M. Radhika Choudhary
Regulatory Affairs Associate
A Brief Introduction to
DMF and CEP
CTD
Format for submission
for INDs and marketing
applications like NDA, ANDA, BLA,
etc.
Introduction to CTD
3.1 Table of
Contents
3.2 Body of
Data
3.2.S Drug Substance
3.2.P Drug Product
3.2.A Appendices
3.2.R Regional
Information
3.3 Literature
References
MODULE-3 (DRUG SUBSTANCE PART)
3.2.S.1 General Information
3.2.S.2 Manufacture
3.2.S.3 Characterization
3.2.S.4 Control of Drug Substance
3.2.S.5 Reference Standards or Materials
3.2.S.6 Container Closure Systems
3.2.S.7 Stability
Filings in FDA
(Substance part)
Nature of Drug
Substance, Drug
Product.
Manufacturing
process is shown
to be in control
Manner in which
they are made
DMF (Drug Master File)`
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 the component of a drug Product.
Used as support for various applications.
C M C?Who must file a DMF….?
NOBODY.
Types of DMFs
Originally Five Types… for US Market
I. Plant information (Withdrawn)
II. Drug substance, intermediates and material used in 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)
How the System Works ?
 Holder sends the DMF 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
NEW ADDRESS
Submissions of Drug Master File
DMF is reviewed for administrative purposes ONLY by
Central Document Room (CDR) staff.
Entered into DMF DATABASE, Assigned a number, and
a letter is sent to the HOLDER.
If the DMF Holder does not receive any response from
FDA
HOLDER can put a query on the e-mail:
dmfquestion@cder.fda.gov
• 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.
Letter sent by FDA to DMF HOLDER consists of...
Letter of Authorization (LOA)
The DMF will be reviewed ONLY when it is referenced in an Application or another DMF.
DMF HOLDERUS FDA Send a letter to
remind holder
obligations
Send 2 copies of LOA to the FDA
1 copy of LOA to the APPLICANT
The applicant submits THIS
copy of LOA in their
Application.
Letter of Authorization (LOA)
DMF HOLDER
1 copy of LOA to the APPLICANT
The applicant submits THIS
copy of LOA in their
Application.
LOA to the FDA
Key points - LOA
 Sending LOA is the only mechanism
which triggers the review procedure of
DMF.
 If the holder cross references its own DMF,
the holder should supply following
information in the LOA.
• DMF number
• Specific product(s) covered by the DMF
• Section numbers and/or page numbers to
be referenced
[Authorization to refer to a DMF]
Sample LOA
Review of the DMF
REVIEWER
When reviewer receives an application
(IND/NDA/ANDA) with an LOA 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.
Next slide
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.
DMF - Annual Update
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.
Retiring DMFs
If a DMF has no activity (amendment or annual report) in three
years FDA will initiate 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.
(Note: LOA is not counted for activity)
PARTS OF DRUG MASTER FILE
APPLICANT’S PART RESTRICTED PART
2 PARTS
OPEN PART CLOSED PART
What neXt?...
Information in the Drug Master File…
APPLICANT’S PART OF DMF
OPEN PART
( AVAILABLE TO APPLICANT )
ACTIVE SUBSTANCE
MANUFACTURER
SUPPLIES INFORMATION
TO THE APPLICANT
THE INFORMATION INCLUDES:
- outline of the manufacturing method
- impurities originating from the manufacturing method,
isolation procedure and degradation
- information on the toxicity of specific impurities
THE INFORMATION 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)
RESTRICTED PART OF DMF
CLOSED PART
( NOT AVAILABLE TO APPLICANT )
Filings in EMA
(Substance part)
ASMF (Active Substance Master File)
 Sometimes called as EDMF (European Drug Master File)
 This is generally used for Non-Pharmacopoeial
substances in Europe.
 In Europe, the permission to reference an ASMF is called
Letter of Access.
CEP (Certificate of Suitability)
Role
To demonstrate that the purity of the given API is suitably controlled
by the relevant monographs of European Pharmacopoeia.
Advantages
 Full confidentiality of the submitted data.
 Centralised evaluation by EDQM (European Directorate for the
Quality of Medicines & HealthCare).
 Easing management of applications for MAA in Eu-countries.
 prevents duplication of assessment by the individual national
authorities.
-Issued by EDQM
It’s a Separate registration process for an API with EMA
CEP (Certificate of Suitability)
Scope of the procedure
Substances covered by a specific Ph. Eur. Monographs :
Active, excipients, herbal drugs/herbal preparations
 TSE risk products (starting materials, intermediates,
reagents,…)
Not applicable for biotechnological products, products from
human tissues, semi-finished or finished products, substances
not included in Ph. Eur.
-Issued by EDQM
It’s a Separate registration process for an API with EMA
How does the process of Evaluation by
EDQM work Flow?
DMF - Application
Certification Division of the EDQM
Validated and listed for assessment
EDQM may send queries to the applicant
When the queries have been resolved
EDQM sends the applicant the CEP
Inspection program for manufacturing
sites covered by a certificate (CEP)
Checks compliance with current Good
Manufacturing Practices (GMP) and
the CEP application dossier
A CEP looks
like this 
Is my CEP valid?
Thank you for your attentive listening!

