TABLE OF CONTENTS
Spring 2004 . Spring 2005
18th New Drug Evaluation Division
Information Meeting
19th New Drug Evaluation Division
Information Meeting
20th New Drug Evaluation Division
Information Meeting
21st New Drug Evaluation Division
Information Meeting
Spring 2004 . Spring 2005 (No. 18, 19, 20 and 21)
18th New Drug Evaluation Division
Information Meeting
Spring 2004 . Spring 2005 (No. 18, 19, 20 and 21)
18th New Drug Evaluation Division
Regular Meeting
Date: February. 19, 2004
Time: 10:30 . 15:00
Venue: Melpark Hall, Tokyo
Organizer: The Society of Japanese Pharmacopoeia (SJP)
(Incorporated Foundation)
Sponsors:
. Japan Federation of Pharmaceutical
ManufacturersEAssociations (JFPMA)
. Japan Pharmaceutical Manufacturer
Association (JPMA)
. The Pharmaceutical ManufacturersE
Association of Tokyo (PMAT)
(Incorporated Association)
. Osaka Pharmaceutical Manufacturers
Association (OPMA)
. Japan Medical Association (JMA)
(Incorporated Association)
February 2004
February 2004
PROGRAM
10:30-1040
Opening Address from the Organizer Mr. Uchiyama (SJP)
10:40-11:00
Current Status of the Pharmaceutical Administration
MHLW, PFSB, Evaluation and Licensing Division
Division Head
Dr. Shuichi Kishida 1
11:00-11:50
New Drug Approval Review
MHLW, PFSB, Evaluation and Licensing Division
Assistant Division Head
Dr. Hidehito Sekino
Lunch Break
13:00-13-50
Biostatistics in the New Drug Approval Review
NIHS, PMDEC, Evaluation Division I
Evaluation Manager
Dr. Daisuke Shibata
Break
13:50-14:10
GCP Compliance Investigation and Initial Clinical
Trial Review
OPSR, Clinical Trials Guidance Department
Head of Clinical Trials Investigation Division
Dr. Junichi Ohnishi
Disclaimer
1 Due to absence the presentation was made by Mr. Hidehito Sekino.
February 2004
Title
No.
New Drug Evaluation Division
Information Meetings
18
Periodic ICH Information Meetings
9
Problems with Safety of Drugs
6
Problems with QA of Drugs
4
14th Japanese Pharmacopoeia
1
Total as of February 2004
38
Opening Address from the Organizer: Mr. Uchiyama (SJP)
(Gist)
The progress in the research and development of
medicinal products in our country is remarkable;
however a number of difficulties have appeared
recently. In this foundation (The Society of Japanese
Pharmacopoeia) we selected some recent topics
affecting the development of medicinal products, and
with guidance and support we organized this
information meeting and hope even small this would
be helpful for all of you in the audience. We also
would like to thank to our sponsors and to all
participants.
Note: The first of the series of information meetings was
carried out on January 29, 1999 in Tokyo with the purpose
to provide direct clarification for a number of current
topics (organizational changes, acceptance of ICH
Guidelines, GCP and the conduct of clinical trials). The
title “New Drug Evaluation Division MeetingEreflects
the name of the current Evaluation and Licensing Division
(ELD) back in 1999. Since then totally 38 meetings have
been held as follow:
February 2004
Current Status of the Pharmaceutical Administration
MHLW, PFSB, Evaluation and Licensing Division
Division Head
Dr. Shuichi Kishida 2
Key points of the presentation:
.. For new drug applications, current average period for
clerical procedure is 12 months.
.. The Pharmaceuticals and Food Safety Bureau (PFSB) will
continue its effort to collect and make announcements
on data on new drug approvals.
.. As of April 1, 2004, three major organizations for
evaluation of medicinal products3 - National Institutes
of health Sciences (NIHS), Pharmaceutical and Medical
Device Evaluation Center (PMDEC), Organization for
Pharmaceutical Safety and Research (OPSR) - will merge
into one organization, the Pharmaceuticals and Medical
Devices Organization (PMDO) 4 (Independent
Administrative Organization). Basic functions of MHLW
and the new organization will be as follows:
- MHLW : Planning and drafting of basic policies;
take administrative measures for
approvals, orders, judgments, etc.
- PMDO: Conduct evaluation, review, handling of
data, etc. that do not require
administrative decisions
.. Other tasks of the MHLW
- Priority reviews
2 Due to absence the presentation was made by Mr. Hidehito Sekino.
3 Including pharmaceuticals, medical devices, quasi-drugs and cosmetics.
4 The English name of the PMDO will be officially unveiled on April 1, 2004.
February 2004
- New scheme on wider application of anti-cancer
agents for parallel treatment, expanded
access program
- Off-label use
- ICH
- The government will continue its basic policy to
comply with ICH, and observe its movements
on tasks such as: biotechnology and other
new technologies, cooperation with non-ICH
regions, etc.
February 2004
New Drug Approval Review
MHLW, PMSB, Evaluation and Licensing Division
Assistant Division Head
Dr. Hidehito Sekino
Key points of the presentation:
A. About the Pharmaceuticals and Medical Devices Organization
(Independent Administrative Organization)
Name5: Pharmaceuticals and Medical Devices
Organization (Independent
Administrative Organization6)
Employees: non-civil servants
Establishment: April 1, 2004
Description:
. Operations:
. Provide benefits to the sufferers of health damages
due to Adverse Drug Reactions
. Conduct investigation and evaluation based on
Pharmaceutical Affairs Law
. Provide consultation on initial clinical trial
. Accumulate data on efficacy and safety of drugs,
further investigate, analyse and evaluate.
. Promote research and development
. Tasks:
. Reinforce the evaluation system
.. new organization
.. priority review
. Provide safe and effective new drugs to the nation
.. revision of law
.. re-evaluation system
5 At the presentation only the name in Japanese was given: Iyakuhin Iryoukiki Sogo Kiko
6 Denotes the legal status.
February 2004
. Aims:
. For the benefit of both the industry and nation,
the organization will make effort to shorten time
period of new drug approvals.
.. For the initial 5 years: approve 50 to 80%
of the applications within 12 months (for
priority approvals to accomplish 50% in 6
months)
. Collaborative approval and post-marketing safety
.. survey on all cases
.. post-marketing clinical study
.. compilation and announcement of ADR cases
. Promote “CreationE(R&D) and “FosterageE
(post-marketing)
.. encouragement for proper use
.. post-marketing safety measures
.. prevention of health damages
. Drug safety
.. collection and supervision of drug safety
information at one place
.. conduct survey, analysis and consultation in
accordance with the characteristics of the
product
.. improve communication with medical workers,
companies and patients
.. consultation and education of medical related
people and the nation
. Expected requirements
.. swift and efficient approval
.. collaboration of clinical study consultation
and evaluation
.. first-track system and priority approval
.. improvement of evaluator skill and knowledge
.. effectiveness and clarity of the process
.. communication with industry/nation
.. complaint management
February 2004
B. On the domestic clinical trials
. Current status
.. numbers of clinical trials have decreased after
revision of Pharmaceutical Affairs Law
.. physicians are now able to conduct clinical
studies
. Tasks
.. provide satisfactory information to the
patients after completing clinical study
.. report as much as possible on the status of the
trial
.. companies to obtain as much data for trial to
prompt the approval procedure
C. Miscellaneous
An appeal was made to the physical and legal persons with
a request to refrain from submitting application for approvals
from March 1 to April 9, 2004, in order to prevent disorders
at the kick-off period of the Pharmaceuticals and Medical
Devices Organization.
