Monthly Archives: July 2010

EMA, The European Herbal Regulator, Publishes Assessment Report on Leonurus Cardiaca L., Herba (Motherwort)

EMA, The European Herbal Regulator, Publishes Assessment Report on Leonurus Cardiaca L., Herba (Motherwort)

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Herbal substance(s)
Leonuri cardiacae herba, Motherwort Ph. Eur. 6.0: Whole or cut, dried flowering parts of Leonurus cardiaca L. Content: minimum 0.2% of flavonoids, expressed as hyperoside (Ph. Eur. 01/2008:1833 corrected 6.0).
Herba Leonuri cardiacae EB6: Dried above-earth parts of Leonurus cardiaca L. var. villosus (DESF.) BENTHAM, collected during the flowering season (July – September) (EB6). This variety is covered by the definition of the Ph. Eur.
Motherwort, Leonuri cardiacae herba (BHP 1974, 1990, 1994):
The dried aerial parts of Leonurus cardiaca L. collected when the plant is in flower. This definition is covered by the Ph. Eur.

Herbal preparation(s)
powdered herbal substance (BHP 1994)
tincture 1 : 5, ethanol 70% V/V (Latvia, Mashkovskij 1972, Krylow 1993, Sokolov 1984)
tincture 1 : 5, ethanol 45% V/V (BHP 1974, Barnes 2007)
liquid extract 1 : 1, ethanol 25% V/V (Wichtl 2002, 2009, Bradley 1992, BHP 1974, Barnes 2007)
tincture 1 : 5, ethanol 34% V/V (Wichtl 2002, 2009)
tincture 1 : 5, ethanol 25% V/V (Bradley 1992)
dry extract 8-9 : 1, ethanol 40% m/m (Finzelberg 2000, Germany since 1993)
dry extract 7.5-8.8 :1, ethanol 40% m/m (Germany since 1994)
Combinations of herbal substance(s) and/or herbal preparation(s) including a description of vitamin(s) and/or mineral(s) as ingredients of traditional combination herbal medicinal products assessed, where applicable.

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EMA, The European Herbal Regulator, Publishes Assessment Report on Trigonella Foenum-graecum L., Semen (Fenugreek Seed)

EMA, The European Herbal Regulator, Publishes Assessment Report on Trigonella Foenum-graecum L., Semen (Fenugreek Seed).

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The aim of this report is to assess the non-clinical and clinical available data on Trigonellae foenugraeci semen for preparing a Community herbal monograph. This report is based on the documentation published in the literature

Herbal substance(s)
Fenugreek seed

Herbal preparation(s)
Powder, dry extract, soft extract
Fenugreek seed is rich in mucilage polysaccharide (consisting mainly in galactomannans 25–45%) and contains a small amount of essential oil (0.015%) and a variety of secondary metabolites, including protoalkaloids, trigonelline (up to 0.37%), choline (0.05%); saponins (0.6–1.7%) derived from diosgenin, yamogenin, tigogenin and other compounds; sterols including β-sitosterol; and flavonoids, among which are orientin, isoorientin and isovitexin (WHO, 2007). Furthermore, the nutrition composition of fenugreek seeds is : moisture 2.4 %, protein 30 %, lipids 7 %, saponins 4.8 %, total dietetary fibre 48.% (insoluble 28.%, soluble 20.%), and ash 3.9 % (WHO, 2003; ESCOP 2003; MURALIDHARA et al, 1999; BRUNETON 1998; RAO et al, 1996; PARIS AND MOYSE, 1967.
The European Pharmacopoeia does not prescribe any assay (monograph ref. 01/2008:1323 corrected 6.6).
Combinations of herbal substance(s) and/or herbal preparation(s) including a description of vitamin(s) and/or mineral(s) as ingredients of traditional combination herbal medicinal products assessed, where applicable.

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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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“Having worked alongside Damien for the past year, helping to create new businesses based on innovative scientific research, I would highly recommend his services. Damien’s experience and extensive, up-to-the-minute knowledge added significant value to each and every one of the commercialisation projects he mentored. His perception is excellent and his ability to identify and nurture good business propositions is second-to-none. On a personal level, Damien is an absolute pleasure to work with.”

