ICH Update: Developments and Future Directions
IV Pan American Conference on Drug Regulatory Harmonization Boca Chica, Dominican Republic 2-4 March, 2005 Mike Ward Health Canada
A Unique Approach
International Conference on Harmonisation (ICH) was created in 1990 Agreement between the EU, Japan and the USA to harmonize different regional requirements for registration of pharmaceutical drug products Unique because joint effort by regulators and associated pharmaceutical industry trade associations
ICH Objectives
Identification and elimination of the need to duplicate studies to meet different regulatory requirements More efficient use of resources in the R&D process, as a consequence Quicker access for patients to safe and effective new medicines
Working Groups
SAFETY EFFICACY
QUALITY
MULTIDISCIPLINARY
STEERING COMMITTEE
Endorses topics, guidelines and monitors progress
Retrospective
ICH a mature harmonization initiative Over 50 technical guidelines, a dictionary of medical terms, electronic standards and a common format for drug registration Six ICH conferences to date, including ICH 6 in Osaka, Japan, November 2003 Witnessing increased interest in and use of ICH guidelines globally Formation and evolution of Global Cooperation Group (GCG)
Time to Reflect
Following over a decade of significant achievements in the harmonization of quality, safety and efficacy requirements for the registration of new drugs in the three ICH regions, is the work of ICH mostly done? Will ICH become a maintenanceonly organization?
No, however
Appropriate time to evaluate the future of ICH to ensure:
Proper balance between maintenance and new activities
New topics are of high value and objectives are
achievable Most efficient use and management of resources Flexible enough to deal with evolving science and technologies More transparent
ICH Output since 3rd Pan-Am Conference, April 02 (1)
New products:
Five technical guidelines:
3 Quality: Stability (Q1E, Q1F), Biotech comparability (Q5E) 2 Efficacy: post-approval safety (E2D) and pharmacovigilance
planning (E2E)
Specifications established for electronic submissions: eCTD Four Considerations documents: 3 on gene therapy, 1 on gender and clinical trials
ICH Output since 3rd Pan-Am Conference (2)
Responding to user needs and new data: maintenance, improvement, clarification activities:
Introduction of question and answers documents (M4CTD/eCTD, E5-ethnic factors, E2B(M)-transmission of safety case reports)
Revision of Quality guidelines on stability (Q1A) and
impurities (Q3B) Maintenance of limits for residual solvents (Q3C) New addendum to periodic safety update reports (E2C); `granularity` annex to Common Technical Document (CTD) guidance
ICH Output since 3rd Pan-Am Conference (3)
MedDRA:
Continual improvement: MedDRA version 8.0
scheduled for release March 2005 Now available in 8 languages, including Spanish and Portuguese New draft Points to Consider documents on term selection and data retrieval/presentation Release of first Standardized MedDRA Queries (SMQs) collaboration with Council for International Organization of Medical Services (CIOMS)
ICH: Developments and Future Directions
`Themes`:
New topics: facilitating innovation New topics: promoting safety/public health
Regulatory communication
Maintenance/implementation Mechanics of ICH Transparency and communication
New Topics: Facilitating Innovation
Examples:
Q5E: comparability of biotech/biological products subject to
manufacturing changes Q8: pharmaceutical development Q9: risk management application to quality requirements and practices
Serve to facilitate innovation and improvement More informed, risked-based approach to regulation Consistent with FDAs GMPs for the 21st Century initiative
New Topics: Promoting Safety/Public Health
Examples:
E2E: pharmacovigilance planning (completed) E14/S7B: QT prolongation (draft)
Topics identified by regulators Considered important in contributing to drug safety and public health Potential new pharmacovigilance topics to be considered by ICH following gap analysis of current regional guidelines
New Topics: Other projects
Q4B: regulatory acceptance of (Japanese, European and US) pharmacopeial interchangeability
Process established Piloting
S8: immunotoxicology
Nonclinical test methods and decision tree for assessing
immunosuppression caused by non-biologic pharmaceuticals
Regulatory Communication (1)
ICH has sought to enhance regulatory communication through the development of:
Standardized data elements, example: E2B Controlled vocabularies, example: MedDRA Common format for drug registration: CTD Electronic specifications and standards for the transmission of such information, example:
ESTRI and eCTD
Regulatory Communication (2)
Benefits:
Speak same language: promotes
communication Quality, accuracy and consistency of information Improve timeliness of communications (electronic transmission) CTD/eCTD reduces delays and costs associated with registration of drug applications
Regulatory Communication (3)
Status of CTD/eCTD implementation:
As of July 2003 CTD mandatory in EU and
Japan, highly recommended in US and Canada Integration of CTD in existing regulatory frameworks No significant difficulties encountered New era: eCTDs now being submitted in all ICH regions
Regulatory Communication (4)
New: M5: Data elements and standards for drug dictionaries:
For use in describing medicinal products and
active ingredients Controlled vocabulary includes units, routes of administration, pharmaceutical forms Electronic message specifications to be developed