February 2004
Biostatistics in the New Drug Approval Review
NIHS, PMDEC, First Evaluation Division
Evaluation Manager
Dr. Daisuke Shibata
Key points of the presentation:
A. Current Status
Environmental changes
. Social need for scientific review of drugs is rising
. Break away from “authority vs. companyEstructure
. Change in flow of information
Time period
. There is no significant difference between USA and
Japan whereas there is a big difference in the system,
structure and role of the reviewing organization 7
Basic attitude
. Appropriate (scientific, rational, realistic)
judgement
. Prompt judgement
. Follow-up of judgement
B. Future Tasks
. Collaboration with clinical trial consultation
. scientific report, analysis and consideration
on the status quo
. critical and constructive evaluation
. Speed-up the review procedure
. speed-up the clerical procedure of the reviewer
. speed-up the clerical procedure of the applicant
. shorten the waiting line
7 http://www.pharmasys.gr.jp
http://www.fda.gov/cder/rdmt/NMEapps93-02.htm
http://www.fda.gov/cder/Offices/Biostatistics/default.htm
February 2004
.. reviewer: priority system
.. applicant: submit scientifically adequate
application data
. Post-marketing safety measures and means for
providing information
. Adequate evaluation of the study conducted by those
in charge of biostatistics will create additional
value
. Enable smooth flow of project from study design,
development plan, to post-marketing policies
. Enhance decision-making
. Expansion of role of those in charge of biostatistics
Accurate and swift analysis enhance the
application procedure
Avoid trouble caused by misuse of statistics
. Participation in Project Management
. Participation in Risk Communication/Risk
Management
. Participation in Lifecycle Management
C. Further issues to tackle
. Consider the measures for tailor-made treatment;
seeking possibilities in how to scheme the clinical
studies to enable that
. Seeking what is necessary for smooth collaboration
of development evaluation, post-marketing safety
. How to collect and accumulate necessary data at the
stage of development
. How to utilize the accumulated data, how to utilize
the daily data and reflect on the accumulated data
. How to solve the communication defects
February 2004
Summary
Involvement of those in charge of biostatistics in
companies has started to contribute to the improvement of
application data quality. For further improvement, it is
considered to become more important for them to be involved
in even more parts of the drug development.
February 2004
GCP Compliance Investigation and Initial Clinical Trial Review
OPSR, Clinical Trials Guidance Department
Head of Clinical Trials Investigation Division
Dr. Junichi Ohnishi
Key points of the presentation:
A. Status quo of GCP compliance review
Numbers of items reviewed and sponsors/institutions have not
changed in the recent 5 years, however, the numbers of
national medical institutions have decreased whereas
private clinics have increased for one of the basic policies
to select the institutions to review is to conduct on
institutions that have not been reviewed in the recent years
(or never have been).
B. Violation of GCP by medical institutions
Violation of GCP has decreased from fiscal year 2000 to 2001,
however, boosted in 2002, which is believed to be because
the survey was conducted for the first time at 49% of the
institutions. The most prominent violation is against the
protocol. The increase in the number of coordinators (CRC)
has contributed in keeping good records.
C. Violation of GCP8 by sponsors
The revised GCP enforced the role of sponsors to take more
responsibility on clinical trials. SponsorsEviolations of
GCP concentrate on Article 20 Paragraph 1 and 2 9 (in case
8 PAB Notification No. 430 dated March 27, 1997 on Enforcement of Good Clinical Practice
for Trials on Drugs (GCP)
9 MHW Ordinance No. 28 dated March 27, 1997 on Good Clinical Practice (GCP)
February 2004
of ADR, sponsors are responsible to report, as soon as
possible, to the investigator and the head of institution),
and Article 22 Paragraph 2 10 (monitors should submit
monitoring report to sponsors).
D. Important factors in monitoring
The essential condition for IRB is to be able to conduct the
review sufficiently. Those that are not specialized in the
related area and those who do not have any interest with
institutions should be included in the board members. Also,
procedure manual, board member name list and minutes should
be composed (Article 28)11. Additionally, those who have not
attended the review do not have the right to vote (Article
29).
The study directors should sufficiently consider the
patient’s condition, symptom, age and ability to consent,
etc., in accordance to the purpose of the study (Article 44)12.
The investigator has the responsibility to keep a record and
report to the sponsor and the head of study institution
whenever compliance of protocol is not kept as of Article
46 13 and Article 6-2-8-214.
E. Initial Trial Review
Inquiry from OPSR to the sponsor should be replied in 30 days.
Dissatisfactory data on investigators brochure, reasons of
extrapolation, protocol, and written informed consent are
the major inquiries.
10 MHW Ordinance No. 28 dated March 27, 1997 on Good Clinical Practice (GCP)
11 MHW Ordinance No. 28 dated March 27, 1997 on Good Clinical Practice (GCP)
12 MHW Ordinance No. 28 dated March 27, 1997 on Good Clinical Practice (GCP)
13 MHW Ordinance No. 28 dated March 27, 1997 on Good Clinical Practice (GCP)
14 "CPAC-GCP Advised to MHW from CPAC" - CPAC Notification No. 40 dated March 13,
1997
19th New Drug Evaluation Division
Information Meeting
Spring 2004 . Spring 2005 (No. 18, 19, 20 and 21)
19th New Drug Evaluation Division
Regular Meeting
Date: May 20, 2004
Time: 10:30 . 15:00
Venue: Kosei-Nenkin Kaikan Hall, Tokyo
Organizer: The Society of Japanese Pharmacopoeia (SJP)
(Incorporated Foundation)
Sponsors:
. Japan Federation of Pharmaceutical
ManufacturersEAssociations (JFPMA)
. Japan Pharmaceutical Manufacturer
Association (JPMA)
. The Pharmaceutical ManufacturersE
Association of Tokyo (PMAT)
(Incorporated Association)
. Osaka Pharmaceutical Manufacturers
Association (OPMA)
. Japan Medical Association (JMA)
(Incorporated Association)
May 2004
May 2004
PROGRAM
10:30-10:40
Opening Address from the Organizer Mr. M. Uchiyama (SJP)
10:40-11:10
Current Trends in the Approval Examination
MHLW, PFSB, Evaluation and Licensing Division
Division Head
Dr. Shuichi Kishida
11:10-11:55
Clinical Trial Consultations in PMDA
Pharmaceuticals and Medical Devices Agency
Priority Review, Coordinator
Dr. Takeyuki Sato
Lunch Break
13:00-13-50
Drug Safety Measures of PMDA
Pharmaceuticals and Medical Devices Agency
Safety Control, Supervisor
Dr. Tatsuo Kurokawa
Break
13:50-14:10
New Approval Review System of PMDA
Pharmaceuticals and Medical Devices Agency
Director (concurrently, Head of Evaluation Centre)
Dr. Satoshi Toyoshima
Disclaimer
May 2004
Key illustrations
Table 1. New categories of consultations
Table 2. Present Consultation Categories (for new
medicinal products)
Table 3. Fees for new drug clinical trial
consultations
Flowchart 1. Procedure for consultation in PMDA
Flowchart 2. Flow-chart of the review work by PMDA
Table 4. Department in charge of clinical trial
consultation
May 2004
Opening Address from the Organizer: Mr. M. Uchiyama (SJP)
(Gist)
The progress in the research and development of
medicinal products in our country is remarkable;
however a number of difficulties have appeared
recently. In this foundation (The Society of
Japanese Pharmacopoeia) we selected some recent
topics affecting the development of medicinal
products, and with guidance and support we
organized this information meeting and hope even
small this would be helpful for all of you in the
audience. We also would like to thank to our
sponsors and to all participants.
Note: The first of the series of information meetings was
carried out on January 29, 1999 in Tokyo with the
purpose to provide direct clarification for a number
of current topics (organizational changes,
acceptance of ICH Guidelines, GCP and the conduct of
clinical trials). The title “New Drug Evaluation
Division MeetingEreflects the name of the current
Evaluation and Licensing Division (ELD) back in 1999.
