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Republic of the PhilippinesDepartment of Health
Food and Drug Administration
KAPIHAN AT TALAKAYANCENTER FOR DRUG REGULATION AND RESEARCH
27 March 2015FDA Annex Building
1. New Organizational Structure
2. New Citizens Charter
3. CDRR Activities
4. Updates on Regulations
5. Target Regulations for 2nd Qtr 2015
6. Regulatory Challenges
Presentation Outline
2
Republic of the PhilippinesDepartment of Health
Food and Drug Administration
NEW ORGANIZATIONAL STRUCTURE
3
4
FOOD AND DRUG ADMINISTRATIONOrganizational Structure
*Based on RA 9711
Director-General*
Deputy Director-General*for Administration and Finance
Deputy Director-General*for Field Regulatory Operations
Policy and Planning Service
Legal ServiceAdministrative & Finance
ServiceSouth Luzon FO(NCR, IV-A, IV-B, V)
Mindano West FO(IX, XII, ARMM)
North Luzon FO(CAR, I, II, III)
Visayas FO(VI, VII, VIII)
Policy Formulation & Program
Implementation
Monitoring and Evaluation Division
Investigation Division
Litigation & Enforcement
Division
Human Resource Development
Division
Inf ormation & Communications
Technology Mgt. Div .
Budget and Mgt. Division
Accounting Divison
General Services Division
Center for Device Regulation & Radiation Health & Research
Center for Food Regulation and Research
Center for Cosmetics Regulation and Research
Center for Drug Regulation and Research
Product Licensing and Registration
Division
Product Research & Stds. Dev't. Div.
Radiation Regulation Division
Physics Laboratory
Product Licensing and Registration
Division
Product Research & Stds. Dev't. Div.
Product Licensing and Registration
Division
Product Research & Stds. Dev't. Div.
Product Licensing and Registration
Division
Product Research & Stds. Dev't. Div.
Common Services Laboratory
Policy Dissemination and Training Division
Mindano East FO(X, XI, CARAGA)
Administrative and Finance Division
Establishment Licensing, Inspection
& Enf orcement Div ision
Administrative and Finance Division
Establishment Licensing, Inspection
& Enf orcement Div ision
Administrative and Finance Division
Administrative and Finance Division
Administrative and Finance Division
Establishment Licensing, Inspection
& Enf orcement Div ision
Establishment Licensing, Inspection
& Enf orcement Div ision
Davao Testing & Quality Assurance
Laboratory
Alabang Testing & Quality Assurance
Laboratory
Cebu Testing & Quality Assurance
Laboratory
Establishment Licensing, Inspection
& Enf orcement Div ision
CDRR ORGANIZATIONAL CHART
5
CDRR
PRSDD
Standards Devt/
Advocacy
Clinical Research
PMS
Drug Safety/PV
SSFFC
PRC
LRD
Licensing
L1
RONPD &
DS
L2
DM
DD
CRO
Sponsor
Registration
Human Drugs
CMC
Clinical
TM/H/
OTCBio/Vacc Vet PAC
Pre-evaluation
Melody M. Zamudio, RPh, MGM-ESP
Grace L. Medina, RPh, MBA/PARegina S. Obligacion, RPh
CDRR MANPOWER COMPLEMENT
Total CDRR
personnel
Technical
Personnel
Non
technical
Personnel
84 56 28
6
Republic of the PhilippinesDepartment of Health
Food and Drug Administration
7
NEW CITIZENS CHARTER
Type of Application Duration of Activity
Licensing of drug establishment 30 calendar days
Initial application 254 calendar days
Renewal application 68 calendar days
Automatic Renewal application 33 calendar days
CLIDP application 31 calendar days
Variation application 52 calendar days
Certificate of Pharmaceutical Products (CoPP)
14 calendar days
Certificate of Free Sale 14 calendar days
Export Certificate 14 calendar days
Sales Promotion and Ads Permit 14 calendar days
New Citizen’s Charter
8
Republic of the PhilippinesDepartment of Health
Food and Drug Administration
9
CDRR ACTIVITIES1st QTR 2015
• ASEAN TMHS National Consultation
• CDRR Retooling
• AO 2014-0034 cascading to FROO
• BA/BE Training
• Focus Group Discussion – Fee Restructuring
CDRR Activities10
ASEAN TMHS Consultation - Luzon
• Held 05 January 2015 at FDA AVR Annex11
ASEAN TMHS Consultation – Visayas
• Held 17 March 2015 at RO VII Conference 12
ASEAN TMHS Consultation – Mindanao
• Held 18 March 2015 at Grand Regal Hotel Davao 13
ASEAN TMHS Consultation –
Collation of Feedback
14
ASEAN TMHS Consultation –
Collation of Feedback