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EMA, the European Herbal Regulator, Publishes Overview of Comments Received on Community Herbal Monograph on Ribes Nigrum L., Folium (Blackcurrant Leaf)

EMA, the European Herbal Regulator, Publishes Overview of Comments Received on Community Herbal Monograph on Ribes Nigrum L., Folium (Blackcurrant Leaf)

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ESCOP appreciates the draft for a Community Herbal Monograph on “blackcurrant leaf” prepared by the Committee on Herbal Medicinal products (HMPC). However, we consider the following modification necessary.

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FDA, the USA drug regulatory, Publishes Draft Recommendation for the Revision of the Permitted Daily Exposure for Cumene According to the Maintenance Procedures for Q3C Impurities: Residual Solvents

FDA, the USA drug regulatory, Publishes Draft Recommendation for the Revision of the Permitted Daily Exposure for Cumene According to the Maintenance Procedures for Q3C Impurities: Residual Solvents.

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Cumene [synonyms: Cumol; isopropylbenzene; isopropylbenzol; (1-methyl/ethyl)benzene; 2phenylpropane]
is listed in the ICH Q3C guideline in Class 3, i.e. as a solvent with low toxicity. A summary of the toxicity data used by the EWG to establish a Permitted Daily Exposure (PDE) value for cumene at the time when the ICH Q3C guideline was signed off at Step 2 in November 1996 is published in Connelly et al., 1997 (1).
According to this report from the EWG no data from carcinogenicity studies with cumene were available. Regarding genotoxicity data cumene was reported negative in an Ames test and in Saccaromyces cerevisiae and positive in in vitro UDS and cell transformation assays using mouse embryo cells. Calculation of a PDE value was based on a rat toxicity study published in 1956. Female Wistar rats were given cumene at doses of 154, 462 and 769 mg/kg by gavage 5 days/week for 6 months. No histopathological changes but slight increases in kidney weights at the two higher doses were observed suggesting a NOEL of 154 mg/kg. It was concluded that the PDE for cumene is 55.0 mg/day i.e., cumene is a solvent with low toxicity to be listed in Class 3.
Meanwhile new toxicity data have been published including results from NTP 2-year inhalation studies showing that cumene is carcinogenic in rodents. A reappraisal of the PDE value of cumene according to the maintenance agreement from 1999 is therefore initiated. For establishing a revised PDE value in this document the standard approaches (modifying factors, concentration conversion from ppm to mg/L, values for physiological factors) as described in detail in Connelly et al. (1) were used.

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EMA, The European Herbal Regulatory Body, Publishes Assessment Report on Ribes Nigrum L., Folium (Blackcurrant Leaf)

EMA, The European Herbal Regulatory Body, Publishes Assessment Report on Ribes Nigrum L., Folium (Blackcurrant Leaf)

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Handbooks as well as publications (PubMed & local journals) were used as sources. Keywords: Ribes nigrum, blackcurrant, cassis. Herbal substance(s)
Blackcurrant leaf consists of the dried leaves of Ribes nigrum L. (blackcurrant), belonging to the family of the Grossulariaceae. The genus Ribes contains between 140 and 150 species. The leaves are collected during or shortly after flowering (Pharm. Française 1996; Hänsel et al. 1994).
A dark green upper surface and a pale greyish green lower surface is characteristic for the slightly wrinkled leaf fragments. Furthermore a widely spaced reticulate venation is particularly distinct on the lower surface. Glands can be seen as scattering yellowish dots. In contrast with the fresh leaves, the dried leaves have no odour or taste. There are no falsifications as the herbal substance is harvested from cultivation (Wichtl 1994; Hänsel et al. 1994).
The dried Ribes nigrum leaf contains not less than 1.5% of flavonoids, expressed as rutin. The material complies with the monograph of the Pharmacopée Française (1996) (ESCOP, 2003).

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FDA, the USA Drug Regulator, Published Q4B Evaluation of Pharmacopoeial Texts for Use in the ICH Regions: Annex 14: Bacterial Endotoxins Text General Chapter

FDA, the USA Drug Regulator, Published Q4B Evaluation of Pharmacopoeial Texts for Use in the ICH Regions: Annex 14: Bacterial Endotoxins Text General Chapter.