Since then totally 38 meetings have been held as
follow:
Title
No.
New Drug Evaluation Division
Information Meetings
19
Periodic ICH Information Meetings
9
Problems with Safety of Drugs
6
Problems with QA of Drugs
4
14th Japanese Pharmacopoeia
1
Total as of February 2004
39
May 2004
Current Trends in the Approval Examination
MHLW, PFSB, Evaluation and Licensing Division
Division Head
Dr. Shuichi Kishida
Key points of the presentation:
.. Outline of Pharmaceuticals and Medical Devices
Agency (PMDA)
.. Flow of new drug approval
.. Importance of the applicant to respond to the
requirements of the reviewing authority in order to
achieve approval as fast as possible
.. Priority review
.. Clinical trial priority consultation
.. Regulations to be framed on partial modification
during approval application
- Partial modification during partial modification
of drugs and quasi-drugs
- Additional application during new drug
application
.. Off-label use
.. Expanded access program of anti-cancer multiple drug
treatment
- Conduct a rapid review (4 months)
May 2004
.. Improvement in pediatric use of medicines
- Protocol, post-marketing drug safety, gathering
of data
.. Announcement by authority of the approval data
- Outline of approval shall be made public after 3
months of approval
.. Promote countermeasures on misuse of drugs
- Label dosage regiment with trade name, etc.
.. Re-evaluation of drugs
- Approximately 30% of total results are
dissatisfactory (leading to disapproval)
.. Schedule on re-evaluation of antibacterial products
- Deliberate by June and notify in September 2004
.. ICH, CTD issues
.. GCP compliance
- Performance is greatly influenced by the degree
of contribution of the monitors
May 2004
Clinical Trial Consultations in PMDA
Pharmaceuticals and Medical Devices Agency
Priority Review, Coordinator
Dr. Takeyuki Sato
Key points of the presentation:
A. Basic view of clinical trial consultations
Description:
. Basic view:
- Clinical trial consultation in PMDA will have
designated consulting team for each case. In
this way, the applicant and the consulting team
will have closer communication, which will lead
to an effective consultation result
- In order to provide more effective drugs to the
medical scene, PMDA is determined to offer apt
consultation in a swift manner
. Is Consultation an advantage for the approval?
- Consultation will often shorten the total time
for approval if applicants observe the
consultation results
- Judgment of PMDA is subject to change according
to new scientific discoveries and progress
May 2004
. Changes in handling fee:
. Consultation fees 1 have been revised
. Timing for payment is to be reconsidered
. Cancellation fee will be charged
B. New categories of consultations
. Changes in the categories of consultations:
. Consultation categories have been changed during
3 periods (Table 1):
a) Before July 13, 2003 . prior to the
introduction of CTD
b) Between July 14, 2003 and March 31, 2004 .
transition period prior to the
establishment of PMDA
c) After April 1, 2004 . present period after
the establishment of PMDA
. Present consultation categories are listed in
details on Table 2 below.
1 See Table 3 (page 15)
May 2004
Table 1. New categories of consultations
Before July 13, 2003
From July 14, 2003
to March 31, 2004
After April 1, 2004
Initial clinical trial
consultation for:
“Clinical trial consultationE
“Safety consultationE
“Quality consultationE
Post-phase II consultation
Pre-application consultation
Specific consultation
Re-evaluation/re-examination:
Protocol consultation
Post clinical test consultation
Procedure consultation
Pre-phase I consultation
Safety consultation
Quality consultation
Pre-phase II
consultation
Additional consultation
Earlier pre-phase II
consultation
Latter pre-phase II
consultation
Bioequivalence study
consultation
May 2004
Early pre-phase II consultation
. Restricted to consultation on protocol of earlier
phase II clinical trial. Guidance and advice will be
provided based on the results and data of the phase I
trial
. For example, adequacy of parameter applied to the
pharmacokinetics of patients.
Late pre-phase II consultation
. For the first time, the organization will consult on
those cases that arise after completing phase I trial
until settlement of clinical dosage, that is, for
example, on phase II protocols
. Consultation will be based on the result of phase I
trial, overseas clinical data in human, approvals of
other countries and information on similar drugs
. When even before the earlier phase II trial is
launched, if the consultation should include matters
on latter phase II protocols, the case will be
categorized here
. That is, validity of dosage of the investigational
drug in phase II trial, written informed consent for
patients, and so on
May 2004
Consultation on pharmaceutical bioequivalence study
. Guidance and advice on those cases that do not
categorize under phase I ~ III trials nor under
quality / safety consultation, but require data
evaluation are categorized here. Such cases as
consultation on the categorization, bioequivalence
study reviews will be allocated here.
Consultation prior to application for new nonprescription
drugs (planned)
. Guidance and advice on those non-prescription drugs
classified (2) 2 and (3) 3 in the approval application
classification and have more new aspects to the drug.
Consultations will be on the necessity of clinical
trial, adequacy of protocol, non-clinical study data,
and on
. Before applying for this consultation, it is highly
recommended to receive a good advice through the prior
interview service.
2 Class 2 - “New Proprietary IngredientEnon-prescription medicines
3 Class 3 - “New Compound IngredientsEnon-prescription medicines
May 2004
Consultation prior to clinical trial and application of
medical devices / in-vitro diagnostics products
(planned)
. Guidance and advice on those that require data
evaluation, such as non-clinical study plan and
adequacy of trial method.
May 2004
Table 2. Present Consultation Categories (for new medicinal
products)
[1] Consultations available during the new drug
development
(1) Pre-phase I consultation
(2) Earlier pre-phase II consultation
(3) Latter pre-phase II consultation
(4) Post-phase II consultation
(5) Pre-application consultation
[2] Consultations on clinical trials for reevaluation
/ re-examination
(1) Re-evaluation/re-examination Protocol
consultation
(2) Re-evaluation/re-examination Post
clinical test consultation
[3] Consultations that supplement the above
(1) Procedure consultation
(2) Bioequivalence study consultation
(3) Quality consultation
(4) Safety consultation
(5) Additional consultation
May 2004
Table 3. Fees for new drug clinical trial consultations
Consultation category
Fee per
consultation(Yen)
Procedure consultation
172,100
Bioequivalence study
consultation
566,100
Early pre-phase II
consultation
2,349,900
Quality consultation
1,483,500
Safety consultation
1,637,200
Early pre-phase II
consultation
865,200
Late pre-phase II
consultation
1,678,700
Post-phase II
consultation
3,331,900
Pre-application
consultation
3,333,000
Re-evaluation/reexamination
Protocol consultation
3,331,900
Re-evaluation/
re-examination
3,333,000
Post clinical trial
consultation
3,333,000
Additional consultation
1,483,500
May 2004
C. Procedure of face-to-face advice
Flowchart 1. Procedure for consultation in PMDA
Temporary application for consultation
schedule adjustment
notification of the consultation date
contract (payment)
prior research
face-to-face advice
close consultation report
conveyance of the record
Work-flow in PMDA
The review work carried by PMDA is summarized in
Flowchart 2. (next page)
May 2004
Flowchart 2. Flow-chart of the review work by PMDA
テキスト ボックス: Convey recordsテキスト ボックス: Scheduling, consultation reception/informationテキスト ボックス: Recordテキスト ボックス: Schedule adjustmentテキスト ボックス: Designated person in chargeテキスト ボックス: Clinical trial coordinatorテキスト ボックス: Evaluation and Licensing Divisionテキスト ボックス: Answerテキスト ボックス: Face-to-face adviceテキスト ボックス: Evaluation Sectionテキスト ボックス: Evaluator in chargeテキスト ボックス: Person in chargeテキスト ボックス: Advisorテキスト ボックス: Applicantテキスト ボックス: PMDAテキスト ボックス: Question
May 2004
Table 4. Department in charge of clinical trial
consultation
Department
in charge
Medicinal products
First
New drug
evaluation
Department
Anti-malignancy, anti-bacterial,
anti-HIV-viral related drugs
Second
New drug
evaluation
Department
Cardio-vascular drugs, urinary and
recto-anal drugs, reproductive
organ drugs, metabolic disease
drugs (limited to combined
ingredients), internal diagnosis
drugs, radioactive drugs
Third
New drug
evaluation
Department
Gastrointestinal drugs, metabolic
disease (other than combined
ingredients), hormonal drugs,
dermatological drugs, central
nervous system drugs, peripheral
nervous system drugs, respiratory
organs drugs, allergy drugs,
narcotics
Biological
evaluation
Department
Biological, cell and tissue drugs,
blood products
May 2004
D. For more effective consultations
.. Consultation is available in morning and afternoon
from Monday to Friday
.. Write at least 3 possible days for consultation
when applying for consultation
.. Make good use of the prior interview system for
deliberation of the consultation category and data
preparation
.. Contact the evaluation department when payment is
to be delayed
.. Cancellation procedure will be necessary if the
applicant request to cancel or change the date of
face-to-face interview due to the applicants
reason, and in that case, 50% of consultation fee
will be reimbursed
.. When cancellation by PMDA reasons, 100% of the fee
will be reimbursed
.. For more information visit the web site of the
PMDA at http://www.pmda.go.jp
May 2004
E. Priority face-to-face interview on designated items
. Criteria and necessary documents
- Drug items that are considered important for
treatment of serious disease will be
designated as priority face-to-face interview
items
- In order to achieve this priority, submission
of data that prove the importance of the item
in medical treatment is necessary, for example,
outline of investigation drug, etc.
