recombinant DNA Advisory Committee IBSC: Institutional Biological Safety Committees RCGM: Review Committee on Genetic Manipulation
  • 4. State Government Statutory Functions Licensing of Drug testing labs Approval of drug formulations for manufacture Monitoring for quality of drugs and cosmetics, manufactured by respective states units and those marketed in India Recall of substandard drugs Investigation and prosecution in respect to contravention of legal provisions Pre and Post licensing inspection Administrative actions
  • 5. Central Government Statutory Functions Approve licenses to manufacture certain categories of drug as Central License Approving Regulate CR in India Establish regulatory measures, amendments to acts and rules Screening drug Formulations available in Indian Market Regulate MA of new drug Regulate the standards of imported drugs Conduct training programs for regulatory officials and catalyst In India Publication of Indian Pharmacopoeia
  • 6. The Regulatory Affairs Organization Chart National Government Ministry of health and Ministry of Chemicals & welfare Ministry of Environment Petrochemicals GEAC DCP NPPA Central Drug Standard& Control Organization Drug Controller General of India HQ Zonal Offices
  • 7. Beyond Guidelines Trial can be initiated only after permission from Licensing Authority and approval from ethics committee.
  • 8. Drug Registration and Biologics/Pharmaceuticals in India Drugs are registered with DCGI( Drug Controller General of India) which is the main regulatory body.
  • 9. Clinical Research Guidelines/Regulations in India Drugs & Cosmetics Act & Rules (Schedule Y1988) GCP Guidelines, 2001 National Pharmacovigilance Programme, 2004 Schedule Y, 2005 ICMR Guidelines, 2000 (being revised)
  • 10. New Regulations Governing Clinical Research in India In keeping with Global regulatory standards India specific cultural, social, political and administrative condition
  • 11. Sponsor’s Responsibilities Protocol Reporting timelines Adequate Training Sponsor’s Study team, Investigators team Resources /Infrastructure Insurance/Expenses for medical management of AEs Monitoring
  • 12. Sponsor’s Responsibilities Compilation /Evaluation of safety reports Dissemination •Information (AEs /Safety Updates/ PSURs) •All concerned parties (Regulators/ Investigators/ Ecs) Generate “Investigator Notifications” when required Generate periodic safety update reviews and submit to DCGI
  • 13. Investigator’s responsibilities Understand Protocol requirements Training of his team members Provision of necessary resources & infrastructure Monitor, capture & documents ALL AEs Medical care including follow up AE Report to sponsor and IEC Archives
  • 14. Responsibilities of Ethics Committees and DSMBs ECs Review: safeguard rights, safety and well-being of participant Monitor: SAE reports, annual reports, project reports DSMBs Ongoing Review
  • 15. Schedule Y(2005 Amendment) -Statute Guidelines: Declaration of Helsinki ICH-E6 GCP Guidelines ICMR Guidelines
  • 16. Schedule Y Ethics Committee – Composition, quorum prescribed – SOPs mandatory – Amendment approvals – Review of agreements – Approval format prescribed (http:// www.cdsco.nic.in)
  • 17. Ethical Issues Freely given, informed, written consent in prescribed form Appendix V Constitution, quorum and approval format as per Appendix VIII
  • 18. Provisions for Using Independent EC Investigators may accept Approval granted by EC of another site or approval granted by an independent ethics committee
  • 19. Sponsors Roles and Responsibilities PSUR mandatory Protocol Format (Appendix X) Report format (Appendix II) Reporting Timelines specified: Unexpected SAEs within14 days to DCGI and other investigators Stability testing
  • 20. Investigators Training/Qualifications Investigators to document SOPs for all tasks performed by them Responsible for conduct of trial according to protocol and GCP Compliance as per undertaking Medical care for AEs SAE reporting to EC (7days) and Sponsor (24hrs) Informed consent
  • 21. PSURs 6 monthly for 2 years; annually for 2 years Within 30 calendar days Different dosage forms/formulations/ indications in one report New studies planned for safety to be described
  • 22. Pharmacovigilance in India 1998: •India established national centre at AIIMS •Joined Uppsala programme •WHO Special Centre at KEM Hospital 2004: •National Pharmacovigilance Programme launched on 23rd November 2004
  • 23. National Pharmacovigilance Advisory Committee Advisory Committee to Government 16 members Supervise activities of National Pvig Program
  • 24. Protocol Amendments Amendments which do not require notification or permission of the Licensing Authority Administrative and logistic changes, Minor protocol amendment and additional safety assessments Amendments which require notification to Licensing Authority, but sponsor need not wait for permission. Additional investigator sites, Change in investigator, with the consent to withdraw from the earlier investigator., Amended IB or ICF • Amendments which require prior permission of the Licensing Authority Additional Patients to be recruited Major changes in protocol with respect to study design, dose and treatment . Any change in inclusion/exclusion criteria
  • 25. Global Clinical Trials are classified into 2 categories: Category A: Category B: It includes clinical trials whose It includes clinical trials whose protocols protocols have been approved by have been approved in other countries USA, UK, Switzerland, which are not listed in category A. Australia, Canada,Germany, The regulatory (DCGI) turnaround time South Africa, Japan or the EMEA. for these applications The regulatory (DCGI) will reach to a will be 8-12 weeks. decision whether to approve the trial within 2-4 weeks.