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This annex is the result of the Q4B process for the Bacterial Endotoxins Test General Chapter. The proposed texts were submitted by the Pharmacopoeial Discussion Group (PDG).

The ICH Steering Committee, based on the evaluation by the Q4B Expert Working Group (EWG), recommends that the analytical procedures described in the official pharmacopoeial texts, Ph.Eur. 2.6.14. Bacterial Endotoxins, JP 4.01 Bacterial Endotoxins Test, and USP General Chapter <85> Bacterial Endotoxins Test, can be used as interchangeable in the ICH regions subject to the following conditions:

Any of the three techniques can be used for the test. In the event of doubt or dispute, the gel-clot limit test should be used to make the final decision on compliance for the product being tested.

The Endotoxin Reference Standard should be calibrated to the current WHO (World Health Organization) International Standard for Endotoxin.

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EMA, The EU Herbal Regulator, Publishes List of References Supporting the Assessment of Ribes Nigrum L., Folium; Blackcurrant Leaf

EMA, The EU Herbal Regulator, Publishes List of References Supporting the Assessment of Ribes Nigrum L., Folium; Blackcurrant Leaf.

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The MHRA, the UK drug Regulators, Published a Reminder – Update to Labelling to Comply with Article 54(a), 54(e) and 56(a)

The MHRA, the UK drug Regulators, Published a Reminder – Update to Labelling to Comply with Article 54(a), 54(e) and 56(a).

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The legislation provided a transitional period for the labelling of medicines which were the subject of a granted marketing authorisation at the time the regulations came into force on 30 October 2005. This transitional period ends on 30th October 2010 by which time the necessary applications must have been approved to bring the marketing authorisations into compliance.
The new requirements for labelling under the articles cited above are as follows:
• Following the brand name of the medicine (where one has been registered) the packaging must include reference to the common name(s) of the active substances in the formulation (where up to three active substances are present in the formulation). The common name(s) must be prominently displayed on the packaging.
• Space for the prescribed dose to be indicated – in the UK this is in the form of space for a dispensing label to be indicated on the outer packaging. Such space should be 35mm by 70mm in size. Although not required by the legislation, best practice suggests that the space should be marked on the pack and appear on a face where the name of the medicine is displayed.
• The name registered in section 1 of the summary of product characteristics must be displayed in Braille on the packaging.
Detailed guidance on how to apply for these changes and the criteria which apply are available from the MHRA website.

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EMA, the European Drug Regulator, Publishes Draft Guidance on Detection and Management of Duplicate Individual Cases and Individual Case Safety Reports (ICSRs)

EMA, the European Drug Regulator, Publishes Draft Guidance on Detection and Management of Duplicate Individual Cases and Individual Case Safety Reports (ICSRs).

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Duplicate cases can pose significant problems for analysing signals arising from pharmacovigilance databases, both artificially inflating and masking signals of disproportionate reporting. The current reporting rules guarantee duplicate reporting.
Databases should be routinely screened to detect and eliminate duplicate cases. This guideline proposes methods for detecting, confirming and managing duplicate cases suitable for organisations receiving pharmacovigilance data in various different formats.