. Procedure of priority face-to-face interview
proprietary steps
- Inquiry and hearing will be conducted to the
applicant
- PMDA internal deliberation (with opinions from
specialists)
- Notification of the result to the applicant
- Report to the relevant sections of MHLW and
Health Science Council
May 2004
. Procedure after designated as priority face-to-face
item
- Those items, compounds or effects of drug that
is designated as priority item through the
above procedure is prioritized in face-to-face
interview (clinical trial consultation)
- The case is also applicable to consultation on
the reliability standard conformation
- Designation is subject to withdrawal in
specific cases such as violation of
pharmacopoeia
. Prior to applying for the designation
- Thorough deliberation should be made at prior
interview, which can be applied in the same
procedure with the regular new drug prior
interview application.
May 2004
Drug Safety Measures of PMDA
Pharmaceuticals and Medical Devices Agency
Safety Control, Supervisor
Dr. Tatsuo Kurokawa
Key points of the presentation:
. Inauguration of PMDA was a good opportunity to
improve and reinforce human resource and
organization in drug safety administration. Expanded
capacity of specialized personnel will handle drugs
for disease such as cancer, dementia and acute
infectious disease, which require drugs of new
mechanism and technology
. Drug Safety operation in PMDA will take-over routine
operations of MHLW therefore giving leeway to the
total drug safety of the country
. MHLW will be in charge of decision making while PMDA
will implement the established projects
. MHLW and PMDA will share information and promote the
safety measures together, will cooperate with other
medical institutes in a friendly manner, and will
improve in operational transparency
May 2004
. Continue to work on the post-marketing drug safety
issues of new drugs. Post-marketing adverse drug
reactions (ADR) are constantly reported, due to the
fact that ADR information at the pre-marketing stage
is likely to be held back owing to expectations of
patients, families, concerned medical workers and
companiesEdesire to develop the new drug as a block
buster.
May 2004
New Approval Review System of PMDA
Pharmaceuticals and Medical Devices Agency
Director (concurrently, Head of Evaluation Centre)
Dr. Satoshi Toyoshima
Key points of the presentation:
. Provide better medicinal products to the medical
scene in a swift manner
. Organization of PMDA . improvement
. Clinical trial evaluation procedure
20th New Drug Evaluation Division
Information Meeting
Spring 2004 . Spring 2005 (No. 18, 19, 20 and 21)
20th New Drug Evaluation Division
Regular Meeting
Date: October 22, 2004
Time: 10:30 . 15:00
Venue: Melparque Hall, Tokyo
Organizer: The Society of Japanese Pharmacopoeia (SJP)
(Incorporated Foundation)
Sponsors:
. Japan Federation of Pharmaceutical
ManufacturersEAssociations (JFPMA)
. Japan Pharmaceutical Manufacturer
Association (JPMA)
. The Pharmaceutical ManufacturersE
Association of Tokyo (PMAT)
(Incorporated Association)
. Osaka Pharmaceutical Manufacturers
Association (OPMA)
. Japan Medical Association (JMA)
(Incorporated Association)
October 2004
October 2004
PROGRAM
10:20-10:30
Opening Address from the Organizer Mr. M. Uchiyama (SJP)
10:30-11:00
Current Trends in the Approval Examination
MHLW, PFSB, Evaluation and Licensing Division
Division Head
Mr. Akira Kawahara
11:00-11:45
CTD and eCTD
Pharmaceuticals and Medical Devices Agency
New Drugs Division III, Chief Specialist
Mr. Masakatsu Imoto
Lunch Break
13:00-13:45
Directions for Pediatric Pharmacotherapy
National Center for Child Health and Development
Chief of Clinical Trial Management Office
Dr. Hidefumi Nakamura
Break
13:45-14:00
New Drug Application Risk Communication
Pharmaceuticals and Medical Devices Agency
New Drugs Division III, Chief Specialist
Mr. Masayuki Ikeda
Disclaimer
October 2004
Key illustrations
Figure 1. Current system of manufacturing and sales,
licensing and approval
Figure 2. Overview of the Master File system
Figure 3. Flowchart of the Evaluation system after
April 2005
Figure 4. Outline of the CTD structure
Table 1. Changes in the format for submission
October 2004
Opening Address from the Organizer: Mr. M. Uchiyama (SJP)
(Gist)
The progress in the research and development of
medicinal products in our country is remarkable;
however a number of difficulties have appeared
recently. In this foundation (The Society of
Japanese Pharmacopoeia) we selected some recent
topics affecting the development of medicinal
products, and with guidance and support we
organized this information meeting and hope even
small this would be helpful for all of you in the
audience. We also would like to thank to our
sponsors and to all participants.
Note: The first of the series of information meetings was
carried out on January 29, 1999 in Tokyo with the
purpose to provide direct clarification for a number
of current topics (organizational changes,
acceptance of ICH Guidelines, GCP and the conduct of
clinical trials). The title “New Drug Evaluation
Division MeetingEreflects the name of the current
Evaluation and Licensing Division (ELD) back in 1999.
Since then totally 38 meetings have been held as
follow:
Title
No.
New Drug Evaluation Division
Information Meetings
20
Periodic ICH Information Meetings
10
Problems with Safety of Drugs
7
Problems with QA of Drugs
4
14th Japanese Pharmacopoeia
1
Total as of October 2004
42
October 2004
Current Trends in the Approval Examination
MHLW, PFSB, Evaluation and Licensing Division
Division Head
Mr. Akira Kawahara
Key points of the presentation:
1. Implementation of the revised Pharmaceutical Affairs Law
According to the revised Pharmaceutical Affairs Law, in
2003, a revision in the regulations of biological
products and clinical tests were implemented, and in 2004,
PMDA was established. In 2005, revisions on the
followings are planed:
.. Manufacturing and sales, licensing and approval
.. Foreign manufacturers
.. Master file system
.. Classification of drugs
.. Labeling
.. Others
1) Manufacturing and sales, licensing and approval
In the present approval/licensing system, significance
is placed on the manufacturing part of the drug and it
is on the premises that all pharmaceutical companies
own the manufacturing facility. However, in accordance
to business diversification and globalization of the
industry, it is necessary to allow flexibility in the
system, maintain international conformation and secure
further safety.
