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EMA Publish Overview of Comments Received on Community Herbal Monograph for Viola Tricolor L.

EMA Publish Overview of Comments Received on Community Herbal Monograph for Viola Tricolor L.

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Organisations and/or individuals that commented on the draft Community herbal monograph on Viola tricolor L. and/or subspecies Viola arvensis Murray (Gaud) and Viola vulgaris Koch (Oborny), herba cum flore as released for public consultation on 11 March 2010 until 15 August 2010.
Organisations and/or individuals
1 European Scientific Cooperative on Phytotherapy (ESCOP)


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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 Publish Guidane on Media Fills for PET Drugs

FDA Publish Guidane on Media Fills for PET Drugs

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This guidance is intended to help manufacturers of positron emission tomography (PET) drugs meet the requirements for the Agency’s current good manufacturing practice (CGMP) regulations for PET drugs (21 CFR part 212). Most PET drugs are designed for parenteral administration and are produced by aseptic processing. The goal of aseptic processing is to make a product that is free of microorganisms and toxic microbial byproducts, most notably bacterial endotoxins. A media fill is the performance of an aseptic manufacturing procedure using a sterile microbiological growth medium, in place of the drug solution, to test whether the aseptic procedures are adequate to prevent contamination during actual drug production.



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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 Publish Concept Paper on Bio-Similar products containing Active Proteins: Clinical and Non-Clinical

EMA Publish Concept Paper on Bio-Similar products containing Active Proteins: Clinical and Non-Clinical

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The Guideline on similar biological medicinal products containing biotechnology-derived proteins as active substance: non-clinical and clinical issues (EMEA/CHMP/BMWP/42832/2005) lays down the  nonclinical and clinical requirements for a biological medicinal product claiming to be similar to another one already marketed. This guideline came into effect in June 2006. Since then several biosimilar  products have come into the EU market, the number of scientific advices given by the CHMP on the development of biosimilar products has increased significantly and the regulatory framework is becoming wider, e.g. the draft guideline of the biosimilar monoclonal antibodies is being finalised.

An increasing number of biosimilar products are under development, especially biosimilar monoclonal antibodies. The development of more complex biosimilar medicinal products is challenging, and several issues in the development are under re-evaluation. These include the selection of relevant species for non-clinical studies, need for clinical equivalence studies and other issues of the design of the pivotal clinical studies, role of biomarkers, amount of immunogenicity data needed, and the possibility to extrapolate to other indications. The WHO Guidelines on Evaluation of Similar Biotherapeutic Products with detailed recommendations on clinical development were published in October 2009. In addition, the EMA is emphasizing the need to follow the 3 R principles (replacement, reduction and refinement) with regard to the use of animal experiments. All these factors suggest revising the current guideline.



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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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Health Canada Publishes a Document on Reviewing the Medical Device Inspection Cycle

Health Canada Publishes a Document on Reviewing the Medical Device Inspection Cycle

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Health Canada is in the process of creating a Medical Devices Inspection Cycle. Our goal is to make this inspection cycle risk-based. This document provides potential options in inspecting scheduling and cycles.
We are exploring changes and we would appreciate your input on key concepts that we are considering. Specially, we welcome input on (i) how we assess the risk of an establishment; (ii) appropriate inspection cycles for different levels of risk.
The following suggestions may help you prepare your comments:

  • Please explain your views as clearly and concisely as possible.
  • Be sure to distinguish between what you support and what you object to in this document.
  • Provide rationale for your views, particularly your concerns, with facts, data or specific examples.
  • Describe any assumptions that you made.

Please submit your comments by November 16, 2011.
In order to provide your comments you must submit them by sending the Word or PDF format and email them to the mdcu-ucim@hc-sc.gc.ca.
Please note that any information collected will only be used for input to this consultation. The information collected will be used to create a summary report and will guide recommendations made as part of this review. The summary report will be made available to stakeholders once consultations are complete.