Thank you for your attentive listening!
Hope Our Paths will
Cross Again!

DMF CEP

  • 1.
    M. Radhika Choudhary RegulatoryAffairs Associate A Brief Introduction to DMF and CEP
  • 2.
    CTD Format for submission forINDs and marketing applications like NDA, ANDA, BLA, etc. Introduction to CTD 3.1 Table of Contents 3.2 Body of Data 3.2.S Drug Substance 3.2.P Drug Product 3.2.A Appendices 3.2.R Regional Information 3.3 Literature References MODULE-3 (DRUG SUBSTANCE PART) 3.2.S.1 General Information 3.2.S.2 Manufacture 3.2.S.3 Characterization 3.2.S.4 Control of Drug Substance 3.2.S.5 Reference Standards or Materials 3.2.S.6 Container Closure Systems 3.2.S.7 Stability
  • 3.
  • 5.
    Nature of Drug Substance,Drug Product. Manufacturing process is shown to be in control Manner in which they are made DMF (Drug Master File)` 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 the component of a drug Product. Used as support for various applications. C M C?Who must file a DMF….? NOBODY.
  • 6.
    Types of DMFs OriginallyFive Types… for US Market I. Plant information (Withdrawn) II. Drug substance, intermediates and material used in 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)
  • 7.
    How the SystemWorks ?  Holder sends the DMF 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 NEW ADDRESS Submissions of Drug Master File
  • 8.
    DMF is reviewedfor administrative purposes ONLY by Central Document Room (CDR) staff. Entered into DMF DATABASE, Assigned a number, and a letter is sent to the HOLDER. If the DMF Holder does not receive any response from FDA HOLDER can put a query on the e-mail: dmfquestion@cder.fda.gov
  • 9.
    • Number givento 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. Letter sent by FDA to DMF HOLDER consists of...
  • 10.
    Letter of Authorization(LOA) The DMF will be reviewed ONLY when it is referenced in an Application or another DMF. DMF HOLDERUS FDA Send a letter to remind holder obligations Send 2 copies of LOA to the FDA 1 copy of LOA to the APPLICANT The applicant submits THIS copy of LOA in their Application.
  • 11.
    Letter of Authorization(LOA) DMF HOLDER 1 copy of LOA to the APPLICANT The applicant submits THIS copy of LOA in their Application. LOA to the FDA Key points - LOA  Sending LOA is the only mechanism which triggers the review procedure of DMF.  If the holder cross references its own DMF, the holder should supply following information in the LOA. • DMF number • Specific product(s) covered by the DMF • Section numbers and/or page numbers to be referenced [Authorization to refer to a DMF]
  • 12.
  • 13.
    Review of theDMF REVIEWER When reviewer receives an application (IND/NDA/ANDA) with an LOA 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. Next slide
  • 14.
    After getting DMF,the Reviewerstarts 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.
  • 15.
    DMF - AnnualUpdate 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.
  • 16.
    Retiring DMFs If aDMF has no activity (amendment or annual report) in three years FDA will initiate 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. (Note: LOA is not counted for activity)
  • 17.
    PARTS OF DRUGMASTER FILE APPLICANT’S PART RESTRICTED PART 2 PARTS OPEN PART CLOSED PART What neXt?... Information in the Drug Master File…
  • 18.
    APPLICANT’S PART OFDMF OPEN PART ( AVAILABLE TO APPLICANT ) ACTIVE SUBSTANCE MANUFACTURER SUPPLIES INFORMATION TO THE APPLICANT THE INFORMATION INCLUDES: - outline of the manufacturing method - impurities originating from the manufacturing method, isolation procedure and degradation - information on the toxicity of specific impurities
  • 19.
    THE INFORMATION INCLUDES: Detailedinformation 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) RESTRICTED PART OF DMF CLOSED PART ( NOT AVAILABLE TO APPLICANT )
  • 20.
  • 22.
    ASMF (Active SubstanceMaster File)  Sometimes called as EDMF (European Drug Master File)  This is generally used for Non-Pharmacopoeial substances in Europe.  In Europe, the permission to reference an ASMF is called Letter of Access.
  • 23.
    CEP (Certificate ofSuitability) Role To demonstrate that the purity of the given API is suitably controlled by the relevant monographs of European Pharmacopoeia. Advantages  Full confidentiality of the submitted data.  Centralised evaluation by EDQM (European Directorate for the Quality of Medicines & HealthCare).  Easing management of applications for MAA in Eu-countries.  prevents duplication of assessment by the individual national authorities. -Issued by EDQM It’s a Separate registration process for an API with EMA
  • 24.
    CEP (Certificate ofSuitability) Scope of the procedure Substances covered by a specific Ph. Eur. Monographs : Active, excipients, herbal drugs/herbal preparations  TSE risk products (starting materials, intermediates, reagents,…) Not applicable for biotechnological products, products from human tissues, semi-finished or finished products, substances not included in Ph. Eur. -Issued by EDQM It’s a Separate registration process for an API with EMA
  • 25.
    How does theprocess of Evaluation by EDQM work Flow? DMF - Application Certification Division of the EDQM Validated and listed for assessment EDQM may send queries to the applicant When the queries have been resolved EDQM sends the applicant the CEP Inspection program for manufacturing sites covered by a certificate (CEP) Checks compliance with current Good Manufacturing Practices (GMP) and the CEP application dossier
  • 26.
  • 27.
    Is my CEPvalid?
  • 28.
    Thank you foryour attentive listening!  Thank you for your attentive listening! Hope Our Paths will Cross Again!