Maintenance/Implementation (1)
Critical aspects of the ICH harmonization process considering need to ensure
continued relevance and improvement of an ever-
growing number of guidelines consistent and intended use by regulators and industry
Tools/mechanisms:
Qs and As, addenda, revisions, points to consider Change control and maintenance processes: eCTD,
E2B(M) and Q3C New: maintenance of ICH controlled terminology lists
Maintenance/Implementation (2)
Tools/mechanisms:
MedDRA maintenance and support service
organization (MSSO) Creation of implementation working groups (e.g., for CTD/eCTD, E2B(M)) and implementation tool (new) Implementation standing item on ICH Steering Committee agenda General procedures and roles/responsibilities under development
Mechanics of ICH
Given costs involved in harmonization activities, it is important that effective structure and procedures are in place to ensure maximum benefit is derived Periodic reassessment of mandate, procedures within context of Future of ICH Most recent review in progress: June 03 May 2005; focus includes:
selection of new topics: business case now required streamlining of procedures clarifying roles and responsibilities means of assessing implementation of guidelines Transparency and communication
Transparency and Communication
Reviewing current practices at regional and ICH level Options to be considered to strengthen transparency and communication GCG seen as increasingly important mechanism for communication and engagement with non-ICH regions and parties
Global Cooperation Group (GCG)
Established March 1999 as sub-committee of ICH Steering Committee Formed to respond to this growing interest in ICH guidelines Name reflective of desire to establish links with non-ICH regions Membership :
6 ICH parties 2 Observers (WHO and Health Canada) ICH secretariat
Initial Mandate
Initial focus on information-sharing Soon became clear that more active engagement necessary to respond to increasing interest in ICH and ICH guidelines
Evolution In GCG Activities and Thinking
Series of joint meetings with regional representatives in preparation for ICH6 satellite session Parallel discussions within GCG on need to be more relevant through establishing closer ties with regional harmonisation initiatives
Osaka, Nov. 2003: An Important Milestone
Endorsement by ICH SC of new Mandate and Terms of Reference that call for
the ongoing participation of regional
harmonization initiatives Greater transparency
Regional Harmonization Initiatives
APEC
Asia-Pacific Economic Cooperation
ASEAN
Association of the Southeast Asian Nations
GCC
Gulf Cooperation Council
PANDRH
Pan American Network for Drug Regulatory Harmonization
SADC
Southern African Development Community
PANDRH Representation
Initial selection during PANDRH Steering Committee meeting in Madrid (February 2005):
Dr. Carlos Chiale (ANMAT)
Dr. Davi Rumel (ANVISA)
Review scheduled for next Steering Committee meeting (March 2005)
GCG Meeting 16 November 2004, Yokohama, Japan
GCG Co-chairs: Dr. Yves Juillet (European Industry) Mr. Mike Ward (Health Canada)
GCG Role and Procedures
Definition of GCG membership
Maximum of 2 permanent representatives per
regional harmonization initiative Representatives should solicit/present views of regional initiatives
Criteria for harmonization initiative to participate in GCG GCG principles: openness and transparency
GCG Reflections Paper: Mission, Activities and Operations of GCG
Issue: While new terms of reference provide authority, tools and rules (the means), they do not define the mission of the new GCG (the ends) Mission/vision necessary to guide and validate future activities
Considerations (1)
Moving beyond bounds of ICH Serve as unique forum for harmonization initiatives to discuss
Best practices, lessons learned and innovative
approaches to harmonization and regulation ICH topics of interest Technical guidelines beyond scope of ICH
Considerations (2)
Managing expectations: resources, realistic objectives
GCG not a technical body
Funding issues
Stepwise approach build on successes
Draft Mission Statement
To promote a mutual understanding of regional initiatives in order to facilitate harmonisation processes related to ICH guidelines regionally and globally; and to strengthen the capacity of drug regulatory authorities and industry to implement them.
Areas of work
ICH technical guidelines Harmonization/regulation Training and capacity building
Identified Topics of Interest
CTD implementation and e-submission GCP implementation E5 implementation Pharmacovigilance guidelines and MedDRA implementation
Interest also expressed in: - technical assistance expressed - review process and data assessment - joint GCP inspections
Regional Meetings Identified
SADC January 05: implementation of ICH guidelines, including CTD ASEAN February 05: pharmacovigilance
Next Steps: Regional Input
Comments on draft ICH guidelines (Q8, S8, then Q9) Proposals for pharmacovigilance plenary session (May 05) Identification and presentation of guideline implementation and technical difficulties (formal presentations at GCG Brussels meeting) GCG teleconference organized for April 7, 2005 Next GCG meeting May 10, 2005 in Brussels
Summary
ICH continues to balance development of important new topics with maintenance and implementation activities New procedures and business case templates meant to improve efficiency and value of ICH process Transparency, communication and engagement through GCG seen as increasingly important