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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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Twitter Weekly Updates for 2011-10-23

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FDA Publish Guidance on Time and Extent Applications for NonPrescription Drug Products

FDA Publish Guidance on Time and Extent Applications for Non Prescription Drug Products

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This guidance is intended to explain what information an applicant should submit to the Food and Drug Administration (FDA) to request that a drug product be included in the over-thecounter (OTC) drug monograph system and to describe the process for submitting that information. FDA regulations set forth criteria and procedures by which OTC drugs that initially were marketed in the United States after the OTC drug review began in 1972 and OTC drugs without any U.S. marketing experience can be considered for inclusion in the OTC drug monograph system (21 CFR 330.14). The regulations establish a two-part process. First, to determine whether a drug product is eligible to be considered for inclusion in the OTC drug monograph system, certain information must be submitted in a time and extent application (TEA) to show that a drug product can meet the statutory standard of marketing to a material extent and for a material time.2 Second, if the drug product is found eligible to be considered for inclusion in the OTC drug monograph system, we will publish a notice of eligibility in the Federal Register that requests that interested persons submit data to demonstrate the safety and effectiveness of the drug product for its OTC use(s) (21 CFR 330.14(e) and (f)).

This guidance describes the format and content of a TEA that is used to determine if a drug has been marketed OTC to a material extent and for a material time, and what happens after a TEA is submitted. Drug products covered by this guidance are those OTC drug products that: (1) were initially marketed in the United States after the OTC drug review began on May 11, 1972; or (2) are without any U.S. marketing experience.


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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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Key references and local legislation for PIL User Testing: Europe

Key references and local legislation for PIL User Testing: Europe

article by Associate Consultant Mark Gibson

The following document was included in a market analysis report compiled in July 2009. As such, some recent developments, such as the Lithuanian readability testing guidance and the Romanian accreditation guidance are not included.  Neither are any of the guidance published by countries, such as Croatia and Ukraine. All of the above are subjects currently being written up as separate blog articles…so, watch this space!  Nevertheless, a lot of the references included in this article might still be useful.


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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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Health Canada Publishes Guidance on Inspection Strategy for Medical Device Companies

Health Canada Publishes Guidance on Inspection Strategy for Medical Device Companies.

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The purpose of this document is to detail the strategy for the effective and uniform implementation of a national inspection program for the medical device industry in order to assess compliance against applicable requirements of the Food and Drugs Act (Act) and the Medical Devices Regulations (Regulations).

Historically, the medical device regulatory compliance program has primarily utilized a responsive approach, resolving issues of noncompliance on a case by case basis. A more systematic approach in the form of a proactive medical device inspection program is needed to improve and maintain compliance across the industry. For manufacturers holding device licences, regulatory compliance is assessed through CAN-ISO 13485:03 quality system audits under the Canadian Medical Devices Conformity Assessment System (CMDCAS), conducted by accredited registrars. This inspection program is designed to address regulatory compliance of companies subject to establishment licensing and the manufacturers of class I devices.
The synergy resulting from the continued responsive approach, together with the proactive Inspection Strategy described in this document, is expected to significantly enhance regulatory compliance and, thereby, the safety and effectiveness of medical devices on the Canadian market.



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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.

Avoid Expensive Mistakes, Keep On Top of New and Changing Regulations for Free!

Sign up for the most value add free newsource you can get for free. We spend a huge amount of time and effort monitoring the main drug / device regulators websites for changes in the regulatory environment, and capture between 20 and 40 new regulations, rules and initiatives each month, and summaries them in a fantastic FREE monthly Regulatory and Market Round Up. You can Un-Subscribe at any time and we don not share your details with anybody. You can’t afford to miss out on this service. Just fill in the form below.

