WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Regulatory principles reflected in practice of WHO PQP Milan Smid, M.D., Ph.D. Prequalification Programme: Priority Essential Medicines

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Principle approaches to regulatory assessment of medicines Innovative & generic medicines Structure of the dossier of medicinal product Product information

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Life cycle of medicine Regulatory approval Post-registration follow-up and maintenance Experimental concept Experimental and clinical concept verification Proof of clinical efficacy and safety Technological development Marketing and clinical use Accumulation of data IP!

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Life cycle of medicine Post-registration development, line extensions Marketing and clinical use IP Product follow-up and maintenance Generics Established medicine WHO list of essential medicines Product obsolete Product calamity! Cost Patent expires

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 WHO list of essential medicines dicines/publications/T RS958June2010.pdf

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Multisource pharmaceutical products need to conform to the same appropriate standards of quality, efficacy and safety as those required of the innovator’s (comparator) product. In addition, reasonable assurance must be provided that the multisource product is therapeutically equivalent and interchangeable with the comparator product. WHO Technical Report Series, No. 937, 2006, Annex 7

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Multisource interchangeable pharmaceutical products World Health Organization WHO Technical Report Series No. 937, 2006, Annex 7, Multisource (generic) pharmaceutical products: guidelines on registration requirements to establish interchangeability Pharmaceutical products that are therapeutically equivalent. Two pharmaceutical products are considered to be therapeutically equivalent if they are pharmaceutically equivalent or pharmaceutical alternatives and after administration in the same molar dose, their effects, with respect to both efficacy and safety, are essentially the same when administered to patients by the same route under the conditions specified in the labelling. This can be demonstrated by appropriate bioequivalence studies, such as pharmacokinetic, pharmacodynamic, clinical or in vitro studies.

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Generics and not generics FDA requirements for generic drugs ( Generic drugs must: 1.contain the same active ingredients as the innovator drug 2.be identical in strength, dosage form, and route of administration 3. have the same use indications 4. meet the same batch requirements for identity, strength, purity and quality 5. be manufactured under the same strict standards of GMP required for innovator products. 6. be bio-equivalent.

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Generics and not generics EU Directive 2001/83/EC Article 10 “Generic medicinal product” shall mean a medicinal product which has the same qualitative and quantitative composition in active substances and the same pharmaceutical form as the reference medicinal product, and whose bioequivalence with the reference medicinal product has been demonstrated by appropriate bioavailability studies.

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Generics and not generics EU Directive 2001/83/EC Article 10 The different salts, esters, ethers, isomers, mixtures of isomers, complexes or derivatives of an active substance shall be considered to be the same active substance, unless they differ significantly in properties with regard to safety and/or efficacy. In such cases, additional information providing proof of the safety and/or efficacy of the various salts, esters, or derivatives of an authorised active substance must be supplied by the applicant.

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Generics and not generics EU Directive 2001/83/EC Article 10 The various immediate-release oral pharmaceutical forms shall be considered to be one and the same pharmaceutical form. Bioavailability studies need not be required of the applicant if he can demonstrate that the generic medicinal product meets the relevant criteria as defined in the appropriate detailed guidelines.

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Regulation of innovatory products and generics For innovator products proof of QUALITY, SAFETY and EFFICACY is needed. Newly also plan of prospective risk-management. For multisource products (generics) safety and efficacy data is referred to the originator. QUALITY and THERAPEUTIC EQUIVALENCE must be demonstrated to allow bridging of data between originator and generic. Different originators (comparators) may be required in different regulatory settings

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Proof of interchangeability Administrative and summarizing data, including GMP Pharmaceutical data Preclinical data Innovative medicine Experimental data/ Literature Generic medicine Multisource interchangeable Clinical data Data required for regulatory approval Pharmaceutical data

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Module 1 Regional Administrative Information Nonclinical Overview Quality Overall Summary Clinical Summary Module 3 Quality Module 4 Nonclinical Study Reports Module 5 Clinical Study Reports Clinical Overview Nonclinical Summaries Not Part of CTD CTD Module 2 NDS CTD triangle for innovator

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Module 1 Regional Administrative Information Nonclinical Overview Quality Overall Summary Clinical Summary Module 3 Quality Module 4 Nonclinical Study Reports Module 5 Clinical Study Reports Clinical Overview Nonclinical Summaries Not Part of CTD CTD Module 2 NDS CTD triangle for generic BE

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Benefits of the CTD More “reviewable” applications Complete, well-organized submissions More predictable format More consistent reviews Easier analysis across applications Easier exchange of information Facilitates electronic submissions Common dossier for PQ and regulatory bodies adopting CTD

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Prerequisites for regulatory approval of generic product Data –about innovator are available and not protected by IP –literature data available and applicable for well established medicines, existing reference product Pharmaceutically equivalent or alternative Defined quality (Dossier) Proven interchangeability (BE/BCS/waiver) Defined and stable way of production (GMP) Same way of clinical use as innovator (Product information)

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Post-approval monitoring of innovatory and generic product Variations to the dossier Pharmacovigilance Reinspections Sampling and Testing Reevaluation Some medicines may require specific risk management and risk minimization programmes Mechanisms must exist to deal with emergencies like quality or safety crisis

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Conclusions on information "Medicine = tablet + information" Good quality drug information for healthcare professionals and patients is a shared responsibility of industry and regulators. Regulators with limited resources could do more for public health by trusting scientific assessments by well resourced DRAs and concentrating more on ensuring the accuracy of drug information in national settings. Not only accuracy of information but also its proper communication is important.

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Correct information and its proper communication can reduce (preventable) ADRs 27 th Annual Meeting of Representatives of the National Centres participating in the WHO Programme for International Drug Monitoring Dublin, Ireland, October 2004 –The summary of product characteristics (SPC) could be an effective tool in preventing ADRs. Accurate and recent information should be provided in the SPCs. The SPC should be appropriately worded and presented to help health professionals get the summary quickly and with the least effort. Doctors should be advised to read all package inserts and labels.

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Product related regulatory information Summary of Product Characteristics/ Data sheet Package Information Leaflet / Patient Information Leaflet Labelling / Text on the Packaging Assessment / Evaluation Report Public Assessment / Evaluation Report

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 WHO PQP (information for applicants, guidelines, generics) Annex 5: Suggested structure of the Summary of Product Characteristics Annex 6: Suggested structure of the Package Information Leaflet

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 WHO PQP (information for applicants, guidelines, WHO Public Assessment Reports - WHOPARs) Guidance note to Applicants (Manufacturers) on the compilation of the WHO Public Assessment Report –Appendix 1: Characteristics of WHOPAR –Appendix 2: Documentation to submit together with the initial submission –Appendix 3: Guidance on Package Leaflet, Summary of Product Characteristics and Labelling –Appendix 4: Format of the Discussion

WHO Workshop on Prequalification of Medicines Programme, Abu Dhabi, October, 2010 Thank you for attention