See Figure 1 (next page)
October 2004
Figure 1. Current system of manufacturing and sales,
licensing and approval
Japan
US
EU
Approval
System
Manufacturing
approval
Sales
approval
Sales
approval
テキスト ボックス: Factors to be improved角丸四角形吹き出し: From manufacturing to post marketing safety measuresテキスト ボックス: ? Are post marketing safety measures enough?
? Is the present system eligible to cope with diversification of business such as branch offices and consignments?
? Should the system not conform to that of EU and US where more significance is placed on approval on sales?
テキスト ボックス: Issues to solveテキスト ボックス: ? On the premises that the developer has the manufacturing facility
? Manufacturing approval by each items and manufacturing license are necessary
角丸四角形吹き出し: Manufacturingテキスト ボックス: Present Systemテキスト ボックス: Applicationテキスト ボックス: Salesテキスト ボックス: Manufacturing
(Licensing of manufacturing)
テキスト ボックス: Quality, efficacy and safety evaluation
(Manufacturing approval by items)
テキスト ボックス: R&Dテキスト ボックス: ? Clarify market responsibility of companies
? Enforce post marketing measures and clarify its regulations on consignments
? Enable complete liberalization of manufacture outsourcing by “original sales licenseE“original sales approvalEsystem
October 2004
2) Outline of Master File system
Figure 2. Overview of the Master File system
テキスト ボックス: Both EU and US carry out the Master File system: global conformation角丸四角形吹き出し: It is necessary to avoid trouble between original drug manufacturer and pharmaceutical company for the approval procedure will go into details of manufacturing details.テキスト ボックス: The registered data will be available also for other manufactures to utilize.テキスト ボックス: The system will allow data that is submitted separately by manufacturers other than the applicant of the drug.
テキスト ボックス: Quality, manufacturing data registrationテキスト ボックス: Application form円形吹き出し: Information concealed (except for cases when disclosure is necessary for safety reasonsテキスト ボックス: Allow other companies to useテキスト ボックス: Evaluate as a complete dataテキスト ボックス: MF Registrationテキスト ボックス: Evaluation authorityテキスト ボックス: Quality, manufacturing method and dataテキスト ボックス: Original drug manufacturer
テキスト ボックス: Efficacy, Safety
Quality (partial)
テキスト ボックス: Pharmaceutical company (applicant)
October 2004
2. Evaluation system in PMDA
1) Evaluation Flow (2005~)
Figure 3. Flowchart of the Evaluation system after April
2005
テキスト ボックス: Overseas GMP Surveyテキスト ボックス: Evaluation Reportテキスト ボックス: Approvalテキスト ボックス: Clinical Trial Consultationテキスト ボックス: Applicationテキスト ボックス: GMP Survey (excluding new drug, biological, radiation products)テキスト ボックス: PMDAテキスト ボックス: MHLWテキスト ボックス: Equivalence Review (incl. GMP)
Compliance Review
テキスト ボックス: Prefectureテキスト ボックス: Manufacturing Companyテキスト ボックス: Manufacturing and Sales Companyテキスト ボックス: Foreign Manufacturing Companyテキスト ボックス: Approvalテキスト ボックス: GMPテキスト ボックス: GMP Survey (new drug, biological, radiation products)テキスト ボックス: Excluding prefecture approvalテキスト ボックス: Report
October 2004
2) Establishing a system that provides stable total
evaluation time
3) Priority evaluation
Consider the seriousness of the disease and medical
benefit
4) Priority consultation on clinical trial
5) Work flow of approval evaluation results etc.
6) Collaboration of approval evaluation and postmarketing
safety measures
7) Developing and fostering
Promoting development of new drug, enhanced prompt
approval, and enforcing the post-marketing safety
8) Promotion of re-evaluation
Efficacy re-evaluation, quality re-evaluation
9) Evaluate clinical value of the drug on the basis of
latest medical standard
10) New scheme for expanded access program of anti-cancer
multiple drug treatment
Establish anti-cancer multiple drug treatment
committee
Speed up approval procedure
October 2004
11) Promoting medical malpractice prevention
Add supply type and amount on trade name
Trade name of prescription drugs
12) Prompt action against prevention of malpractice
13) Prevent delay of evaluation process
14) Others under consideration
Part of OTC drugs to be shifted to quasi drugs
Labeling of generics
ICH
Lectures for manufacturing control
Clinical trial promotion committee
OTC sales improvement
Risk triage study group
October 2004
CTD and eCTD
Pharmaceuticals and Medical Devices Agency
New Drugs Division III, Chief Specialist
Mr. Masakatsu Imoto
Key points of the presentation:
New Drug Approval Application Documents
Dossier
.. Name (generic name, trade name)
.. Ingredients, composition
.. Manufacturing procedure
.. Dosage
.. Effect and efficacy
.. Storage and validity
.. Standard and method of trial
.. Others
October 2004
Data
a. Data on origin, details of discovery, use in
foreign countries, etc.
b. Data on physical and chemical properties,
specifications, testing methods, etc.
c. Data on stability
d. Data on acute toxicity, subacute toxicity,
chronic toxicity, teratogenicity and other
toxicity
e. Data on pharmacological action
f. Data on absorption, distribution, metabolism and
excretion
g. Data on results of clinical trials
Outline of data
October 2004
Common Technical Document (CTD)
. Japan, US, and EU Common document for drug
application
. Agreed at ICH (International Conference on
Harmonization)
. Developed by 3 specialists committee, Quality,
Safety and Efficacy
. When applying for approval in Japan, US, and EU,
the common documentation style will save time and
will enhance speed in providing drug to patients
and market
. However, the approval/licensing system is different
between countries, therefore, it will comply with
the order of the document, the contents will accord
to ICH guideline, and the details will be decided
by each local authority
. Drugs that CTD is to be applied
Drugs with new active ingredients
New combination prescription drugs
Drugs with new routes of administration
Drugs with new indication
Drugs with new dosage forms
October 2004
Drugs with new doses
(Additional dosage forms, generics are
acceptable in the previous form)
. CTD Guidelines do not indicate what kinds of trials
are required but shows the appropriate format to
apply to submit the obtained data
See also Figure 4 (next page)
October 2004
Figure 4. Outline of the CTD structure
テキスト ボックス: Part 5
Clinical
Test Report
テキスト ボックス: Part 4
Laboratory Test Report
テキスト ボックス: Part 3
Quality
テキスト ボックス: Part 2
Quality Laboratory Clinical
Outline Outline Outline
テキスト ボックス: Part 1
Local authority
テキスト ボックス: USubmitted Dataテキスト ボックス: UOutline of data submitted
Origin, etc
Properties, stability
Toxicity
Pharmacology
Pharmacokinetics
Clinical trial
テキスト ボックス: CTD
October 2004
From CTD to eCTD
CTD: Common Technical Document
eCTD: Electronic Common Technical Document
Table 1. Changes in the format for submission
Period
Original copy
Duplicate
June 1,
2004~
Paper
Paper (eCTD)
April 1,
2005 ~
Paper or eCTD
Under
consideration
.. Signature and Statement of the documents
To guarantee that the eCTD is correctly duplicated
from the paper materials or electronic materials,
for example, correctly scanned, correctly
transferred to PDF
.. Electronic documentation is expected for attached
data within one year from now
.. The Japanese authority request to submit a list of
symptoms (basically in PDF) and a list of attached
data (in both PDF and Excel)
October 2004
.. The applicant is responsible to confirm the
accessibility of submitted application data at the
PMDA computer. If not, the time clock will be
returned to the applicant
.. PMDA plan to organize a reception number for each
case
.. The submitted data should be renewed, replaced or
deleted according to the evaluation process and
results. (Life cycle management)
.. Cover letter
A cover letter should be attached as PDF and paper
October 2004
Directions for Pediatric Pharmacotherapy
National Center for Child Health and Development
Chief of Clinical Trial Management Office
Dr. Hidefumi Nakamura
Key points of the presentation:
Present status and issue of off-label use for pediatric
pharmacotherapy
Among drugs commonly administered for pediatric use,
almost 70% of package inserts lack sufficient information
on dose and dosage, efficacy and safety. These include
those drugs that indicate, “safety not established in
certain age rangeE(40% of total) and “contraindicatedEor
“conform to contraindicationE(2~3% of total).