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Health Canada Publish Draft Guidnace on GMP for Medical Gases

Health Canada Publish Draft Guidance on GMP for Medical Gases

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The draft guidelines outlined in Good Manufacturing Practices for Medical Gases (GUI-0031), state the generally applicable principles and practices that are acceptable to the Inspectorate and that should facilitate compliance of fabricators, packagers/labellers, distributors, importers, and home care providers of medical gases with Division 2, Part C of the Food and Drug Regulations on Good Manufacturing Practices (GMP).

This guidance document was revised to reflect the current regulatory environment and to clarify certain aspects that have relevance to the companies dealing with medical gases. Due to their unique production and handling characteristics, the application of the GMP Regulations to medical gases may be different from their application to other pharmaceuticals, thus the interpretations provided in the main GMP Guidelines are replaced by those given in this document for medical gases.

The GMP guidelines are available on Health Canada’s Compliance and Enforcement website.



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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.

Avoid Expensive Mistakes, Keep On Top of New and Changing Regulations for Free!

Sign up for the most value add free newsource you can get for free. We spend a huge amount of time and effort monitoring the main drug / device regulators websites for changes in the regulatory environment, and capture between 20 and 40 new regulations, rules and initiatives each month, and summaries them in a fantastic FREE monthly Regulatory and Market Round Up. You can Un-Subscribe at any time and we don not share your details with anybody. You can’t afford to miss out on this service. Just fill in the form below.

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Revisiting the ‘summative’ / ‘formative’ distinction when approaching PIL User Testing

Revisiting the ‘summative’ / ‘formative’ distinction when approaching PIL User Testing

Written by Assocaite Consultant Mark Gibson

The following article is simply a write-up from a recent informal meeting I had with information design specialists working in other industries, a special interest group, I suppose. My role in the meeting was to describe how the PIL Testing industry started off as one thing, developed a life of its own and then went on a Frankensteinian rampage across Europe!

In the context of the above-mentioned meeting with delegates from many other, unrelated sectors where often no legislation is in place for the development and iterative design of instructive texts, it is absolutely clear to me that pan-EU PIL design and testing is the poor relation of the information design industry, despite a legislation being in place. What a great opportunity the pharmaceutical industry had back in 2005 to reach out to their patient audiences in a clear and concise way, yet what a paltry set of circumstances we now find ourselves in. The reason why this is so is clear: the legislation created a business opportunity, a bandwagon and too many under-qualified people carried out the testing. Arguably, the quality of Patient Information Leaflet is the same as pre-legislation: some very good PILs that were co-produced by members of the public and quality testers and some very bad ones that were forced through the testing process in record time and where there is little evidence of the flair, creativity and expertise that the pharmaceutical industry should expect from their PIL Testing providers.



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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 Publish Guidance on the Sameness of Monoclonal Antibody Products Under the Orphan Drug Regulations

FDA Publish Guidance on the Sameness of Monoclonal Antibody Products Under the Orphan Drug Regulations

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The regulations implementing the Orphan Drug Act are codified in 21 CFR Part 316. FDA published the Proposed Rule for these regulations on January 29, 1991 (56 FR 3338) (Ref. 1) and the Final Rule on December 29, 1992 (57 FR 62076) (Ref. 2). One of the incentives for orphan drug development is the exclusive approval of a product for a period of seven years. During this seven year period, no approval will be given to a subsequent sponsor’s marketing application for the same drug product for the same indication unless the subsequent product is shown by the sponsor to be clinically superior, as defined in 21 CFR 316.3 (b)(3). In determining whether or not two products would be considered the same, FDA recognized that different criteria were necessary for macromolecules versus small molecules [21 CFR 316.3(b)(13)]. Macromolecules include a variety of structures including proteins, nucleic acids, carbohydrates and closely related, complex, partly definable drugs such as vaccines or surfactants. The current definition of sameness for protein drugs [21 CFR 316.3(b)(13)(ii)(A)] however, does not adequately consider the unique nature of antibodies. The purpose of the present document is to describe FDA’s current thinking on the criteria by which two monoclonal antibody products would be considered the same under the Orphan Drug Act and its implementing regulations.

