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Drug Master Files Global Perspectives
Drug Master Files Global Perspectives
Global Perspectives
III Symposium
SINDUSFARMA – IPS/FIP - ANVISA
Peter J. Schmitt
Montesino Associates, LLC
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Agenda
• Executive Summary: Drug Master Files
• Closed DMFs: The FDA Way
• Mixed ASMFs: The European Way
• Harmonizing: the eCTD challenge
• Global Trends: The Future of DMFs
• Questions
Stakeholders & DMFs
• National • API / Excipient
Regulatory Manufacturer
Authorities /Packaging
Supplier
Safety /
Efficacy Secrecy
/ Quality
Speed to Cost /
Market Results
• Pharmaceutical • Consumer
Manufacturer /
MAA
Executive Summary:
Drug Master Files
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Drug Submissions: US, Canada, EU
TYPES OF DRUG SUBMISSIONS: US, Canada, EU
USA New Drug Application (NDA), for new drugs
Accelerated New Drug Application (ANDA)-for generics
Biologic License Application (BLA), for biologic
Canada New Drug Submission (NDS)―for both drugs and biologic
products
EU Marketing Authorization Application (MAA)―via the Centralized
Procedure for eligible products. For other products, via the
decentralized, mutual recognition or national authorization are
applicable.
Role of DMFs
• Highly Regulated Markets (Drug Master Files used to support approval process)
• United States:
• Canada:
• Australia
• Japan
• Europe: China is developing its own DMF system
• Nearly Regulated Markets (Technical Package / Registration Dossier)
• Brazil
• Russia
• South Africa
• Less Regulated Markets (No Drug Master Files used in registration process)
• India and many others
Drug Master Files: USA
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How the US DMF System Works
Drug substance, drug substance intermediate, and materials used in the preparation, or Drug Product II 15,230
13 Considerado o status de Inativo para os DMFs sem atividade pelos últimos 3 anos, ou sob
exigência do detentor do DMF. Todos os dados são para 4T 2011
US DMFs – Type II
NDA Aprovado !
Animais Fase II
(segurança)
Resultados Estabilidade
IND Submetido NDA Submetido
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FDA Resources
• Established in 1989-1991
• Revised in 2005 and became ASMF (Active Substance Master
File) after implementation of CTD in EU
• Applicable only to active substances
• Has been divided into 2 parts
• Applicant Part (Open)
• ASM Restricted Part (Closed / Confidential)
European Master File
• The DMF contains information which includes valuable know-how which should be kept confidential and
submitted to the authorities only. Therefore, it should be divided into 2 parts – an applicant’s part and an ASM
Restricted Part. The applicant’s part of a DMF is provided by the ASM (Active Substance Manufacturer) to the
applicant directly and becomes part of the application for marketing authorization. Both the applicant’s part and
the ASM Restricted Part of the DMF are submitted to the authorities.
• Applicant’s part of a DMF – opening part
• The applicant must be supplied by the ASM with sufficient information to be able to take responsibility for an evaluation of
the suitability of the active substance specification to control the quality of the substance. This normally includes a brief
outline of the manufacturing method, information on potential impurities originating from the manufacturing method, from
the isolation procedure (natural products) or from degradation and, where applicable, information on the toxicity of specific
impurities.
• ASM Restricted Part of DMF – closing part
• Detailed information on the individual steps of the manufacturing method such as reaction conditions, temperature,
validation and evaluation data for certain critical steps of the manufacturing method, etc. and on quality control during
manufacture may contain valuable know-how. Such information may therefore be supplied to the authorities only.
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EU: Documenting Quality:
4 Options
In Europe there are four ways to document the quality of the drug
substance for the purpose of marketing authorization:
• Certificate of Suitability of the pharmacopoeia monograph (CEP)
• Full details of manufacture (according to CTD Module 3 - Quality
of Drug Substance)
• European Active Substance Master File (ASMF; former Drug
Master File, DMF)
• Other evidence of suitability of the pharmacopoeial monograph
EU ASMF Structure: CTD
• Filing to include:
• Starting materials
• Intermediate products
• Manufacturing processes
• Quality specifications
• Test methods
• Report from audit of outsourced material manufacturer(s)
• If changes to production of any items covered by this Provision,
description of change and justification
Proposed Use of DMF
• US NDAs:
• 2005: 2.34% filed by eCTD
• 2010: 62.41% filed by eCTD
• EU: New Applications
• 2009: 7% filed by eCTD
• 2010: 8% filed by eCTD
Global DMF Challenges
• Open or Closed?
• CTD, eCTD
• Major advantages of a DMF system for Brasil?
• Major disadvantages of a DMF system for Brasil?
THANK YOU!
MUITO OBRIGADO
• Sindusfarma
• IPS/FIP
• Anvisa
• Vocês
Obrigado a todos!
Peter J. Schmitt
Montesino Associates, LLC
1719 Delaware Avenue, 3rd Floor
Wilmington, DE 19806 -- U.S.A.
peter.schmitt@montesino.com
+1 (302) 888 2355 (escritório) -- +1 (302) 521-3203 (celular)
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