The document discusses post-approval regulatory affairs. It notes that the FDA may require post-approval studies to ensure continued safety and effectiveness of approved drugs and devices. Failure to comply with post-approval requirements can result in withdrawal of approval. It also discusses requirements for making and reporting manufacturing and distribution changes to approved applications, including prior approval supplements, changes being effected supplements, and annual reports. Finally, it provides examples of major, moderate, and minor labeling changes that may require different levels of regulatory submission.

1. REGULATORY AFFAIRS
TOPIC -- POST APPROVAL REGULATORY AFFAIRS
UNDER THE GUIDENCE OF:-
DR. URMILA MAM
PRESENTED BY:-
ABDUL NAIM

2. POST APPROVAL REGULATORY AFFAIRS
• The FDA may require a post-approval study at the time of approval of a
Premarket Approval (PMA), Humanitarian Device Exemption (HDE), or product
development protocol (PDP) application to help assure continued safety and
effectiveness (or continued probable benefit, in the case of an HDE) of the
approved drug product of medical device
• A sponsor’s failure to comply with any post approval requirement may be
grounds for withdrawing approval i.e., whether the post approval study will be
terminated or revised/replaced.
• The safety surveillance is designed to detect any rare or long-term adverse effects
over the much larger population and longer time period.
• Harmful effects shown in this trial may result in drug ban or restricted in certain
usages.
• Holders of NDA and ANDA who intended make post approval changes should
follow section 502A of the federal food, Drug and cosmetic act.

3. • Which provides requirement for making and reporting manufacturing changes to an approval
application and for distribution changes.
• An application must provide specific information to access the effect of the quality, purity, and
potency of a drug product.
Reporting categories:
(1) Prior approval supplement
(2) Changes being effected (CBE) Supplement,
(3) Annual report
CMC (chemistry manufacturing and controls) Post approval Regulatory Submissions : Prior approval
supplement : A prior approval supplement is required for a CMC changes that has a
substantial(major) potential to have an adverse effect on the identity, strength, quality, purity, or
potency of the product as they may relate to its safety and effectiveness.
It is also referred as Major change
CBE is Referred as Moderate change
Annual report is referred as Minor change

4. • A prior approval supplement may need to be approved as soon as
possible in the interest of the public health (e.g., drug shortage).
Potential impact on product quality is major. Implementation after
approval of submission.
• Changes being Effected supplement: A CBE supplement is required
for a CMC change that has a moderate potential to adversely affect
the drug product as to its safety or effectiveness. The CANA (changes
to an approved NDA & ANDA) guidance provided for 2 types of CBE
supplements:
(a) Supplement -Change Being Effected in 30 days (CBE -30): Applicant
wait at least 30 days following receipt of the submission by FDA before
distributing product incorporating the change.

5. (b) Supplement- Changes Being Effected (CBE-0): Implementation
occur immediately upon FDA receipt of submission. Unlike CBE-30
Supplement, a CBE-0 Supplement does not require a waiting period.
Annual Report: The annual report is a periodic, post marketing
submission required by 21-CFR 314.81(code of federal regulation).
Potential impact on product quality is low. Implementation occur
immediately – filled yearly within 60 days of anniversary date of
NDA(new drug application) approval.

6. Types of CMC Post approval Submission

12. LABELLING
A. Major
• Based on post marketing study results , labelling changes associated
with new indication and usage.
B. Moderate
Change in the clinical study section reflecting new or modified data
C. Minor
Change in the layout of packaging, FDA regulation editorial changes,
such as adding a distributors name