21 CFR Part 316.3(b)(13)(ii) defines sameness for a macromolecule as “…a drug that contains the same principal molecular structural features (but not necessarily all of the same structural features) and is intended for the same use as a previously approved drug…” Two protein drugs would be considered the same “…if the only differences in structure between them were due to post-translational events or infidelity of translation or transcription or were minor differences in amino acid sequence …” [21 CFR Part 316.3(b)(13)(ii)(A)]. For monoclonal antibody products, these definitions lay the groundwork for the determination of sameness but, because of the unique series of processes involved in creating an antibody molecule, additional guidance as to what would be considered the same under the Orphan Drug regulations is needed.

An antibody molecule is composed of four polypeptide chains, two identical heavy (H) chains and two identical light (L) chains. Both heavy and light chains are divided into variable (V) and constant (C) regions. The VH-VL pairs confer specificity for antigen while the constant region of the heavy chain is responsible for effector functions such as, but not limited to, complement fixation and antibody dependent cellular cytotoxicity. The variable and constant regions were so named because amino acid sequence data showed that the amino terminal regions of heavy and light chains from different antibodies had different sequences while the carboxy terminal region amino acid sequences were the same within a given isotype (class or subclass). Subsequent analysis of variable region amino acid sequences defined three hypervariable regions (also known as complementarity determining regions or CDRs) each in the VH and VL regions which form the antigen binding site of the molecule (Ref. 3). Antibody diversity is created by the use of multiple germline genes encoding variable regions and a variety of somatic events. The somatic events include recombination of variable gene segments with diversity (D) and joining (J) gene segments to make a complete VH region and the recombination of variable and joining gene segments to make a complete VL region. The recombination process itself is imprecise, resulting in the loss or addition of amino acids at the V(D)J junctions. These mechanisms of diversity occur in the developing B cell prior to antigen exposure. After antigenic stimulation, the  expressed antibody genes in B cells undergo somatic mutation. Based on the estimated number of germline gene segments, the random recombination of these segments, and random VH-VL pairing, up to 1.6 x 107 different antibodies could be produced (Ref. 4). When other processes which contribute to antibody diversity (such as somatic mutation) are taken into account, it is thought that upwards of 1 x 1010 different antibodies could be generated (Ref. 5). Because of the many processes involved in generating antibody diversity, it is unlikely that independently derived monoclonal antibodies with the same antigen specificity will have identical amino acid sequences.



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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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Review and Validation of Translations: How far do you go?

Review and Validation of Translations: How far do you go?

Article by Mark Gibson

Up until recently, reviewing translations was not accorded much, or any, importance. This is the sole reason why we often receive manuals translated into English for goods produced in East Asia that are nonsensical and useless. The reason for this is primarily cost.

Where reviews were undertaken, the back-translation method was widely practiced. While there are advantages to the back-translation approach, the disadvantages are evident: it is time-consuming and the costs of the back-translation equal those of the forward translation. However, there are areas of the pharmaceutical industry where back-translation is a Standard Operating Procedure, such as linguistic validation of measurement instruments, such as Quality of Life or Patient-Reported Outcome tools.

Nowadays, some kind of review is an industry expectation. However, because translations usually involve a rapid turn-around to the client, it has become standard practice amongst translation companies worldwide to involve an independent translator in the review process. This is primarily a proofreading exercise for spelling, grammar, syntax, etc.

Contemporary international experts in translation theory and practice now recommend a third party, or even a community review. Typically, if the translated document was intended for a healthcare professional audience, then the third party reviewer would be an expert in that field, native in the target language. If the translated document was intended for a lay audience, such as a Patient Information Leaflet, then the third party review would be one or two lay native speaker of the target language.

The review procedures differ as follows:

·         Back-translation:    For specific activities where this is an expectation (e.g. PRO tools)·         Internal review:      proofreading step for spelling, grammar, syntax, etc.

·         Community review: review step for general sense, understandability, readability, cultural appropriateness. 