Volume 9A of The Rules Governing Medicinal Products in the European Union – Guidelines on Pharmacovigilance for Medicinal Products for Human Use1 and Volume 10 of The Rules Governing Medicinal Products in the EU2 provide detailed guidance on the reporting of suspected (unexpected) serious adverse reactions in compliance with the legal provisions laid dawn in Regulation (EC) No 726/2004, Directive 2001/83/EC as amended and Directive 2001/20/EC.
Guidance is also provided for situations where individual cases might be reported by different senders e.g. where a MAH is aware that a healthcare professional has reported an adverse reaction to one of the medicinal products, for which he holds a marketing authorisation, to the Competent Authority of a Member State. Volume 9A states that the MAH should still report the adverse reaction, informing the Competent Authority that the report may be a duplicate of a previous report. In this situation, it is essential for the MAH to provide all the available details including all case identification numbers allocated to the case, in order to aid identification of the duplicate.
Based on the current reporting rules and reporting practices, duplication of individual cases can occur. A duplicate refers to the same individual case reported by a primary source to describe suspected adverse reaction(s) related to the administration of one or more medicinal products to an individual patient at a particular point of time. This individual case may be reported by different senders, through different routes, whereby the case information may be handled differently by the processor of the case, which makes it difficult to identify the reported cases as duplicates. Case handling refers e.g. to coding practices, obtaining follow-up information and processing of personal data in line with EU Data Protection legislation.
Detection and handling of duplicates by National Competent Authorities (NCAs), Marketing Authorisation Holders (MAHs) and Sponsors of clinical trials (Sponsors) is an important element of good case management. The presence of duplicates in any pharmacovigilance system can create misleading signals and therefore impact on the safety monitoring and potential regulatory actions. How duplicates can impact on the identification of potential new safety issues can be illustrated by an example of duplication in the US FDA Adverse Events Reporting System (AERS) database. In an evaluation of quinine-induced thrombocytopenia, FDA researchers identified 20% of 141 reports as duplicates.3 Norèn et al.4 highlighted that since commonly used data-mining procedures may highlight associations with as few as three reports, one or two duplicates may severely affect their utility.

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EMA, the European Drug Regulators, Publish Draft Guidance on Non-Clinical and Clinical Aspects of Medical Products Containing Geneticaly Modified Cells

EMA, the European Drug Regulators, Publish Draft Guidance on Non-Clinical and Clinical Aspects of Medical Products Containing Genetically Modified Cells.

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This guideline defines scientific principles and provides guidance for the development and evaluation of medicinal products containing genetically modified cells intended for use in humans. Its focus is on the quality, safety and efficacy requirements of genetically modified cells developed as medicinal products.

Genetically modified cells may be developed either for therapeutic use (gene therapy medicinal products) or to use the genetic modification in the manufacturing process of a cell therapy / tissue engineering product.
The following are some examples of medicinal products containing genetically modified cells (GMC) that have been used in clinical trials:

genetically modified cells for treatment of monogeneic inherited disease;

genetically modified dendritic cells and cytotoxic lymphocytes for cancer immunotherapy;

genetically modified autologous chondrocytes for cartilage repair; genetically modified progenitor  cells for cardio-vascular disease treatment or for in vivo marking studies, particularly for in vivo biodistribution or in vivo differentiation analysis;

genetically modified osteogenic cells for bone fractures repair; genetically modified cells for 66 infectious disease treatment.
This guideline defines scientific principles and provides guidance to applicants developing medicinal products containing genetically modified cells. It is recognised that this is an area under constant development and guidance should be applied to any novel procedures as appropriate.

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Market Report on Life Sciences and Healthcare Sector Forecasts

Market Report on Life Sciences and Healthcare Sector Forecasts

Published by Rodman and Renshaw and EpstineBeckerGreen full Text Here

Based on interviews with over 75 healthcare investors in the US, this report offers valuable insight into emerging trends in investment activity, as well as a detailed forecast for specific subsectors, including biotechnology and pharmaceuticals; medical devices; healthcare providers and payors; and healthcare services.

Respondents to this survey unanimously agree that healthcare M&A activity will either increase or remain at its current level over the next 12 months. The biotechnology and pharmaceuticals subsector and the healthcare services subsector are particularly likely to witness a significant increase in M&A during this time, according to 87% and 83% of respondents, respectively.

Investment patterns are likely to vary according to industry over the next 12 months. Strategic buyers are likely to be most active in the biotechnology and pharmaceuticals subsector, following on a recent wave of large-cap deals including the US$68bn Pfizer-Wyeth merger and the US$44bn Roche-Genentech merger. Financial buyers, on the other hand, are likely to focus their attention on the healthcare services space, where recent private equity buyouts include TPG Capital’s US$5.3bn acquisition of IMS Health.

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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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EMA, the European Drug Regulator Published Draft Reflection Paper on the Co-development of Pharmacogenomic Biomarkers and Assays in the Context of Drug Development.