Dosage form is another issue for pediatric usage. Solid
dosage form drugs and oral administration drugs (p.o.)
that are prepared by hospitals for pediatric use (taking
off capsules, grinding pills, transferring i.v. to p.o.)
should be standardized officially.
Additionally, for those drugs that are not yet approved in
Japan, there are cases that drugs obtained personally from
October 2004
overseas doctors or compounds for clinical trials are
administered.
Present status of pediatric clinical trial
“Guidance on Pharmaceuticals for Pediatric UseEICH E-11:
Pharma No.1334) has been implemented since April 2001.
This guidance advises, “When the drug is presumed to be
pediatrically administered, the pediatric use should be
merged in the new drug development plan.EThis guidance,
however, has no enforcement to pharmaceutical companies
and there is little incentive for companies to develop
such drugs (profit do not increase by pediatric use drugs),
therefore, there is little impression that pediatric use
drug has increased by the guidance.
Promotion of pediatric clinical trial in Europe and US
In the US such laws as Pediatric Research Equity Act of
2003 and Best Pharmaceuticals for Children Act are
established, FDA has the right to request necessary
pediatric clinical trial, and drug patent will be legally
extended if pediatric clinical trial is conducted. These
measures result in rapid increase of pediatric clinical
trials. Such law is also being prepared in the EU and is
considered to put into practice shortly. Under such
October 2004
movements, it is necessary for Japan to take prompt action
to enact such policies.
Update on administrational policies
By the “Handling of prescription drugs and off-label useE
February 1, 1999, drugs from overseas can be approved with
only partial or totally no clinical trials conducted in
Japan, when the medical society request, the medical
necessity is clear, and the efficacy and safety of the
drug is publicly apparent. Under present regulation,
however, it is reportedly said to have given negative
impressions to the companies on the development of
pediatric drugs for such reasons as delay in insurance
administration for difficulties in settling the NHI drug
price, and cooperation to pediatric R&D is economically
unprofitable.
“Revision on post-marketing sales survey and reevaluationE
December 27, 2000, promote special survey on
pediatric use and post-marketing clinical tests for
pediatric dose regimen. When implementing clinical tests
for pediatric dose during re-evaluation period, extension
of re-evaluation period (not over 10 years) is granted.
The notice has been applied, however, for only 2 items as
October 2004
of February 2004. The incentive for pharmaceutical
companies is extremely limited.
Policies of Medical Societies
Japan Pediatric Society (JPS) Pharmaceutical Committee,
other sub-committees of JPS, and Japan Developmental
Pharmacology and Therapeutics are actively working on the
off-label use issues. Drugs considered necessary to
promptly enact the approval were listed with collaboration
of the various activities.
In addition, “Action plan for pediatric off-label use and
clinical trial promotionEwas assigned at the JPS
Pharmaceutical Committee meeting in July 2004, which
clarified the policy and indicated concrete measures to
undertake.
1. Pediatric off-label use and clinical trial promotion
are one of the most important missions of the JPS and
it will continue its active and positive efforts to
tackle the issue.
2. Enhance synthetic categorization of the entire offlabel
use drugs and pursue concrete measures to solve
each off-label use issues.
3. Outline the problems on reagents, chemically
October 2004
synthesized or reformed drugs and named patient
program.
4. Implement active measures on improving the systems on
pediatric clinical trials.
5. Take movements to legalize incentives of
pharmaceutical companies, or right to request
pediatric clinical trial.
6. Frame a system to collect data on pediatric treatment
through post-marketing survey / drug use survey.
7. Improve safety information on pharmacotherapy during
pregnancy and lactation.
Full-scale measures to be implemented in 2005
According to the newspapers, MHWL will appropriate
pediatric drug problems fee in the fiscal 2005 budget, and
kick-off a study group to tackle the above-mentioned
problems including such regulations seen in the US and
others. In order to gain success in the project,
cooperation of various organizations, society and
companies are required.
For the fair pediatric pharmacotherapy
In order to cover all the off-label use issues, it is
necessary that the pharmaceutical companies, government,
October 2004
and society cooperate to satisfactorily study measures on
each issue, and create a new regulation on all category of
drugs, from those that need new clinical trials to those
that is considered enough if existing evidence or postmarketing
survey and safety information is reflected in
the package insert. On the reagent and named patient
program, measures to promote development and solve
problems are essential.
Fundamental solution of off-label use is unachievable
without environmental improvement in pediatric drug
development of pharmaceutical companies. In order to gain
this target, effective and strong incentives for the
companies such as free PMDA consultation, extension of
patent, or advantage in NHI drug price are necessary and
as well as to exchange frank opinions with companies on
the matter.
National Center for Child Health and Development desire to
settle measures on pediatric clinical trial within few
years in collaboration with companies and authorities
since solving the problems of off-label use and promotion
of clinical trial are crucial for the fair pediatric
pharmacotherapy.
October 2004
New Drug Application Risk Communication
Pharmaceuticals and Medical Devices Agency
New Drugs Division III, Chief Specialist
Mr. Masayuki Ikeda
Key points of the presentation:
Application dossier
Application dossier is a vital tool to maintain
communication between the applicant and evaluation team
and clarify various matters on risk and benefit of the
drug. In order to keep away from trouble, companies are
likely to avoid referring on negative factors, however,
bad news travel fast and therefore it is important to
consider the way to break the bad news and take prompt
necessary actions in a calm manner.
Adverse event or adverse drug reaction (ADR)
Those ‘possibleE‘probableE‘definiteEadverse events in
causal relationship criteria are considered as ADR in US,
whereas in Japan ‘unlikelyEadverse events are also
included. Application data should be compiled on the basis
of all adverse event data with medical judgment and should
try to avoid being suspected of any scheme to conceal
negative data. PMDA hold a weekly meeting with clinical
October 2004
specialists and provide such suggestions as, to submit
comprehensible CIOMS report, provide adequate translation
for overseas report, select correct MedDRA words, write
down ADR name when symptoms are listed, write down the
consideration of the company and react promptly to
questions.
Risk and benefit
It is important to balance the risk and benefit of the
drug, which every drug is different. Companies should make
effort to minimize the risk, provide enough information to
doctors so that patients receive satisfactory explanation,
and continue to gather information on risk/benefit.
Common Technical Document (CTD)
All adverse events should be analyzed and reported in the
CTD Module 2. Parameters should be indicated in 3 steps,
central tendency, example, and the group mean and median
values. Caution should be paid to confusing symptoms.
October 2004
Summary
Application dossier is the history book of the drug, the
communication basis and the key to release risk
information.
Media
Establish good media and public relations and promote
understanding by the nation.