The community review could be developed as a mini-readability test, whereby the reviewer, whether a healthcare professional or lay native speaker, could be asked to find an explain items of information in the translated document. Alternatively, the community review could entail open-ended questions for discussion about problematic sections (in an understandability context) of the document.

Some companies might value the review processes and be content to pay for quality, while others may be reluctant to fund the community review in particular, perhaps viewing it as excessive. The solution to these objections is simply to educate about the importance of the review processes, but, above all, listen to the client and supply their needs.


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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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An exploration of SPC Harmonisation

An exploration of SPC Harmonisation

Article by Associate Consultant Mark Gibson

SPC harmonisation is notoriously regarded as one aspect of regulatory affairs that is seldom fully outsourced. This is for obvious reasons: a bit like the uncertainty I feel when I hand over the keys to my house to people working on my house who I don’t really know while I’m not at home. However, on occasions, SPC harmonisation can be such a tough job, particularly when this involves multilingual input, that there is no other choice but to outsource at least part of the harmonisation process. It is precisely the ‘how to’ aspects of this process that the following article focuses on, both involving monolingual and multilingual SPC Harmonisation processes.


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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 Publish Guidance on Physical Chemical Identifiers for Anti-Counterfeiting

FDA Publish Guidance on Physical Chemical Identifiers for Anti-Counterfeiting

Full Text Here

This document is intended to provide guidance to pharmaceutical manufacturers who want to use physical-chemical identifiers (PCIDs) in solid oral dosage forms (SODFs). A PCID is a substance or combination of substances possessing a unique physical or chemical property that unequivocally identifies and authenticates a drug product or dosage form.
This guidance provides recommendations to pharmaceutical manufacturers on (1) design considerations for incorporating PCIDS into SODFs, (2) supporting documentation to be submitted in new drug applications (NDAs) and abbreviated new drug applications (ANDAs) to address the proposed incorporation of PCIDs in SODFs, (3) supporting documentation to be submitted in postapproval submissions to report or request approval to incorporate PCIDs into SODFs, and (4) procedures for reporting or requesting approval to incorporate PCIDs into SODFs as a postapproval change.
The incorporation of components or features used in radiofrequency identification for drug products is outside the scope of this guidance. In addition, this guidance does not apply to manufacturing or formulation changes, made in conjunction with the addition of a PCID, that go beyond simply inserting the PCID into a blending or mixing operation (e.g., adding a PCID to a non-functional tablet film coating is covered by this guidance, but adding a non-functional film coating that contains a PCID to a previously uncoated tablet involves manufacturing changes that are not covered by this guidance). The incorporation of a PCID into the packaging or labeling is not covered in this guidance.
Other guidance documents, which may be applicable to proposed changes outside the scope of this guidance, are located on FDA’s guidance Web site2 and should be consulted to help to determine whether additional reporting or approval procedures may apply to proposed changes outside the scope of this guidance.


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The loose-end of auditing translation workflow

The loose-end of auditing translation workflow

Article by Assocaite Consultant Mark Gibson

A number of my clients have pointed out to me that the translation process is the one of the only activities that goes unaudited in Big Pharma. Throughout the drug development lifecycle, employees can barely move without having to comply with some Standard Operating Procedure or Best Practice Guide. Years ago, when I started providing services to both the pharma industry, the notion of ‘audit’ was quite alien to me, having spent so much of my early career in academia where nothing was audited. In fact, I think a lot of the academics across Europe I know would probably go prolonged sick leave if an audit was ever suggested. I remember being terrified during my first ISO 9001 audit and suitably traumatised during my first client audit – both of which my team passed. Then, as I became more experienced, working to SOPs and preparing for audits became routine and easier , although the auditing process should never be taken lightly!

