Experience with CEPs, API manufacturer s perspective

Similar documents
Use of a CEP. CEP: What does it mean? Pascale Poukens-Renwart. Certification of Substances Department, EDQM

PRODUCT REGISTRATION: AN E-GUIDE

Fedima Position Paper on Labelling of Allergens

Streamlining Food Safety: Preventive Controls Brings Industry Closer to SQF Certification. One world. One standard.

Union Authorisation. Gosia Oledzka. A.I.S.E. Bratislava May Scientific and Technical Affairs Manager

Update on the Biocidal Products Regulation (BPR) Formulators, importers and distributors of disinfection products

The Biocidal Products Regulation. Key Commission Issues & Next Steps

Subject: Industry Standard for a HACCP Plan, HACCP Competency Requirements and HACCP Implementation

CEPE guidance Labelling of Treated Articles

CONSEQUENCES OF THE BPR

INNOVATIVE SOLUTIONS POWERING YOUR SAFETY SUCCESS

Flavourings Legislation and Safety Assessment

Soft and Semi-soft Cheese made from Unpasteurized/Raw Milk in Canada Bureau of Microbial Hazards, Food Directorate, Health Canada

Treated Articles and their regulation under the European Biocidal Products Regulation

A Practical Guide to Biocidal Products and Articles

ECOBULK WINE-STORE-AGE HIGHEST FOOD SAFETY AND COST-EFFECTIVENESS IN WINE PRODUCTION

"Outcomes of the Working Groups' discussions"

Memorandum of understanding

1) What proportion of the districts has written policies regarding vending or a la carte foods?

GI Protection in Europe

IFPTI Fellowship Cohort V: Research Presentation Matthew Coleman, R.S., CP-FS

SEPAWA Nordic Update on disinfectants under the BPR. Michael Fink DHI, Denmark 16 th of May 2017

Magnesium Oxide. Product Regulatory Data Sheet. MOC Product Description Code

Thought Starter. European Conference on MRL-Setting for Biocides

STEARIC ACID. Product Regulatory Data Sheet

Flavour Legislation Past Present and Future or From the Stone Age to the Internet Age and Beyond. Joy Hardinge

Relevant Biocidal Product Types in Food Contact Applications

Global Rum Market Insights, Forecast to 2025

NEW ZEALAND WINE FOOD BILL ORAL SUBMISSION OF NEW ZEALAND WINEGROWERS 23 SEPTEMBER Introduction

BPR Requirements for Treated Articles. A.I.S.E. Biocides WG First revision - December 2017

Control of treated articles in the Biocidal Products Regulation ECHA Biocides Stakeholders Day 25 June 2013

Glycine. Product Regulatory Data Sheet. MOC Product Description Code

Ideas for group discussion / exercises - Section 3 Applying food hygiene principles to the coffee chain

Calcium Acetate. Product Regulatory Data Sheet

Towards EU MRLs for biocides current status. Karin Mahieu

ILSI Workshop on Food Allergy: From Thresholds to Action Levels. The Regulators perspective

Magnesium Hydroxide. Product Regulatory Data Sheet. code 5984 Magnesium Hydroxide, Powder, U.S.P. - F.C.C. R

Ammonia Solution, Strong (Ammonium Hydroxide)

New missions for ANSES in the area of biocidal products

Calcium Phosphate, Dibasic, Anhydrous

Allergy Awareness and Management Policy

Sqf Food Safety Manual

Specify the requirements to be met by agricultural Europe Soya soya bean collectors and Europe Soya primary collectors.

Allergies and Intolerances Policy

1156 Fifteenth Street, NW Suite 200 Washington, DC 20005

STATE OF THE VITIVINICULTURE WORLD MARKET

Louisiana Crawfish Action Plan

Global Hot Dogs Market Insights, Forecast to 2025

The New EU Rules on Articles Treated with Biocidal Products. Cándido García Molyneux European Food Law Conference 2014 ERA, Trier May 5, 2014

Pasta Market in Italy to Market Size, Development, and Forecasts

Appendix 1 fees for biocidal active substances and products. A. Fees for evaluation of applications* Active substances fees

Precautionary Allergen Labelling. Lynne Regent Anaphylaxis Campaign

Guideline to Food Safety Supervisor Requirements

Tea Statistics Report 2015

CERT Exceptions ED 19 en. Exceptions. Explanatory Document. Valid from: 26/09/2018 Distribution: Public

ISO INTERNATIONAL STANDARD. Infusion equipment for medical use Part 6: Freeze drying closures for infusion bottles

Canada-EU Free Trade Agreement (CETA)