Future tasks
Compile ADR data (publicize clinical trial data: ICJME,
structure pharmacovigilance system and harmonization on
safety. Improve mass-media relationship and enact risk
communication.
21st New Drug Evaluation Division
Information Meeting
Spring 2004 . Spring 2005 (No. 18, 19, 20 and 21)
21st New Drug Evaluation Division
Regular Meeting
Date: May 26, 2005
Time: 10:20 . 15:00
Venue: Melparque Hall, Tokyo
Organizer: The Society of Japanese Pharmacopoeia (SJP)
(Incorporated Foundation)
Sponsors:
. Japan Federation of Pharmaceutical
ManufacturersEAssociations (JFPMA)
. Japan Pharmaceutical Manufacturer
Association (JPMA)
. The Pharmaceutical ManufacturersE
Association of Tokyo (PMAT)
(Incorporated Association)
. Osaka Pharmaceutical Manufacturers
Association (OPMA)
. Japan Pharmaceutical Association (JPA)
(Incorporated Association)
May 2005
May 2005
PROGRAM
10:20-10:30
Opening Address from the Organizer Mr. M. Uchiyama (SJP)
10:30-11:00
Present environment of research and development /
approval of new medicinal products
MHLW, PFSB, Evaluation and Licensing Division
Division Head
Mr. Akira Kawahara
11:00-11:45
Guidance on pharmacogenomics
MHLW, PFSB, Evaluation and Licensing Division
Deputy Division Head
Mr. Kazuhiko Chikazawa
Lunch Break
13:15-14:00
Evaluation and consultation for clinical trials in the
newly integrated system
Pharmaceuticals and Medical Devices Agency
Priority Evaluation Coordinator
Mr. Takeyuki Sato
Break
14:00-15:00
Approach to unapproved drugs in Japan and how the
clinical trials should be in the future
MHLW, PFSB, Evaluation and Licensing Division
Deputy Division Head
Mr. Yoshikazu Hayashi
Further readings
Disclaimer
May 2005
Key illustrations
Figure 1. Manufacturing and Marketing License
Figure 2. Master File System of Active Drug
Substances
Figure 3. Prescription medicinal products
Figure 4. GPMSP, GPSP and GVP
Figure 5. Responsibilities under the GPSP/GVP
system
Figure 6. Evaluation of the clinical efficacy of
the medicinal products
Figure. 7. Logistic model analysis of blood
concentration of HbAlc & reptin before
administration of pioglitazone
Figure 8. New review system
Figure 9. Internal flow of PMDA
Figure 10. Use of unapproved medicinal products in
Japan
Figure 11. Additional Trial and Safety Confirmatory
Test
Figure 12. Examples of the examined unapproved
medicinal products
May 2005
Opening Address from the Organizer: Mr. M. Uchiyama (SJP)
(Gist)
The progress in the research and development of
medicinal products in our country is remarkable;
however a number of difficulties have appeared
recently. In this foundation (The Society of
Japanese Pharmacopoeia) we selected some recent
topics affecting the development of medicinal
products, and with guidance and support we
organized this information meeting and hope even
small this would be helpful for all of you in the
audience. We also would like to thank to our
sponsors and to all participants.
Note: The main organizer of the series of periodic
information meetings held by the regulatory
authorities is the Society of Japanese Pharmacopoeia
(SJP). Although, named a society, the SJP is an
organization of the Japanese regulatory authorities
and until the administrative reforms of 2001 was
fully subordinated to the National Institutes of
Health Sciences (HIHS). Presently, the SJP is an
incorporated foundation and works closely with the
governmental bodies, independent administrative
institutions (such as PMDA) and private industry and
professional associations.
May 2005
About the Periodic Information Meetings Held by the
Regulatory Authorities
The first of the series of periodic information
meetings held by the regulatory authorities was carried
out on January 29, 1999 in Tokyo with the purpose to
provide direct clarification for a number of current
topics (organizational changes, acceptance of ICH
Guidelines, GCP and the conduct of clinical trials).
The title “New Drug Evaluation Division MeetingE
reflects the name of the current Evaluation and
Licensing Division (ELD) back in 1999. Since then
totally 45 meetings have been held as follow:
Title
No.
New Drug Evaluation Division
Information Meetings
21
ICH Immediate Briefings
11
Drugs and Medical Devices Safety Update
Seminars
7
Current Issues in QA of Medicinal
Products
5
14th Japanese Pharmacopoeia
1
Total as of May 2005
45
May 2005
Present environment of research and development / approval
of new medicinal products 1
MHLW, PFSB, Evaluation and Licensing Division
Division Head
Mr. Akira Kawahara 2
Key points of the presentation:
The opening presentation gave an overview of the key
administrative, regulatory and international problems
currently faced by the Japanese pharmaceuticals
authorities during the continuous process of
deregulation, international harmonization and trade.
1 The regulated medicinal products in Japan are classified according to the Pharmaceutical Affairs Law
as drugs, quasi-drugs, medical devices and cosmetics.
2 At the meeting in Tokyo, on May 26, 2005 the scheduled presenter Mr. A. Kawahara was substituted
by another representative of the MHLW, PFSB, Evaluation and Licensing Division . the Deputy
Division Head Mr. Yoshikazu Hayashi, who also made the last presentation that day.
May 2005
Enforcement of the revised the Pharmaceutical Affairs Law
(PAL) and recent administrative problems
About the system for Marketing
Authorization License
Maintenance of approval records /
Master Files
Prescription medicinal products
GPSP
Improvement of consultation on
clinical trials of new
medicinal products
Measures for adjustment of the
external interactions /
influence
Grappling with the problem of
domestically unapproved
medicines and their clinical
trials
Measures for revaluation of
medicinal products
May 2005
Figure 1. Manufacturing and Marketing License 3
Notes:
1. For license authorization, appropriate post-marketing vigilance
system is required (GMP compliance)
2. Outsourcing of the whole manufacturing process will be
liberalized
3. License holders bear the entire responsibility in the market.
4. Minor partial modifications of the authorized information →
only notifications are required. (Applicants should determine
by themselves whether the relevant modification should be
qualified as minor or “not minorE
- Minor modification: Refer to the Article 47 of Enforcement
3 More details in the reports “Current Issues in QA of Medicinal ProductsEavailable in the JKS Document
Store
(http://www.jouhoukoukai.com/Merchant2/merchant.mvc?Screen=PROD&Product_Code=JM_I_0015&Cat
egory_Code=JMI)
May 2005
Regulations of PAL
- “Not minorEmodification: the addition/modification/deletion
of effect-efficacy, etc
Deemed authorization/license and transition period
.. Authorization/license at the date of enforcement is
deemed as Manufacturing and Marketing
Authorization/Manufacturing License until the renewal
date of the current license. (For manufacturing and
marketing, the location of principal office of the
applicant should be filed.)
.. By the date of the renewal of the license under the old
system, the license should be switched to the license
under the new system. Applied information should be
reorganized based upon the new system. (E.g.
manufacturing process, manufacturer identification.)
.. When the same company holds multiple
manufacturing/import and marketing licenses, the
followings are applied:
.. Renewal procedure for all the licenses at one time
to be deemed as manufacturing/manufacturing and
marketing under the new system is granted.
.. It is also granted to do the renewal procedure by
each or sequentially.
.. It is also possible to do the renewal procedure of
the deemed manufacturing/marketing to be authorized
under the new system, at the latest renewal date
among all the licenses.
.. In-advance application can be accepted for
manufacturing and marketing/manufacturing licenses.
