EMA Publish Concept Paper on Non-Clinical Local Tolerance Testing
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The existing guideline on local tolerance is dated 1 March 2001 (1). Over the past years, newer routes of administration, e.g. transdermal systems, are being used more frequently and a shift has been observed towards the regulatory acceptance of scientifically valid in vitro methods as well as formally validated in vitro methods as part of an integrated testing strategy. In addition, recently the ICH Guideline M3(R2) – Non-Clinical Safety Studies for the Conduct of Human Clinical Trials and Marketing Authorisation for Pharmaceuticals (2) – came into force and included a section on local tolerance.
The focus on local tolerance testing has broadened over the last few years, with newer methods of drug delivery being developed. In vitro methods are becoming an integral part of the non-clinical testing local tolerance testing programme of human medicinal products and approaches aiming at reducing or refining animal studies are routinely implemented in regulatory guidelines, where applicable.
Taking into account the progress in the development of newer drug delivery strategies, a revision of the Guideline on Non-Clinical Local Tolerance Testing of Medicinal Products is warranted. The revision will also aim to harmonise local tolerance testing requirements with those out lined in the ICH Guideline M3(R2) – Non-Clinical Safety Studies for the Conduct of Human Clinical Trials and Marketing Authorisation for Pharmaceuticals (2).
Local tolerance should be evaluated prior to human exposure of a product in order to ascertain whether the product (both active substance and excipients) is tolerated at contact sites of the body following clinical use. Local tolerance testing should be conducted according to “state of the art” methods.
Although non-clinical studies still heavily rely on animal data, adherence to the 3Rs principles is clearly evident both at the EU and ICH level. Various in vitro test systems are currently used for different purposes and at different time-points within the non-clinical development programme. Wherever possible, studies on animals, including studies on local tolerance, should be substituted by validated in vitro tests.
The introduction of tailor-made non-clinical testing strategies, involving both in vivo and in vitro testing, is expected to entail a reduction of animal use.
The full revision of Directive 86/609/EC was recently completed and resulted in the adoption of Directive 2010/63/EU on the protection of animals used for scientific purposes on 3 June 2010 [3]. This Directive will take effect on 1 January 2013. Different articles relate to the application of the 3R’s. As such, article 4 clearly states that:
Member States shall ensure that, wherever possible, a scientifically satisfactory method or testing strategy, not entailing the use of live animals, shall be used instead of a procedure. Member States shall ensure that the number of animals used in projects is reduced to a minimum without compromising the objectives of the project.
Member States shall ensure refinement of breeding, accommodation and care, and of methods used in procedures, eliminating or reducing to the minimum any possible pain, suffering, distress or lasting harm to the animals.
Therefore, the Guideline on Non-Clinical Local Tolerance Testing of Medicinal Products (1) should be revised in order to take into account scientific and legislative progress and to also to formulate guidance on when and how 3R alternatives (replacement, reduction and refinement) can be considered for regulatory acceptance.
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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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.
“Please note that the pages on this website are designed to provide you with general information only. We make no warranties, representations or undertakings about any of its content. This includes the completeness, accuracy and fitness for any particular purpose, or the content of any third party site referred to or accessed through it. You are personally responsible for ensuring that the information is correct and we will not be held liable or accountable for any mistakes that occur.”