EMA, the European Drug Regulator Published Draft Reflection Paper on the Co-development of Pharmacogenomic Biomarkers and Assays in the Context of Drug Development.

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The increasing knowledge of variation within the human genome is being used for the development of34 personalised and stratified medicine, with the aims of decreasing the number of adverse drug reactions and increasing the efficacy of drug therapy. Significant pharmacogenomic research has focused on understanding the molecular mechanisms underlying certain adverse drug reactions and on recognising biomarkers (BMs) that identify individuals at risk. A genomic biomarker (in this document referred to as PGBM) is a measurable DNA and/or RNA characteristic that is an indicator of normal biologic processes, pathogenic processes, and/or response to therapeutic or other interventions. The co-development of drugs and PGBMs may open new and often contentious issues: they need to be addressed in the different contexts of PGBM use, moving progressively from PGBM discovery to PGBM use in non-clinical phases and finally to clinical phases of drug development. An individual assay implies a specific test method, reagents and platform which are developed and validated together for the detection, choice and measurement of specific PGBMs. The assay may be subject to performance evaluation during a qualification process independently of a specific drug under development consideration. The level of scientific stringency applied to the assay will depend on the knowledge accumulated about the PGBM and the drug(s) under consideration, as well as the implication of its use. It is recognised that for well established PGBMs relevant to drug developments such as the CYP 450 polymorphic enzymes, there are commercially available in vitro diagnostic medical devices (IVDs). However, for discovery PGBMs, when initially used specifically in non-clinical toxicity or pharmacology studies, and planned to be used afterwards in the clinical drug development context, either customization of existing assays or new development of specific tests may be needed (e.g. assays to identify PGBMs based on new splicing iso-forms or new mRNA profiles.

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EMA, The European Drug Regulator Publishes Draft Guidance on ICH Topic Q3C (R4), Impurities: Residual Solvents PDE for Cumene

EMA, The European Drug Regulator Publishes Draft Guidance on ICH Topic Q3C (R4), Impurities: Residual Solvents PDE for Cumene

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Cumene [synonyms: Cumol; isopropylbenzene; isopropylbenzol; (1-methyl/ethyl)benzene; 2- phenylpropane] is listed in the ICH Q3C guideline in Class 3, i.e. as a solvent with low toxicity. A summary of the toxicity data used by the EWG to establish a Permitted Daily Exposure (PDE) value for cumene at the time when the ICH Q3C guideline was signed off at Step 2 in November 1996 is published in Connelly et al. (1). According to this report from the EWG no data from carcinogenicity studies with cumene were
available. Regarding genotoxicity data cumene was reported negative in an Ames test and in Saccaromyces cerevisiae and positive in in vitro UDS and cell transformation assays using mouse embryo cells. Calculation of a PDE value was based on a rat toxicity study published in 1956. Female Wistar rats were given cumene at doses of 154, 462 and 769 mg/kg by gavage 5 days/week for 6 months. No histopathological changes but slight increases in kidney weights at the two higher doses were observed suggesting a NOEL of 154 mg/kg. It was concluded that the PDE for cumene is 55.0 mg/day i.e., cumene is a solvent with low toxicity to be listed in Class 3. (1) Meanwhile new toxicity data have been published including results from NTP 2-year inhalation studies showing that cumene is carcinogenic in rodents. (2) A reappraisal of the PDE value of cumene
according to the maintenance agreement from 1999 is therefore initiated. For establishing a revised PDE value in this document the standard approaches (modifying factors, concentration conversion from ppm to mg/L, values for physiological factors) as described in detail in Connelly et al. (1) were used.

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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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EMA, the EU Drug Regulator, Published Draft Guidance on the Procedural Advices on the Submission of Variations for Annual Update of Human Influenza Inactivated Vaccines Applications in the Centralised Procedure.

EMA, the EU Drug Regulator, Published Draft Guidance on the Procedural Advices on the Submission of Variations for Annual Update of Human Influenza Inactivated Vaccines Applications in the Centralised Procedure.