Housing Quality in Europe A Comparative Analysis Based on EU-SILC Data

Improving Enquiry Point and Notification Authority Operations

GEOGRAPHICAL INDICATIONS SYSTEM IN THE EUROPEAN UNION

BPR in Brief. Guidance Document for A.I.S.E. members

Overview of the International Framework of Organizations and Agreements

Phosphoric Acid. Product Regulatory Data Sheet

European Vitamin B9 (Folic Acid) Industry 2016 Market Research Report

Biocidal Product Families instead of Frame Formulations The right step forward? Sara Kirkham

World Yoghurt Market Report

Wine-Tasting by Numbers: Using Binary Logistic Regression to Reveal the Preferences of Experts

Chef de Partie Apprenticeship Standard

WORKING GROUP ON TEA TRADE AND QUALITY. Intersessional Meeting of the Intergovernmental Group on Tea Rome, 5-6 May 2014

Ministry of the Environment Decree

Questions and Answers about Smart Snacks in School

MacKillop Catholic College Allergy Awareness and Management Policy

Customer Focused, Science Driven, Results Led

Thiamine Hydrochloride

The Government of the Republic of the Union of Myanmar. Ministry of Commerce. Union Minister s Office. Notification No. 18/2015.

The Positive List System in Japan and Our Approach to the Issues of Pesticide Residues in Cocoa

Experience with Biocidal Product Family as competent authority

Geographical Indications (Wines and Spirits) Registration Amendment Bill Initial Briefing to the Primary Production Select Committee

Winemaking in the 21st Century How will consumer demands shape the future of wine?

The Biocidal Products Regulation in the Automotive Supply Chain

Academic Year 2014/2015 Assessment Report. Bachelor of Science in Viticulture, Department of Viticulture and Enology

Specify the requirements to be met by Donau Soja soya bean primary processors.

SUCROSE. Product Regulatory Data Sheet. MOC * Product Description Code

China s Export of Key Products of Pharmaceutical Raw Materials

Bilateral screening: Chapter 27 PRESENTATION OF THE REPUBLIC OF SERBIA Biocidal Products Regulation (BPR)

Biocides for Fuels & Lubricants Application and Regulations

EU Sugar Market Report Quarterly report 04

To be officially certified organic, it is necessary to meet the requirements listed below.

Verification and Validation of HACCP Plans in U.S. Meat Processing Facilities

5. Supporting documents to be provided by the applicant IMPORTANT DISCLAIMER

A Trip around the World through Exports

Market Implications for GM Crops

ISO INTERNATIONAL STANDARD. Infusion equipment for medical use Part 6: Freeze drying closures for infusion bottles

WTO Agreement on Import Licensing Procedures. An Overview

Acetic Acid. Product Regulatory Data Sheet. MOC Product Description Code

Senior Chef Production Cooking Apprenticeship Standard

TREATED ARTICLES NEW GUIDANCE AND REGULATION BIOCIDE SYMPOSIUM 2015 LJUBLJANA MAY DR. PIET BLANCQUAERT

Bringing Faith and Learning to Life

COMMISSION IMPLEMENTING REGULATION (EU) No /.. of XXX. on the traceability requirements for sprouts and seeds intended for the production of sprouts

Transcription:

Experience with CEPs, API manufacturer s perspective Prague, September 2017 Marieke van Dalen 1 Contents of the presentation Introduction Experience with CEPs: obtaining a CEP Experience with CEPs: using a CEP Filing of changes in the CEP dossier Conclusion 2

Introduction What / who is APIC? A Technical European Industry Association, based in Brussels Focused on APIs from a quality and regulatory perspective 3 Introduction APIC s Mission To promote the use of compliant APIs in medicinal products to ensure patient safety To represent the interests of pharmaceutical and chemical companies producing APIs and intermediates in Europe by being recognized experts who advance and influence the global GMP and Regulatory environment 4

Introduction What / who is Marieke van Dalen Working for Aspen Oss B.V. in the Netherlands as Global Regulatory Specialist Over 30 years of experience in the regulatory field Board member of APIC 5 Contents of the presentation Introduction Experience with CEPs: obtaining a CEP Experience with CEPs: using a CEP Filing of changes in the CEP dossier Conclusion 6

Experience with CEPs: obtaining a CEP To obtain a CEP the procedure is not that difficult: submit a dossier that is in line with all the requirements which are published on the EDQM website and you will obtain a CEP. In practice there is a little more to it. There are few CEPs that are issued without any questions being raised. On the EDQM website references are found to all guidelines that should be applied. 7 Experience with CEPs: obtaining a CEP Taking into account the EDQM Top 10 deficiencies when compiling the dossier certainly increases the quality of the dossier and brings the dossier more in line with what is actually expected. The topic leading to most discussions is the topic of the starting materials. It is quite frustrating for industry that Regulatory Starting Materials (RSM) that were approved in the corresponding ASMFs are not deemed acceptable by EDQM. In the experience of the APIC members this is the most serious and most critical deficiency. 8