The fact that the translation process for much of Big Pharma remains unaudited is quite a revelation. In addition, that Big Pharma companies are starting to address this loose end may pose significant changes to the way they manage and outsource translation projects. For example, I know that the following is already happening in Big Pharma:

·         Affiliates of Big Pharma around the world will no longer operate in a practice of laissez-faire, where, for example, the Jordanian affiliate looks after documentation translations in Arabic, making decisions about outsourcing independently of the parent organisation. Instead, many large multinationals are starting to think about centralising their translation outsourcing practices

·          While the plug was officially pulled on PIM by the EMA in early 2011, some Blue Chip companies are forging ahead with their own Product Information Management systems and are conducting their own audits to identify how they can most efficiently manage their translation flow

·         As a consequence of the above points, some companies are looking at translation strategies, according to their own business models, thus creating vacancies for senior expert consultants to help develop and implement these strategies.

Above all, the biggest realisation felt by Big Pharma is that they do not have a great deal of understanding and visibility of how the translation process works, even when they have partnered with translation suppliers for a number of years.

In earlier articles, I have been critical of the conduct of translation agencies in general. What is patently clear to me is that agencies will have to alter their working practices if they wish to maintain working relationships with Big Pharma. For instance, over the past 7 years or so, I have partnered with 8 or 9 translation agencies and I never had any visibility of a) who was undertaking the forward translation into the target language, b) what validation / reviewing processes were involved (this was particularly a mystery, given the errors I was receiving) and c) who else has had an input into the translation and what Translation Memory systems were involved. Yet these are precisely the kind of details that any auditor would need to know – for every single piece of translation documentation.

The reason why agencies tend to hide away these details is out of self-preservation: translations are typically engaged by agencies at a lower price than they quote the client. Supposing translator and reviewer details are disclosed to the client as part of a translation certificate, there is nothing to stop client and translator pursuing a direct working relationship with each other, thus making the agency redundant, particularly when the agency’s ‘cut’ in the translation transaction is exposed and put into question.



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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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Game to be regulated as a drug

Game to be regulated as a drug,

This is a potential game changes a game is seeking FDA approval as a drug, the game by Brain Plasticity is a cognitive training game and has been fine tuned to help people with Schizophrenia improve the deficits in attention and memory that are associated with the condition.

A clinical study has been planned and the company is seeking FDA drug regulation, this is a huge step and could change the medical landscape for years to come. In most instances people wish to avoid regulation as much as possible and would seak to have this as a device, however there are strong marketing reasons for getting it a drug status and the biological impact of the tool is without question.

But how will this impact on other people developing software packages will they be forced to go down the same route and register their products as medical interventions, once this precident has been set where will it go, we are all awaiting the FDA opinion with baited breath.



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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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Review and validation of translations: how far do you go?

Review and validation of translations: how far do you go?

Article by Associate Consultant Mark Gibson

Up until recently, reviewing translations was not accorded much, or any, importance. This is the sole reason why we often receive manuals translated into English for goods produced in East Asia that are nonsensical and useless. The reason for this is primarily cost.

Where reviews were undertaken, the back-translation method was widely practiced. While there are advantages to the back-translation approach, the disadvantages are evident: it is time-consuming and the costs of the back-translation equal those of the forward translation. However, there are areas of the pharmaceutical industry where back-translation is a Standard Operating Procedure, such as linguistic validation of measurement instruments, such as Quality of Life or Patient-Reported Outcome tools.

Nowadays, some kind of review is an industry expectation. However, because translations usually involve a rapid turn-around to the client, it has become standard practice amongst translation companies worldwide to involve an independent translator in the review process. This is primarily a proofreading exercise for spelling, grammar, syntax, etc.

Contemporary international experts in translation theory and practice now recommend a third party, or even a community review. Typically, if the translated document was intended for a healthcare professional audience, then the third party reviewer would be an expert in that field, native in the target language. If the translated document was intended for a lay audience, such as a Patient Information Leaflet, then the third party review would be one or two lay native speaker of the target language.

