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EU Clinical Trial Regulation(CTR) EU Clinical Trial Regulation(CTR)

EU Clinical Trial Regulation(CTR) - PowerPoint Presentation

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EU Clinical Trial Regulation(CTR) - PPT Presentation

Are you prepared November 2015 AN Moult Employment Disclaimer The views and opinions expressed in the following PowerPoint slides are those of the individual presenter They are brought together as a result in participation in EFPIA Technical Development Expert Group and its Work ID: 632077

ctr clinical legislation part clinical ctr part legislation directive trial annex portal assessment regulation amp cms law conclusion act

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Slide1

EU Clinical Trial Regulation(CTR)

Are you prepared

November 2015

A.N. MoultSlide2

Employment Disclaimer

The views and opinions expressed in the following PowerPoint slides are those of the individual

presenter. They

are

brought together as a result in participation in EFPIA Technical Development Expert Group and its Work

Groups however they are not formal EFPIA policy

The views and opinions expressed in the following PowerPoint slides are those of the individual presenter and should not be attributed to the company the speaker is employed by (Daiichi-Sankyo Development or any other Daiichi-Sankyo Group companies) Slide3

Contents

CTR status

Stages and their currently projected timings

CTR highlights

One point of application

Consequential legal changes (delegated acts) for IMPs and their status

Areas for clarification and or concernSlide4

Approval & implementation

4

27 May 2014

Q4/2017

(estimate)

Q4/2018*

Q4/2020*

EU-CTD

EU-CTR

Publication

Earliest applicability *

Applicability

Repealed by EU-CTR

A

B

A: Clinical trials may still be submitted and started under EU-CTD

B: Clinical trials submitted under A may continue to be governed by EU-CTD until Q1/2020 (earliest)

Reference: EU-CTR Article 98

*Subject to EMA IT development (EU-CTR Article 82)

17 June 2014

Entry into force

Independent audit of EU Portal & Database functionality published in Official Journal 6-months before applicationSlide5

CTA simplification

Regulation Art. 5, 6, 7 and 8Slide6

Outline

of clinical trial

authorisation (CTA)

dossier content

One

Dossier

Classification as a low-intervention clinical trial

Therapeutic & public health benefit aspects

Risks & inconveniences for the subject

Manufacturing/importation of IMPs/AMPs

IMPD

Labelling

Investigator

s brochure

Part I – «General»

Part II – «National»

EU Portal (by EMA)

Content

Submission

Informed consent

Compensation/ rewarding arrangements

Recruitment arrangements

Data protection rules

Suitability of

- individuals

- trial sites

Damage compensation

Biological samplesSlide7

CT Authorisation Concept (simplified

)

Regulation Art. 5, 6, 7 and 8

Dossier (Part I & II)

Submission to EU Portal

Part I Assessment report & conclusion

Confirmation of

rMS

and Validation

45-76 days*

Part II

Assessment

report & conclusion

Default:

No opt-out of

cMS

cMS

accepts positive conclusion of assessment report

Exception:

Qualified opt-out scenarios

Inferior treatment compared to

normal clinical practice

in

cMS

Infringement of national legislation (on use of cells)

Disagreement with conclusion based on safety, data reliability and robustness

Not acceptable

Acceptable

(w/wo conditions)

EU Portal – One Single

decision

per

cMS

and Notification

45-76 days*

Part I – «General»

Lead: reporting MS (rMS)

Part II – «National»

Lead: concerned MS (

cMS

)

Start of Clinical trial Art. 2(25)

rMS conducts review, drafts AR, cMS comment, rMS incorporates input from cMS**

5 days

Conclusion of

national assessment Part II

If no notification

:

Conclusion of

Part I

Assessment report shall be considered the decision

(tacit approval)

10 -25 days

Validation

Assessment

Decision

* Maximal timeline with clock stop for questions.

