In order to consolidate and deepen the internal institutional reform being implemented, the State Food and Drug Administration (SFDA) Center for Drug Evaluation (hereinafter referred to as “CDE”) has recently reviewed, approved and promulgated a corresponding supporting document of the Principles and Procedures for Drug Technical Review (hereinafter referred to as “Principles and Procedures”), and has posted it on the website.
According to the introduction made by Feng Yi, Director of Business Administration Department of CDE, based on the task categorization and risk level for review and approval, the Principles and Procedures has, ,centering upon the principle of scientificity, legality, ethics, openness, impartiality and equity for technology review and approval, specified corresponding decision-making procedures for the review and approval of Investigational New Drug (IND) Application, New Drug Application (NDA), Abbreviated New Drug Application (ANDA), etc., and invited the community to supervise over the operation of CDE in accordance with the Principles and Procedures.
Simplify and Adjust the Original Procedures
The internal institutional reform which began in January this year significantly adjusted the main duties and internal organizational structure of CDE. As a result, the reform intensified the communications and exchanges between the review professionals in the same subject and same profession, and at the same time consciously made a scientific classification of reviews on generic drugs and innovative drugs.
Compared to existing 3,000 persons in the Center for Drug Evaluation and Research (CDER) affiliated to U.S. FDA, CDE only has 120 persons. Over the years, SFDA has been looking for a scientific review path to reasonably allocate the resources based on the grades of drug related risks, in order to resolve the great pressure on the time limit of review.
Being oriented to the value of clinical therapy, U.S. FDA established review structure and mode based on the classification of indications. “However, this mode is supported by the enormous human and material resources from FDA”, says Li Ning, former Director of U.S. FDA Statistical Review of Cardiovascular Products & Senior Director of Sanofi-Aventis Pharmaceutical Affairs and of Medical Policy.
Feng Yi says that the institutional reform simplified and adjusted the original review procedures, so that the procedures and tasks of CDE became better coordinated; it also designed the new processes such as parallel review, sequential review, single-disciplinary review and simplified review, in order to speed up reviews and adjust the review strategy at the appropriate time.
Improve Various Concept in Review Procedures
According to the report, after the completion of the institutional reform, the review tasks, based on the subject matters of applications, are divided into application for new drug clinical trial, application for registration of new drug production and marketing, application for registration of generic drug and supplementary application, etc. According to the general rules of drug development, different types of review tasks adopt the appropriate review procedures respectively. With respect to applications for new drug clinical trial and applications for registration of new drug production and marketing, the procedures for multi-disciplinary parallel review are adopted; with respect to applications for registration of chemical generic drugs, the procedures for one-department single-disciplinary review are adopted; with respect to supplementary applications, the procedures for single-disciplinary review and the procedures for simplified review may be adopted according to the type of changes. If any multi-disciplinary issue is encountered in the varieties applying the single-disciplinary review, the procedures for sequential review may be launched; for the review tasks applying procedures for sequential review, they will also be completed within the prescribed time limit.
It shall be noted that the institutional reform established a separate department of pharmacology and toxicology. The department is responsible for the technical review on the pharmacology and toxicology researching materials relating to the applications for clinical trial, applications for registration and relevant supplementary applications of traditional Chinese medicines, ethno-medicines, natural drugs, chemical drugs and biological products; it is also responsible for the comprehensive evaluation of the applications for clinical trial and relevant supplementary applications of Class 1 to Class 2 chemical drugs and traditional Chinese medicines, ethno-medicines and Class 1 to Class 5 natural drugs, preparing a technical review report and putting forward a clear conclusion and recommendation.
In contrast, the previous review tasks in the pharmacological and toxicological aspects are allocated to the several clinical review departments responsible for different indications. “After the reform, the reviewers of a same profession have been relatively concentrated, the communications and exchanges between the reviewers of a same discipline have been intensified, the unity in the scale of review and the uniformity of review speed have been enhanced, which all substantially promoted the reasonable coordination among the staff members.” Li Ning says.
Improve Various Concept in Review Procedures
In order to improve the efficiency of reviews and the scientificness of decision-making, communication and exchange is always advocated by the Drug Registration Department and CDE of SFDA. The professionals in the new drug development industry hold the opinion that the contribution of the Principles and Procedures is that the ways and means of communication and exchange are truly implemented.
Meanwhile, the Principles and Procedures also enhance the concept of communication and exchange onto a new height. The Principles and Procedures provide that, during the crucial stage of new drug development, the applicant may apply for communication and exchange with CDE concerning the major technical issues, and may also apply for communication and exchange with CDE concerning its annual R&D strategy, overall planning and layout in the process of drug development and other issues. Such exchanges will not only help companies resolve investment risk and terminate certain research and development projects as early as possible, but also help to understand the overall planning in the drug development process of the pharmaceutical companies, and help drug regulatory authorities reasonably deploy and distribute human resources.
With respect to the authorization and issuance of new drug technical review, the Principles and Procedures also made certain new attempts. The Principles and Procedures provide that the director of each review department shall be responsible for verifying the professional review reports and the relevant technical review report, and shall, with the authorization of Director of CDE, be responsible for issuance of the technical review reports corresponding to the applications for registration.
“It means transferring the power of issuance of the technical review report to the lower level, which is similar to the practices of U.S. FDA.” Li Ning comments.
In addition, another highlight of the Principles and Procedures is that it crystallized the “supervision” of the public and the pharmaceutical industry over the review. The Principles and Procedures provide that “the target review time limit of the review task proposed by each responsible review reporting department” must be disclosed to the applicant in advance. Moreover, the information about certain review conclusions must also be announced on the CDE’s website, particularly “the technical review report of the varieties where the materials are submitted in the form of common technical document (CTD) must be disclosed to the applicant” and “the first Overview of Drug Evaluation for new drugs on the domestic market” must be publicized to the public. These efforts will play a far-reaching significance in promoting the consistency of the scale of review and the predictability of results.
In the history of drug review in China, the Principles and Procedures for the first time provide that “all kinds of target review time limits of the review tasks are the important indicators to evaluate the quality and efficiency of reviews”, and also provide two fundamental principles that “the target review time limits of the review tasks relating to the applications for registration of new drug production and marketing shall satisfy the public demand for accessing to the latest therapies” and “the target review time limits of the review tasks relating to the applications for registration of generic drugs shall satisfy the public demand for timely accessing to such type of drugs”. With the implementation of these fundamental principles, “encouraging drug innovation” will no longer be empty words.
“CDE is an important department which evaluates the drug researching data and results by the scientific standards, norms and methods, and ensures the safety, efficacy and controllable quality of the approved marketing drugs. Each time of institutional or system reform in CDE is to make it better adaptive to the development of drug innovation trend and to better enhance the quality and efficiency of drug review.” Zhang Wei, Director of the Drug Registration Department of SFDA, comments on the recent institutional reform in CDE.
Author: Mao Donglei