The review procedures differ as follows:

·         Back-translation:    For specific activities where this is an expectation (e.g. PRO tools)·         Internal review:      proofreading step for spelling, grammar, syntax, etc.

·         Community review: review step for general sense, understandability, readability, cultural appropriateness. 

The community review could be developed as a mini-readability test, whereby the reviewer, whether a healthcare professional or lay native speaker, could be asked to find an explain items of information in the translated document. Alternatively, the community review could entail open-ended questions for discussion about problematic sections (in an understandability context) of the document.

Some companies might value the review processes and be content to pay for quality, while others may be reluctant to fund the community review in particular, perhaps viewing it as excessive. The solution to these objections is simply to educate about the importance of the review processes, but, above all, listen to the client and supply their needs.



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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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Health Canada Publishs Guidance on Drug Submission Application Forms

Health Canada Publishs Guidance on Drug Submission Application Forms

Full Text Here

The attached Drug Submission Application form is designed to assist manufacturers and sponsors in submitting information required to initiate the evaluation of any one of the following types of submissions:

  • Clinical Trial Application (CTA) (human drugs)
  • Clinical Trial Application Amendment (CTA-A) (human drugs)
  • Veterinary Investigational New Drug (VIND) (veterinary drugs)
  • Veterinary Investigational New Drug –Amendment (VIND-AM) (veterinary drugs)
  • New Drug Submission (NDS)
  • Supplement to a New Drug Submission (SNDS)
  • Abbreviated New Drug Submission (ANDS)
  • Supplement to a Abbreviated New Drug Submission (SANDS)
  • Notifiable Change (NC)
  • Drug Identification Number (DIN) Application (Division 1)
  • Post-Authorization Division 1 Change
  • Administrative Change (only applies to manufacturer/sponsor and/or product name change and licensing agreements).

The attached Guidance Document provides instructions on each field of the form. Please read it in its entirety prior to completing the form.

For Drug Identification Number applications, a separate completed HC/SC 3011 must be provided for each formulation, strength and dosage form. For all other submission types, only a separate completed Part 2 must be provided for each formulation, strength and dosage form.



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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 Publish Concept Paper on Addendum to Guidance on Evaluation of Treatments for Bacterial Infections

EMA Publish Concept Paper on Addendum to Guidance on Evaluation of Treatments for Bacterial Infections

This Concept Paper proposes the development of an addendum to the Note for Guidance on Evaluation of New Anti-bacterial Medicinal Products (CPMP/EWP/558/95 Rev 2).
During the revision of the previous version of the guideline (CPMP/EWP/558/95 Rev 1) consideration was given to the need to develop guidance on clinical data requirements to support the approval of specific indications for use. During the consultation period several requests were made for the CHMP to provide more detailed guidance on issues such as patient selection criteria and primary endpoints, including efficacy variables and the timing of the assessment of outcomes. It was proposed that CHMP should give further consideration to, and provide additional clarification regarding, indications for which superiority or non-inferiority study designs could be accepted. In the case of superiority studies, it was requested that further consideration should be given to the feasibility of conducting comparisons between test agents and either placebo or active comparators. In the case of non-inferiority studies there were requests for further consideration of appropriate values of delta. More guidance was considered to be needed regarding clinical development programmes for new antibacterial agents with potential for clinical activity against rare and/or multidrug-resistant pathogens and the accumulation of data to support indications for which there is currently no established regulatory pathway.

In order to gain further insight into the issues raised during consultation a 2-day Workshop was held in February 2011 at which representatives from the pharmaceutical industry and academia met with EU  Regulators to discuss several of these matters (insert link to final published report). Taking into account the written comments received during the consultation period and the discussions during this Workshop it appeared to be appropriate to provide additional guidance along the lines requested. It is proposed that following adoption of the revision of the main guidance document an addendum should be developed to provide indication-specific guidance. The issues that have been identified for inclusionor further consideration in the addendum are detailed below.