**

rMS

can extend assessment time by 50 days for ATMPs and products derived from rDNA technology Slide8

Directive v’s CTR additional legal landscape

Legislation / Other document

CTD (2001/20/EC)

CTR (536/2014)

Status

GMP

Directive for MP and IMP

Directive 2003/94/EC

Will be Implementing act for MP – Legal

basis 2001/83/EC and Delegated Act for IMP – Legal basis 536/2014Both under consultation until 24 Nov 2015 - Industry commenting via EFPIA and a draft response has been prepared. Annex 13 Annex 13 A detailed guidance for IMP Under consultation until 24 Nov 2015 - Industry commenting via EFPIA and a draft response has been preparedNIMPCovered by CTR only (as AMPs)Detailed Guidance is not anticipatedSlide9

Some changes to terminology and Trial Definition

Low-

Interventional Clinical Trial

Commercial product within the MA or strict boundaries away from MA

Aimed at Clinical Practice improvement rather than new product / indication

Less stringent rules (at least intended only opinions vary)

Auxiliary

Medicinal Product (covered by Esther). Tip read labelling requirements very carefully.Very easy to miss read and think everything has to be re-labelled Slide10

Areas for clarification and or concern

It is a significant change in the way Clinical Trials are instigated

The portal is taking shape only taking time

Outside of the world of IMP many other functions are undergoing preparations for the changes at a time of significant political pressure on many aspects of health care and drug development.

There are some aspects of the CTR that Industry / EMA (inspectorate) and Commission are now only understanding as demonstrated in the consultation on “delegated acts”, portal etc. for IMP these include

Annex VI. identified early – current status – no change

Inspections outside EU

UK specific – Transitional QPs – ( R. Smith)

In many functional areas questions are being raised and pragmatic solutions found. Slide11

How prepared is your company

Do you have a cross functional preparedness program / initiative

SOPs for all functions

Most companies will be looking at the impacts via SOPs.

Most SOPs will not change or be very minor such as substitution for references - 2001/20/EC to 536/2014.

A significant minority of SOPs will have a major re-write over terminology

A small number of processes will change significantly – Such as around submissions via the EU Portal

Are these identified and plans in place to work differently even if the exact details are not fully known e.g. Portal information –

Worse case - Exactly how it works will emerge around Mid 2017 after the audit or emerging elements may become clear as it is built in 2016.

Slide12

How prepared is your company continued

IMP preparation.

SOP as previous

Annex VI

Even with Annex VI worst case perhaps 80% of studies will not be impacted

Are the 20% identified and what is the cost of mitigation or other changes needed.

If Annex VI does not change waiting to find out may be too late

Is a subset of the preparedness program looking at the Consultation documents – Delegated Act and Detailed Guidance on GMP for IMPs as well as in the GCP aspects of Inspections of Trials by MS’sSlide13

Questions and AnswersSlide14

Clinical trials - Regulatory framework

Transcribed into national law – UK Medicines Act – additional national requirements

Good Clinical Practice

1996

Transcribed into EU Member State law

Declaration

of Helsinki

Good Clinical Practice

Directive 2005Slide15

Understanding EU law

A simple view

A Directive = EU legislation that requires member states to enact via their own legislation the provisions of the directive.

It sets a minimum standard only each member state is allowed to make more stringent provisions as it translates the directive into national law

A Regulation = EU legislation that becomes law in all member states.

It needs no further legislation and is identical in all member states

Delegated act – The What

May be a Regulation or Directive that stems from primary legislation

Are

considered closer to actual law-making The extent of the delegation has to be clearly determined in the original legislation Their content is more likely to be politically sensitive. Implementing act – The HowMay be a regulation or Directive that stems from primary legislationIs considered to be inherently more procedural (templates, procedures, deadlines)A pure, practical implementation of rules that already exist in the original legislation. Slide16

Back up slides

Annex VI

For those who are not aware of EFPIA concerns the video is available.   

http://www.youtube.com/embed/5bPZb_Ezg1Y?rel=0

Points to consider in any implementation plans for Annex VI compliance

the type of pack and duration of study including potential for date extension

the time during the one year transition period after Q4 2017 that your company wishes to submit CTA . In addition, you may wish to consider if the choice of timing should be dependent on the pack type / study length or other factors.

if the trial will be ongoing beyond the Q4 2020, which is the earliest point at which all clinical trials in Europe should be compliant with the Regulation. If so will the label strategy be compliant currently or will a change in design mid study be employed?