Editor's Notes

  • #7 Type I : plant information Manufacturing site, Equipment capabilities, Operational layout Actual site address, A map showing its location with respect to the nearest city, Corporate headquarters From July 2000 : Type I DMFs use has been eliminated, (Numbering retained to avoid confusion) 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." 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. Type IV:  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. 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 the proposed submission
  • #8 Follow the Guideline at www.fda.gov/cder/guidance/dmf.htm Binders recommended http://www.fda.gov/cder/ddms/binders.htm
  • #12 Reference for 2 copies to be submitted : http://perfectdossier.com/pdf/Inside%20Story%20for%20Review%20of%20DMF%20&%20Dossiers%20by%20Regulatory%20Authorities.pdf http://ictr.johnshopkins.edu/wp-content/uploads/import/1582-FDA_LOA_DrugMasterFiles_18MAR13.pdf
  • #19 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.
  • #24 Manufacturing procedures and controls for finished dosage forms- should ordinarily be submitted in an IND, NDA, ANDA, or Export Application - It should be submitted in a DMF Recognized by the following countries and institutions: - US (FDA), - Canada (HPFB), - Australia (TGA), - New Zealand, - Tunisia and Morocco. Simplifies the trading with pharmaceutical substances and ingredients.
  • #25 CEP for Herbal drugs : pg 8 (section : 5.2) http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2009/09/WC500002813.pdf http://www.gmp-compliance.org/eca_news_224.html
  • #26 Valid- 5yrs, then renewal once, valid for unlimited period.
  • #27 An example : http://www.europa-bioproducts.com/pdf/Equitech's-EDQMH-certificate.pdf
  • #28 CEP online Where to check who has already a CEP?