The content of CPMP/EWP/558/95 Rev 2 covers the general approach to the development of antibacterial agents. This guideline (as with its predecessors) does not provide detailed indicationspecific guidance. It is now apparent that such guidance is needed in order to describe and clarify the CHMP’s position on various matters.



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A critique of the linguistic validation process for Patient-Reported Outcomes and Quality of Life instruments.

A critique of the linguistic validation process for Patient-Reported Outcomes and Quality of Life instruments.

Article by Associate Consultant Mark Gibson – Full Text As a Report Available Soon

The linguistic validation process is required to ensure that translated versions of a source text contain conceptual, semantic and pragmatic equivalents to the original source text. Linguistic validation can also assure that the translated content is culturally appropriate, relevant and meaningful for the document to be used in the target countries. Over the past 20 or so years, the linguistic validation process has been implemented in the area of clinical trial documentation, particularly Patient Reported Outcome measures for administration in clinical trials, as pioneered by organisations such as MAPI Research Institute in France. As many large-scale clinical trial programmes are conducted in non-English countries on an increasing basis, the need to translate and adapt clinical trial documentation for use in other than the source language has risen in demand. This is particularly so since most clinical trial documentation, such as PRO measurement tools, originated in the English language.

 

There are two kinds of linguistic validation:

i)                    inter-lingual validation,  that is validation of questionnaires translated into other languages, such as an instrument originating in US English and is to be used in European variants of French, Spanish and Portuguese.

ii)                   intra-lingual validation, that is linguistic validation of questionnaires ‘translated’ into varieties of the same language, such  as a questionnaire originating in US English, to be used in other English-language countries, such the UK, Australia, Jamaica, etc.

 

Both kinds of validation require slightly different processes and methodologies, as are presented below.

Since most PRO and QoL documents originate in US English, for an instrument to be available in other languages, then linguistic validation helps make sure that the foreign language versions address the same concepts in all languages and offer measurable equivalence between languages. This uniformity, or harmonisation, across languages is vital to be able to pool data and compare results robustly across countries in which a given study is taking place. Therefore, the aim of harmonisation is to produce one instrument in numerous languages. Linguistic validation of each language version is the only possible way to make the international interpretation and analyses of results consistent.

Translation is always a highly subjective operation. Therefore, it is no surprise that instruments that have already been translated in other languages and that have not been linguistically validated have caused concern to regulators worldwide, such as the EMA, regarding the validity of measuring the same concepts. With the enlargement of Europe, the need for the linguistic validation of translated documents for clinical studies becomes increasingly more acute. This is not only relevant to the diversity of official languages, such as standard French, Spanish, etc., within the EU’s borders, but also the diversity of community languages spoken by the cultural diverse populations of many EU Member States, such as Turkish as spoken in Germany, Arabic as spoken in France and Bengali as spoken in the UK. For a PRO / QoL instrument to be effective and useful as a means to collect data, it must be appropriate to each cultural, linguistic and ethnic group under investigation. Therefore, to compare results of a PRO / QoL tool across languages, it needs to undergo a process that ensures:

  • that the language versions obtained are conceptually equivalent, both to the original instrument and to one another. Conceptual equivalence is achieved when the answers to the same questions reflect the same concepts and that these concepts are meaningful and relevant in each of the cultures and languages concerned.
  • that the language versions demonstrate item equivalence. This is achieved when the semantic equivalence of each item in the tool survives translation across languages.
  • that each language version is culturally relevant, acceptable and understandable to the target population
  • that the language versions are psychometrically comparable.

There are three approaches to linguistic validation:

i)                    Where the instrument is developed in one language (e.g. US English) within one country (e.g. USA) and the instrument must be translated into one or several other languages.

ii)                   Where the instrument has been developed in a source language and inter-cultural relevance and conceptual equivalence have been considered in the development of the original questionnaire.

Where the instrument has been developed simultaneously in different countries and languages. In this case, a harmonisation process (not dissimilar from a typical SPC harmonisation in the EU) will be necessary.



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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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