• Seeking comments and feedbacks from stakeholders through the consultation template
• Deadline of sending of comments via mail: 15 April 2015
15
ASEAN TMHS Consultation –
Collation of Feedback
• Consultation Template
16
CDRR Retooling
17
CDRR Retooling
• Licensing Section – 3-5 February 2015
• Registration Section and PRSDD – 4-6 February 2015
18
CDRR Retooling
• Licensing Section Objective:
– Review of the implementation of AO 2014-0034 and its IRR
• Registration Section and PRSDD Objective:
– Review of the implementation of recently issued regulations
– Process mapping
19
AO 2014-0034 Cascading 20
• 9-10 February 2015
• Cascading of AO 2014-0034 and review of its implementation to the officers of the FDA Regional Offices
AO 2014-0034 Cascading 21
BA/BE Training22
• Capacity building for industry and FDA staff
• Training conducted by former US FDA staff and USP Scientists:
– Dr. Leonel M. Santos, PhD
– Dr. Vinod P. Shah, PhD
BA/BE Training23
• Two day training for industry participants (16-17 February 2015
• One day training for CDRR Registration staff (18 February 2015)
• One day training for Drug Laboratory staff (19 February 2015)
• Meeting with FDA staff (20 February 2015)
BA/BE Training24
Focus Group Discussion –Fee Restructuring
25
Focus Group Discussion –Fee Restructuring
• Stakeholder associations’ representatives were consulted for the 2015 CDRR proposed fees
• Focus group discussion in preparation for the public hearing to be held in May 2015
• Draft of FDA Fees and Charges will be posted 2nd week of April
• Proposed fees:
26
General Considerations• Business Plan
– Financial sustainability through retention of income
– Reduce impending funding shortfall
– Facilitate implementation of strengthening measures and activities
• Inflation from 2003-2014*
• Growth in the number of establishments and products registered**
27
Considerations -Licensing Fees
• Drug Establishments – no SME classification
• Cover inspection fees once a year for every valid year
• Validity changes:
– Initial: from 1 year to 2 years
– Renewal: from 2 years to 3 years
• From amendment to variations:
– Major, Minor-Prior Approval, Minor-Notification 28
Considerations -Registration Fees
• New drug classification:
– Investigational Product*
– New Chemical Entities
– Generic Products
– Biotechnological Products
– Other class: OTC, Veterinary, TM, HR, Medical Gas
• One-step submission – quality and clinical/non-clinical review (streamlined process)
29
Considerations -Registration Fees
• Cover PMS fees (sampling and lab testing*) throughout the validity
• From amendment to variations:
– Major, Minor-Prior Approval, Minor-Notification
30
Inclusions -Licensing Fees
• Inflation adjusted licensing fees from 2001
• Inspector’s fee + TEV
• Indirect Costs*
31
Inclusions -Registration Fees
• Inflation adjusted registration fees from 2001
• Clinical/non-clinical review including post-marketing commitments
• Brand name evaluation and acceptance
• PMS sampling and laboratory analysis
• Indirect Costs*
• For IPs – inclusive of Protocol review, ERB/ERC review
32
Inflation adjusted Licensing Fee per year for 2 years
+ Inspector’s Fee
+ TEV
+ Indirect Costs
Example: Initial Distributor Licensing Fee
33
License to Operate
34
Category
Fee (in PhP)
Initial
(2-year
validity)
Renewal
(3-year
validity)
Variation
MaV MiV-PA MiV-N
Drug Manufacturer
(Repacker, Packer,
Trader)
100,000 150,000 9,500 1,100 1,100
Drug Distributor
(Exporter, Importer,
Wholesaler)
28,000 42,000 4,400 1,100 1,100
Drugstore/Pharmacy/B
otica and similar outlets
6,400 9,500 2,800 1,100 1,100
Retail Outlet for Non-
Prescription Drugs
(RONPD)
6,400 9,500 2,800 1,100 1,100
Sponsor/Contract
Research Organization
28,000 42,000 4,400 1,100 1,100
Inflation adjusted MR Fee for 5 years
+ Inflation adjusted NCE review
+ Post Marketing Commitments Review (from PMS protocol review fee)
+ Brand Name Acceptance+ 2 proposed Brand Names
+ Inflation adjusted lab testing fee
+ Sampling Costs
+ Indirect Costs
Example: NCE
35
Product Registration
36
Category
Fee (in PhP)
Initial
(5-year
validity)
Renewal
(5-year
validity)
Variation
MaV MiV-PA MiV-N
New Chemical Entity