  • 26. Advances in Schedule Y Removal of Phase Lag Statutory support of GCP & GLP Conversion of EC, Sponsor, Investigator responsibilities to legal requirements Uniform processes for submission and approval of EC documents and Informed Consent Reinforcement of pharmacovigilance through Phase IV studies, SAE reporting, PSUR etc
  • 27. Future directions Implementation of Schedule Y GCP: Shared responsibility amongst different stakeholders in clinical trials Need for imparting training to all the players
  • 28. Drugs and Cosmetics Act 1945 Rule Permission for Import 122 A Manufacture [except drugs 122 B under schedule C and C(1)] Fixed dose combination 122 D Clinical trial 122 DA CT definition 122 DAA 122 E New drug definition
  • 29. 122 E: New drug definition Not used in the country Approved drug : 1. New claims (Indications, dosage, dosage form, route) 2. FDCs (New / Modified All Vaccines are considered New drugs unless certified by Licensing Authority under Rule 21 A New drug is considered new for the period of 4 years from the date f its first approval or the date it is included in the Indian Pharmacopoeia, whichever is earlier
  • 30. Intent to conduct Phase I*,II or III Pharmaceutical product or Medical Device Clinical Trial in India Parallel submission to Determine if Ethics Committee Submission to be made under Category A or B In Case Central lab outside Category B Category A India used Note: fill aayat niryath form according to category A or B
  • 31. In case of category A Category A Clinical trial already approved by other regulatory agencies (US-FDA, MRHA etc. as defined in the MoM-DCG(I) Oct-06) and approval letters are available NOC received from Application compiled DCG(I) per checklist on APPROVED if trial approved CDSCO website (Internal process) Export license Application made to DCGI received for approval in form 44 Resubmit Apply to Jt.DGFT Within & import license in Application of the respective city/state 2 weeks form 12; fees paid with cover letter & NOC from DGFT Delhi Application evaluated for REJECTED DGFT (Delhi) Completeness if found appropriate Approval received approval normally granted in within 4-6 weeks 4-6 weeks
  • 32. In case of category B Determine if Submission to be made under Category A or B NOC received from DCG(I) if trial approved Category B (Internal process) If study approvals DGFT (Delhi) as required for Category A approval received within are not available 4-6 weeks Application compiled Apply to Jt.DGFT per attached appendix of the respective city/state with cover letter & NOC from DGFT Delhi Application evaluated If found appropriate Application made to DCGI approval normally for approval in form 44 & granted in 8-12 weeks Import license in form 12; Export license received fees paid as required. within 2 weeks
  • 33. Medical Device guidelines Medical Device guidelines amended in Mar. 1, 2006 bringing discipline to medical devices sector The newly included “drugs” are Cardiac stents, drug eluting stents, catheters, intraocular lenses, IV Cannulae, Bone cements, heart valves, scalp vein set, orthopedic implants and internal prosthetic replacements.
  • 34. Recombitant Pharma guidelines New guidelines have been introduced on Recombitant Pharma. There Approval bodies is DCGI but there are asissting bodies like GEAC, RCGM, IBSC.