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Seasonal influenza vaccines for human use authorised via the centralised procedure in accordance with Regulation (EC) No 726/2004, must be varied annually according to Article 18 of Commission Regulation (EC) No 1234/2008 and the Commission “Guideline on the operation of the procedures laid down in Chapters II, III and IV of Commission Regulation (EC) No 1234/2008 of 24 November 2008 as well as on the documentation to be submitted pursuant to these procedures”. This document describes the specific procedure, timelines and data requirements for the adoption of an opinion of such change(s) by the CHMP, without jeopardising public health.

Every year, in general in mid February, a meeting of WHO experts takes place in Geneva, leading to a recommendation on the influenza A and B virus variants which should be used for the production of vaccine for the coming season worldwide. However, there remains flexibility within these recommendations to take into consideration the specificities of European Union epidemiological situation and adapt these recommendations as appropriate. In this respect, for instance, the European Medicines Agency (thereafter The ‘Agency’) publishes also yearly in their EU recommendation the use of reassortants for the manufacture of inactivated vaccines.
The EU wide decision regarding influenza virus strains for vaccine production for the next season is published further to the annual EU Ad Hoc influenza working party meeting which takes place at the Agency (usually mid/end of March, every year).
Further to the publication of the specific EU annual influenza virus strains, manufacturers start the production of each monovalent bulk(s). As soon as the reagents for standardisation are made publicly available by the WHO collaboration centres, the manufacturers will qualify monovalent bulks and will produce and release pilot/full scale of batches of the specific annual influenza vaccine for clinical trials. These clinical trials will start further to national regulatory clinical trial applications’ approvals.
As soon as the quality documentation is available, the manufacturer/MAH will submit it to the Agency, so that the Rapporteur will initiate its review. In general, the Agency’s Scientific Committee, the CHMP, should be able to adopt an opinion at its July plenary meeting or at the latest by written procedure within the timeframes defined in Article 18 of Commission Regulation (EC) No 1234/2008 (see further details of the procedure, timelines in section 4.1).
Once the clinical documentation is available, it is submitted to the Agency, which, further to the Rapporteur’s assessment, will enable the CHMP to adopt its final opinion, which will be transmitted to the European Commission (EC) and the Marketing Authorisation Holder (MAH), as appropriate.

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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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FDA, the US Drug Regulator, Publishes Q4B Evaluation and Recommendation of Pharmacopoeial Texts for Use in the ICH Regions, Annex 13: Bulk Density and Tapped Density of Powders General Chapter

FDA, the US Drug Regulator, Publishes Q4B Evaluation and Recommendation of Pharmacopoeial Texts for Use in the ICH Regions, Annex 13: Bulk Density and Tapped Density of Powders General Chapter

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This annex is the result of the Q4B process for the Bulk Density and Tapped Density of Powders General Chapter.  The proposed texts were submitted by the Pharmacopoeial Discussion Group (PDG).

Analytical Procedures
The ICH Steering Committee, based on the evaluation by the Q4B Expert Working Group (EWG), recommends that the analytical procedures described in the official pharmacopoeial texts, Ph.Eur. 2.9.34. Bulk Density and Tapped Density of Powders, JP  3.01 Determination of Bulk and Tapped Densities, and USP General Chapter Bulk Density and Tapped Density of Powders, can be used as interchangeable in the ICH regions subject to the following conditions:

  • For Bulk Density Method 2, the tolerance of the cup volume should be 16.39 ±0.20 milliliters (mL).
  • For Tapped Density Method 3, the test conditions, including tapping height,should be specified in the results.
  • For Measures of Powder Compressibility, if V10 is used, it should be clearly stated in the results.