(NCE)
210,000 66,000 64,000 6,300 1,100
Generic Drugs 97,000 66,000 64,000 6,300 1,100
Biotechnological
Products
237,000 86,000 64,000 6,300 1,100
Other Drug Product
Classification
97,000 66,000 64,000 6,300 1,100
Republic of the PhilippinesDepartment of Health
Food and Drug Administration
37
CDRR ACCOMPLISHMENTS and
UPDATES
SUMMARY
38
Application Type No. of applications
received
No. of applications
processed
Backlog
LTO & other relatedrequests
6,846 3,899 2,947
CPR & other related requests
14,136 2,558 11,578
LATEST DECKING SCHEDULE
39
PRODUCT SCHEDULEInitial (Rx) Oct 2013Initial (HR-OTC) Oct 2013Monitored Release Oct 2013Automatic Renewal Dec 2014 (12/15)Renewal Apr 2014Monitored Release Extension
Apr 2014
PCPR Dec 2014CLIDP Dec 2014Revalidation UPDATED
LATEST DECKING SCHEDULE
40
PRODUCT SCHEDULEVariation (Others) Jul 2014Variation (SLE-SC) Aug 2014Variation (MiV-PA02) Jul 2014Variation (MiV-N01-10) Oct 2014Compliance Dec 2014PROMO UPDATEDCertification UPDATEDGLE UPDATEDVaccine (Initial & MR) Sep 2014Vaccine (Var-R-MRE) Nov 2014Veterinary Group May 2014
Republic of the PhilippinesDepartment of Health
Food and Drug Administration
UPDATES ON REGULATIONS
41
• FDA Circular – 7
2014-2015 CDRR Issued Regulations
42
FDA Circular No. 2014-025
43
FDA Circular No. 2014-026
44
FDA Circular No. 2014-027
45
FDA Circular No. 2014-028
46
FDA Circular No. 2015-003
47
FDA Circular No. 2014-025 to 026 and 2015-003
• Implementing rules and regulations of AO 2014-0034 for Drugstores, Drug Distributors, Drug Manufacturers, RONPDs, and Sponsors and CROs
48
FDA Circular No. 2015-001 and its amendment
49
FDA Circular No. 2015-001 and its amendment
50
FDA Circular No. 2015-001 and its amendment
• Clarification on the similarity of PCPR and CLIDP
• PCPR and CLIDP must be identical/similar following the definitions provided under AO 2005-0031
• Submission of appropriate variation applications until 31 December 2015
• Denial of incoming initial applications of CLIDP that are not compliant 51
Republic of the PhilippinesDepartment of Health
Food and Drug Administration
Target Regulations2nd Quarter 2015
52
1) LTO Format
2) Labeling Requirements
3) Risk Management Plan for Establishments
4) Licensing of Health Facilities Engaged in the Manufacture and Distribution of Medical Gases
5) Expedited Review of Prequalified Vaccines and WHO Collaborative Review Procedure
6) Fees and Charges
7) Q4 of 2015 – New Registration Guidelines
Targets53
Republic of the PhilippinesDepartment of Health
Food and Drug Administration
54
REGULATORY CHALLENGES
1. Misalignment of 1st yr DBM-approved staffing pattern against requested number and workload/expected output
2. Staff turn-over
3. Influx of applications w/o overseas GMP audit/poor GMP compliance
Challenges55
4. Increased demand for administrative and logistical support to operations– Lack of resources (computers)
– Needs stronger IT infrastructure
5. Increased demand for training and advocacy given the effects of harmonization and globalization, e.g., biosimilars, non-biologic complex drug (NBCD) products, radiopharmaceuticals, and Human Cells, Cellular and Tissue-based products (HCTPs)
Challenges56
Major Deficiencies Encountered
• Non-compliance to AO 2013-0021 (ACTD/ACTR Adoption):
– Not in ACTD/ICH-CTD Format
– Lacking Part (I, II, III, or IV)
• Non-compliance to AO 2013-0022 (Foreign GMP):
– No submitted application of foreign GMP evidence
57
Other Deficiencies Encountered
Noncompliance to FMC 2013-033 and FMC 2014-001 (Conversion to E-copy), and Memorandum on E-copy submission for compliance, revalidation, and re-applications:
• Corrupted files
• Empty folders
• Failure to submit e-copy of old files
58
Republic of the PhilippinesDepartment of Health
Food and Drug Administration
59
CONCLUSION
Conclusion
The CDRR still commits to
1. Reduce the backlog to 10% hoping for a more robustIT infrastructure, additional personnel and provisionof more desktops or laptops
2. Given the right resources, the CDRR is committed tospeed up the processing of applications
3. Continue working on the policies to provide clarity toour work process
60
THANK YOU!