Experience with CEPs: obtaining a CEP This often leads to the situation that the RSM in the CEP is different (further back in the synthesis) from the RSM in other parts of the world. The consequences of redefining are huge: new players may enter the supply chain, very extensive quality agreements need to be prepared with new intermediate manufacturers (who have to comply with GMP). The main objection from industry is NOT that GMP is too expensive, but the fact that change control starts at the RSM, and more steps thus simply means more changes to be reported.. 9 Experience with CEPs: obtaining a CEP Obviously re-definition after a CEP has already been granted is even more frustrating. Re-opening the discussion should only take place when there are serious health concerns. Industry also sees the RSM discussions as a major problem in the IGDRP developments. Obviously we do not want to see assessment reports with earlier RSMs shared with countries where a later RSM has been approved. 10

Experience with CEPs: obtaining a CEP Q3D implementation still raises some questions: EDQM has published their guidance and more than 150 CEPs with a Risk Management Summary appended have been granted since September 2016. APIC feels that the policy seems to have moved from being a non-testing guideline applicable to medicinal products to a testing guideline applicable to APIs and excipients. Although the component approach is a choice, as is the submission of a RMS, whenever an approach is preferred by EDQM/EMA, it becomes the only way in the eyes of the MAH. 11 Experience with CEPs: obtaining a CEP The Drug Product manufacturers and the MAHs are expecting all their suppliers to perfom a risk evaluation, including test results. This is particularly strange for APIs that are really low dosed: in these cases, making the calculations using PDE s, even percentages of elements present in the API would be safe! 12

Contents of the presentation Introduction Experience with CEPs: obtaining a CEP Experience with CEPs: using a CEP Filing of changes in the CEP dossier Conclusion 13 Experience with CEPs: using a CEP In the EU, the use of a CEP is well established and runs rather smoothly. In some occasions questions are being raised on topics already assessed by EDQM. In those cases we try to refer the Authority to the EDQM assessment report. Outside of the EU, different approaches are being used.. 14

Experience with CEPs: using a CEP There are non-eu countries who actually have a system in place to accept CEPs: e.g. Switzerland, Australia, New Zealand. However, often there is a CEP plus requirement: the CEP can be submitted but on top of that Closed Part or Open Part information is needed (this is APIC experience in e.g. Saudi Arabia, Singapore, South Africa, Tunisia). 15 Experience with CEPs: using a CEP In some countries, the CEP is accepted, but only as supporting information, e.g. in India where it can be used as proof of GMP. This could backfire, e.g. when more manufacturing steps (and more manufacturer site addresses) are listed on the CEP as compared to the dossier in that country. Thus, carefully consider if the pro s outweigh the con s. 16

Experience with CEPs: using a CEP The practical use of the CEP is in the hands of the Drug Product manufacturer: we still see that quite a few frequently occurring mistakes are made there. Use of a former version of the CEP (this means it is no longer valid!) in an application. Next to the CEP, incorporate the (often outdated) Applicants Part of the ASMF in the dossier. Extremely confusing for the assessor. Not filing revisions of the CEP through the Variations Scheme. 17 Experience with CEPs: using a CEP One thing often encountered is the lack of information on topics not covered by the CEP assessment in the DP dossier. An example is the micronization process if the CEP has been assessed and granted for non micronized material. The DP manufacturer should get this information from the API supplier and incorporate it in their DP dossier. 18

Contents of the presentation Introduction Experience with CEPs: obtaining a CEP Experience with CEPs: using a CEP Filing of changes in the CEP dossier Conclusion 19 Filing of changes in the CEP dossier This is in the view of APIC one of the major advantages of the CEP system. In the Certification scheme changes with regards to the API are dealt with between the CEP holder (in most cases the API manufacturer) and the EDQM. If a revision of the CEP is issued, this is in almost all cases a Type 1A variation for the Marketing Authorization Holder (MAH). 20

Filing of changes in the CEP dossier The one remaining issue is the expectation to file prestarting material changes. EDQM has announced that the revision guidleine will be revised to reflect the official EU position on pre-starting material information. This is however not yet completed and companies are struggling with what to do at present. 21 Contents of the presentation Introduction Experience with CEPs: obtaining a CEP Experience with CEPs: using a CEP Filing of changes in the CEP dossier Conclusion 22

Conclusion Overall, API Industry is very much in favour of the CEP system. Obviously we do see some room for improvement, but the system works quite well. In fact, our dream would be to have a similar system for non-ph-eur covered substances, as we think that centralised assessment for API s is the only truly workable solution for the European ASMF system. 23 24