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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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MHRA, the UK Regulators, Publish Guidance on the Vigilance System for CE-Marked Medical Devices, Cardiac Ablation Catherters

MHRA, the UK Regulators, Publish Guidance on the Vigilance System for CE-Marked Medical Devices, Cardiac Ablation Catheters

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This guidance document gives advice to manufacturers on the notification of adverse incidents involving cardiac ablation catheters (CACs) under the Medical Devices Vigilance System. It is intended to facilitate the uniform application and implementation of Medical Devices Directive 93/42/EEC as amended by 2007/47/EC. It is supplementary to, and should be read in conjunction with, the European Commission Guidelines on a Medical Devices Vigilance System, and MHRA’s Directives Bulletin 3, Guidance on the operation of the EU vigilance system in the UK.
This guidance sets out the Medicines and Healthcare products Regulatory Agency’s (MHRA) views on the interpretation of the Medical Devices Regulations. It should not be considered to be an authoritative statement of the law in any particular case as it is intended as guidance only. Manufacturers and others should consult the legislation referred to, making their own decisions on matters affecting them in conjunction with their lawyers and other professional advisers. The MHRA does not accept liability for any errors, omissions, misleading or other statements in the guidance whether negligent or otherwise. An authoritative statement could be given only by the courts.

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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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EMA, the European Drug Regulator Publishes Reflection paper on Quality, Non-Clinical and Clinical Issues related to the Development of Recombinant Adeno-Associated Viral Vectors

EMA, the European Drug Regulator Publishes Reflection paper on Quality, Non-Clinical and Clinical Issues related to the Development of Recombinant Adeno-Associated Viral Vectors

