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Course: RGA 6210
Instructor: Dr. Michael Drues
FDA comprises of three main
  departments:
 Center for Drug Evaluation and
  Research (CDER) for Drugs.
 Center for Biologics Evaluation
  and Research (CBER) for
  Biologics
 Center for Drug Evaluation and
  Research (CDRH) for Medical
  Devices.
European Union comprises of:
 European Commission(EC).
 European Federation of
  Pharmaceutical Industries
  Associations (EFPIA).
European Union also contain
multiple agencies like
 European Medicines.
 Evaluation Agency (EMEA).
 Committee for Medicinal
  Products for Human Use
  (CHMP) of the EMEA.
 National Health Agencies.
FDA Drug approval process                    EU Drug approval process

           Preclinical studies                           Preclinical studies
                           Manufacturing                                 Manufacturing
    Non clinical                                  Non clinical
                              data                                          data




Investigational new drug application                 Clinical trial application

 Phase I        Phase II         Phase III     Phase I        Phase II         Phase III




        New Drug Application                  Marketing Authorization Application

     Phase IV              Post marketing          Phase IV              Post marketing
Food drug administration           European Union
Institutional review board         Ethics Committee




 IRB            IRB approval
                                     EC           EC approval
                required                          required


                                                  EC’s are
                IRB registration                  appointed or
                required                          authorized by
                                                  states
Food drug Administration         European Union

Notification      Prior notification is not usually Formal inspection done
Process           given unless specified by the     by inspectorates of the
                  related FDA center.               local regions.
Inspection        All expenses are covered by      All expenses are covered
expense           FDA.                             by MAA holder including
                                                   the travel expense
Number of         Usually wok alone                Commonly work in a team
inspectors                                         of two or three members
Regulatory        Classifications include:         Classifications include:
classification    NAI- no action indicated         Critical
of inspectorial   VAI-voluntary action indicated   Major
findings.         OAI- official action indicated   Minor
                                                   Others
FDA LEGAL AUTHORITY ACTIONS FOR           EU LEGAL AUTHORITY ACTIONS
SPONSORS, MONITORS, AND CROS

1. Warning and untitled Letters.          EU GCP inspections are conducted by
2. Re-inspection.                         EU member state inspectors. The EMA
3. Termination of exemption (IND, IDE).   does not have a role of enforcement
4. Refusal to approve or license.         like the FDA. Any enforcement actions
5. Withdrawal of approval (PMA, NDA).     are the responsibility of the individual
6. Determination of not substantial       member states concerned and are
equivalent or rescission of 510K for      subject to each country’s local laws and
devices                                   regulations.
7. Implementation of the application
integrity policy.
8. Initiation of Stock recovery.
9. Seizure of test articles.
10. injunction.
11. Prosecution under the FFDCA and
other federal statutes e.g. 18 USC 371
FDA           EU
List of all polies/SOP’s /work             During the    Prior to
instructions conduct of clinical trials    inspection    inspection
including AE reporting
Investigator meeting presentation,         During the    Prior to
attendance log, investigator agenda        inspection    inspection
List of ongoing clinical trials of IMP from During the   Prior to
previous GCP inspection or minimum of inspection         inspection
last 3 years
Instructions provided to Investigator and During the     Prior to
monitors                                  inspection     inspection

Complete study report and Table of         During the    Prior to
contents forTrial Master File (TMF)        inspection    inspection
 Common regulatory objectives

 Eliminate Unjustified difference.

 Harmonization between FDA and EU.
 Efforts :
 - Transparency in system
 - Global submissions
 - Uniform reporting obligations

 Adoption of new or improved
  technical research and development
 - Common technical document
 - Pharmacovigilance.
Thank You for Your Attention

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Mini tutorial presentation

  • 1. Course: RGA 6210 Instructor: Dr. Michael Drues
  • 2. FDA comprises of three main departments:  Center for Drug Evaluation and Research (CDER) for Drugs.  Center for Biologics Evaluation and Research (CBER) for Biologics  Center for Drug Evaluation and Research (CDRH) for Medical Devices.
  • 3. European Union comprises of:  European Commission(EC).  European Federation of Pharmaceutical Industries Associations (EFPIA). European Union also contain multiple agencies like  European Medicines.  Evaluation Agency (EMEA).  Committee for Medicinal Products for Human Use (CHMP) of the EMEA.  National Health Agencies.
  • 4.
  • 5. FDA Drug approval process EU Drug approval process Preclinical studies Preclinical studies Manufacturing Manufacturing Non clinical Non clinical data data Investigational new drug application Clinical trial application Phase I Phase II Phase III Phase I Phase II Phase III New Drug Application Marketing Authorization Application Phase IV Post marketing Phase IV Post marketing
  • 6. Food drug administration European Union Institutional review board Ethics Committee IRB IRB approval EC EC approval required required EC’s are IRB registration appointed or required authorized by states
  • 7. Food drug Administration European Union Notification Prior notification is not usually Formal inspection done Process given unless specified by the by inspectorates of the related FDA center. local regions. Inspection All expenses are covered by All expenses are covered expense FDA. by MAA holder including the travel expense Number of Usually wok alone Commonly work in a team inspectors of two or three members Regulatory Classifications include: Classifications include: classification NAI- no action indicated Critical of inspectorial VAI-voluntary action indicated Major findings. OAI- official action indicated Minor Others
  • 8. FDA LEGAL AUTHORITY ACTIONS FOR EU LEGAL AUTHORITY ACTIONS SPONSORS, MONITORS, AND CROS 1. Warning and untitled Letters. EU GCP inspections are conducted by 2. Re-inspection. EU member state inspectors. The EMA 3. Termination of exemption (IND, IDE). does not have a role of enforcement 4. Refusal to approve or license. like the FDA. Any enforcement actions 5. Withdrawal of approval (PMA, NDA). are the responsibility of the individual 6. Determination of not substantial member states concerned and are equivalent or rescission of 510K for subject to each country’s local laws and devices regulations. 7. Implementation of the application integrity policy. 8. Initiation of Stock recovery. 9. Seizure of test articles. 10. injunction. 11. Prosecution under the FFDCA and other federal statutes e.g. 18 USC 371
  • 9. FDA EU List of all polies/SOP’s /work During the Prior to instructions conduct of clinical trials inspection inspection including AE reporting Investigator meeting presentation, During the Prior to attendance log, investigator agenda inspection inspection List of ongoing clinical trials of IMP from During the Prior to previous GCP inspection or minimum of inspection inspection last 3 years Instructions provided to Investigator and During the Prior to monitors inspection inspection Complete study report and Table of During the Prior to contents forTrial Master File (TMF) inspection inspection
  • 10.  Common regulatory objectives  Eliminate Unjustified difference.  Harmonization between FDA and EU.
  • 11.  Efforts : - Transparency in system - Global submissions - Uniform reporting obligations  Adoption of new or improved technical research and development - Common technical document - Pharmacovigilance.
  • 12.
  • 13. Thank You for Your Attention