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Recombinant adeno-associated viral (rAAV) vectors are derived from the single stranded DNA virus adeno-associated virus which belongs to the genus dependovirus within the Parvoviridae family. As the name suggests the wild type virus is incapable of independent replication and relies on co-infection of a helper virus to enable a lytic replication cycle (Gonclaves, 2005). Adenovirus (Ad), herpes simplex virus (HSV), pseudorabies virus (PrV) and human papilloma virus (HPV) are known to support wild type AAV replication.
Infection with wild-type AAV is not associated with any pathogenic disease, and in the absence of a helper virus co-infection, the virus may integrate into the host cell genome or remain as an extrachromosomal form (Schnepp, 2005). In both situations the virus appears to remain latent. In-vitro studies suggest that wild-type viral DNA integration can occur occasionally in a site specific manner (19q13.3) (Kotin, 1990 and 1991 and 1992), but only at very high multiplicities of infection (Hüser, 2002), and this was originally considered to be a safety feature of vectors derived from this virus. However, it has been subsequently shown that site specific integration is dependent on the presence of both the inverted terminal repeats (ITR) and the Rep gene products (Weitzman, 1994; Linden, 1996), the latter of which is not present in rAAV; as such the site specific integration feature of these vectors is lost. The level of integration of DNA into the cellular chromosome in in-vivo models, however remains contentious. Nonetheless, long term protein expression (in-vivo) from the gene of interest inserted into rAAV vectors has been observed (Flotte, 1993; Kaplitt, 1994; Conrad, 1996; Monahan, 1998; Donahue, 1999; Stieger, 2006), even in the absence of identifiable genetic integration (Miller, 2004; Song, 2004; Flotte, 1994). This persistence is thought to be derived from stable concatemerized duplex genome forms (circular or linear molecules) that are transcriptionally active (Duan, 1998; Yang, 1999; Fisher, 1997).
Examples of diseases studied include haemophilia B (Manno, 2006 and 2003), cystic fibrosis (Flotte, 2003), Parkinson’s disease (Kaplitt, 2007), rheumatoid arthritis (www.targen.com [tgAAC94]), Leber’s congenital amaurosis (Bainbridge, 2008; Maguire, 2008; Jacobson, 2006), infantile neuronal ceroid lipofuscinosis (Worgall, 2008) and muscular dystrophy (Xiao, 2000). Furthermore non-clinical studies indicate rAAV expressing heterologous antigenic sequences (HPV16 – Kuck, 2006; HIV – Xin, 2001 and 2002; SIV – Johnson, 2005; malaria – Logan, 2007) can illicit both humoral and cellular immune responses, and modest immunogenicity has been reported in a phase I/II study using rAAV2 encoding HIV antigens (Mehendal, 2008). However, it has been suggested that cellular responses to the transgene products of rAAV vectors may be impaired (Lin, 2007), as such the utility of these vectors when used for prophylactic purposes needs further investigation.
There are currently 6 confirmed serotypes of adeno-associated virus (AAV-1 to -6) and 2 tentative species (AAV-7 and icon cool EMA, the European Drug Regulator Publishes Reflection paper on Quality, Non Clinical and Clinical Issues related to the Development of Recombinant Adeno Associated Viral Vectors (source: International Committee on Taxonomy of Viruses [ICTV]). However there are a number of publications describing additional serotypes (i.e. 9 and 10) which are currently not recognized by the ICTV. It is likely therefore, that there are significantly more serotypes circulating that have currently not been formally identified or recognized (Pacak, 2006; Limberis, 2006; Gao, 2004). Nonetheless, the majority of the 67 clinical trials undertaken to date using rAAV for gene delivery have used serotype 2 (Gene Therapy Clinical Trials Worldwide. J. Gene Med. March 2009 Update, http://www.wiley.co.uk/genmed/clinical ).
Evidence is accumulating which suggests that different AAV serotypes may have different tissue tropisms, for example AAV-8 is suggested to have a preferred tropism to the liver (Davidoff, 2005), while for AAV-1, -6 and -7 the preferred tropism is to skeletal muscle (Duan, 2001; Chao, 2000), AAV-4 is highly specific to the retinal pigmented epithelial cells in several animal species (Weber, 2003) and the ependymal cells (Zabner, 2000) and AAV-9 is described as being tropic to cardiacmuscle (Pacak, 2006), thought it also tranduces liver (Van den Driessche, 2007) and brain (Foust, 2009). Vectors based on these serotypes, in-vitro selected AAV with altered tropisms and hybrid vectors (i.e. ITR and Rep from AAV-2, Cap (protein coat) from another serotype i.e. icon cool EMA, the European Drug Regulator Publishes Reflection paper on Quality, Non Clinical and Clinical Issues related to the Development of Recombinant Adeno Associated Viral Vectors are being investigated (in-vitro and in animal models) to evaluate further the utility of the preferred tropisms and their potential for avoiding pre-existing immunity to AAV-2.
A new development in the field of AAV vectors is the use of self complementary (sc) AAV. Conventional rAAV vectors require 2nd strand synthesis before genes can be expressed, and it is theorized that scAAV bypass this step by delivering a duplex genome. This is achieved by deleting the nicking site of one ITR so that it no longer serves as a replication origin but still forms an AAV hairpin structure. The result is a single stranded, dimeric inverted repeat genome with the altered ITR sequence situated in the middle of the molecule and a wild-type ITR at each end. Following infection and uncoating, the DNA is folded to form a double stranded molecule. A closed hairpin end is formed from the altered ITR, and an open end formed from the two wild-type ITR’s, thus mimicking the structure of a single stranded rAAV after 2nd strand synthesis (McCarty, 2003). It is anticipated that such vectors will improve transduction efficiency and improve the level of protein expression from the transgene. The coding capacity of these vectors, however, is reduced by a factor of two.
Given the basic biology of the ‘parent’ virus as described above, the methods for manufacture and quality control of product are complicated, and the long-term fate of the administered vector is at present unknown. There are a number of manufacturing strategies that can be used to produce rAAV vectors and these are discussed further below, however the basic functional requirements for manufacture are:

The AAV ITR’s flanking the ‘gene of interest’ (this construct contains the cis elements necessary for packaging and replication of its single stranded DNA genome).

Genetic sequences (Rep and Cap) necessary for AAV replication and viral capsid proteins (generally provided in trans within a plasmid or in a packaging cell line).

Helper virus functions: either co-infection of the helper virus or co-transfection/infection of a plasmid/chimeric virus encoding the helper genes (adenovirus: E1a/1b, E2a, E4orf6, VA1 RNA; herpes simplex virus: UL5, UL8, UL52 and UL29).

A cell line capable of supporting helper virus and AAV replication.
The aim of this paper is to discuss quality, non-clinical and clinical issues that should be considered during the development of medicinal products derived from AAV, and to indicate requirements that might be expected the time of a market authorisation application (MAA). The issues raised are specific only to the development of rAAV vectors as medicinal products; general requirements for MAA are not within the scope of this paper. It is recommended that this paper is read in conjunction with the guidance documents referenced in section 4.2.

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