May 2005
Figure 2. Master File System of Active Drug Substances 4
MF
Ethical Drugs
テキスト ボックス: Registration of Quality and Formula
テキスト ボックス: MF Registrationテキスト ボックス: Product quality
Data of manufacturing process
角丸四角形吹き出し: Available for other manufacturers of pharmaceutical preparationsテキスト ボックス: Non-disclosed Data (Formula, etc.)テキスト ボックス: Attached Dataテキスト ボックス: MF Registration Number角丸四角形吹き出し: Reviewed as the completed data角丸四角形: Reviewing Authority
メモ: Application form
角丸四角形: Drug Substance Manufacturer
(No need for Manufacturing and Marketing Authorization)
角丸四角形: Manufacturer (Applicant of Manufacturing and Marketing Authorization)
テキスト ボックス: Efficacy, safety,
quality (partial)
4 Further information regarding the Drug Master File implementation in Japan could be found in the Report of the 20th New Drug Evaluation Division
Information Meeting available in the JKS Document Store at the following address
http://www.jouhoukoukai.com/Merchant2/merchant.mvc?Screen=PROD&Product_Code=JM_I_009&Category_Code=JMI
May 2005
Prescription medicinal products
Designated standards of prescription medicinal products
1. Prescription medicinal products should be used
only on the basis of the diagnosis of the
doctors, and the examination of the treatment
policy as they can not be used safely and
effectively if not selected appropriately
according to the condition and constitution
etc. of the patient because of complications
such a inducing resistant bacteria, etc.
Example: Antibiotic formulations, hormone drugs, all
injections, narcotic formulations
2. Prescription medicinal products may be
associated with serious side effects what
requires a in-depth examination and periodic
check of patient’s conditions.
Example: Blood glucose lowering agents, anti-tumor
agents, human-blood-based manufactured blood products
3. Prescription medicinal products may cause
excitement or dependency, thus posing a risk
of being used for purposes other their
original designation.
Example: CNS agents
May 2005
Based of the designated standards of prescription medicinal
products
. New standards for prescription medicinal products
were enforced
. With the results:
- Existing, ethical medicinal products 5 are redesignated
- Narcotics, psychotropic drugs, stimulants,
stimulant raw materials, living organism
originated products 6 are newly designated
- Others, clearly falling into the designation
standards
See also Figure 3 (next page)
5 The name in Japanese of the “ethical medicinal productsEcould be translated as “products requiring
instructions for useE. thus including not only prescription products (dispensed only on written
prescription by a physician or dentist), but some other types of products, including prescription drugs
for veterinarian use.
6 See the titles in JKS Documents Store related to use of materials originating from living organisms at
http://www.jouhoukoukai.com/Merchant2/merchant.mvc?Screen=CTGY&Category_Code=7M :
May 2005
Figure 3. Prescription medicinal products
Categorization of Medicinal Products
For Medical Use For General Purpose
..Products provided for the use of doctors, etc.
..Authorized professionals comprehend effectiveness
and efficiency, dosage and administration, and the
patients should follow their advice.
..Products provided for the use of general public.
..Effectiveness and efficiency, dosage and
administration are easily described so that general
public can comprehend, and they will apply the
products at one's own discretion.
Prescription Drug Nonprescription Drug
Supply Perspective
Usage Perspective
Safety Perspective
Sale without prescription, such
as over the counter, is
prohibited under any
circumstances.To any
violation, the penal regulations
is applied.
Applied with
prescription, but
adequate sale is
required under
administrative
guidance.
Sale without prescription, such as over the
counter, is allowed.
License requirement is;
1. Establishment of Overall Safety Control
Department.
2. Safety Control Manager is required for 3 years
working experience.
3. Development of Procedure Manual
Type I Manufacturing and Marketing
License requirement is;
1. Establishment of Overall Safety Control
Department is not required.
2. Safety Control Manager is required but with no
quality requirement.
3. Development of Procedure Manual
Type II Manufacturing and Marketing
Categorization of Medicinal Products
For Medical Use For General Purpose
..Products provided for the use of doctors, etc.
..Authorized professionals comprehend effectiveness
and efficiency, dosage and administration, and the
patients should follow their advice.
..Products provided for the use of general public.
..Effectiveness and efficiency, dosage and
administration are easily described so that general
public can comprehend, and they will apply the
products at one's own discretion.
Prescription Drug Nonprescription Drug
Supply Perspective
Usage Perspective
Safety Perspective
Sale without prescription, such
as over the counter, is
prohibited under any
circumstances.To any
violation, the penal regulations
is applied.
Applied with
prescription, but
adequate sale is
required under
administrative
guidance.
Sale without prescription, such as over the
counter, is allowed.
License requirement is;
1. Establishment of Overall Safety Control
Department.
2. Safety Control Manager is required for 3 years
working experience.
3. Development of Procedure Manual
Type I Manufacturing and Marketing
License requirement is;
1. Establishment of Overall Safety Control
Department is not required.
2. Safety Control Manager is required but with no
quality requirement.
3. Development of Procedure Manual
Type II Manufacturing and Marketing
May 2005
About the designated prescription medicinal products
All designated medicinal products should adhere to the
following 3 requirements:
. From hygienic point, the use should be limited only
to what is instructed by a physician, etc.
. Under no circumstances, the sale of ethical products
should be allowed in the pharmacies without a written
prescription
. Penalties under the law 7 shall be applied for the
violations of the rules
About the non-designated prescription medicinal products
The prescription medicinal products other than designated
prescription medicinal products
. Generally, all products medicinal products for
medicinal use 8 should be used only with prescription
from a physician, etc.
. On the administrative base is necessary to balance
the regulations for a reasonable use of the medicinal
products for medicinal use and the excessive penal
regulations
. There is no such term as “non-prescription medicinal
productsE
7 Such as Chapter 11. Punitive Provisions of the PAL, entered into force on April 1, 2005.
8 The term “medicinal products for medicinal useEis common although not official . used mainly to
distinguish from other products in the category of medicinal products h\not intended for “medical
useE. such as quasi-drugs or cosmetics.
May 2005
GPSP
Figure 4. GPMSP, GPSP and GVP
Current GPMSP
GPSP (Surveillance)
GVP (Vigilance)*
1. Requirement for License
In more details the assignment of responsibilities under
the new system is shown at Figure 5. below.
Figure 5. Responsibilities under the GPSP/GVP system
Joint production distribution
Production distributor
Medical sites (facilities)
GPSP
Pharmacy/Ward/DI Dept.
Investigation/Clinical Trials Dept.
QA
Manager
Safety
Manager
Representative responsible for
after-sales research
Person responsible for over-all sales
GVP
May 2005
Other activities
. Elimination of off-label use (e.g. the combination
therapy of antitumor drugs) 9
.. To encourage the partial modification application for
the items requested by the relevant societies, based
on the approvals in other countries, track records in
the medical field, and article publications on
reliable source journals
. Improvement of pediatric medication
9 The off-label use of various approved medicinal products and or the use for individual patients of
drugs not yet approved in Japan (such as thalidomide) became so wide-spread that prompted the
authorities to review the situation and to plan respective measures as detailed in the last part of this
report.
May 2005
. Improvement of the clinical trial consultations
Improvement of clinical trial consultations
affecting new medicinal products
1. Improvement of waiting time 10 of clinical trial
consultations
. Meeting the demand for possible timeframes for
clinical trial consultations
. Review of the methods for clinical trial
consultations application
. Reinforcement of the functions of those
responsible for the clinical trial
consultations
2. Improvement of duties to affect clinical trial
consultations
. Efforts to resolve unapproved drugs problems in Japan
(Detailed in the last part of this report )
. Measures for revaluation of medicinal product See also
Figure 6. (next page)
10 Due to excessive demands for clinical consultations, the requesting parties had been forced to wait
for prolonged periods of time, and in 2004 the consultations were temporarily discontinued. The
overall impact of that crisis was a delay in the development in a number of products.
May 2005
Figure 6. Evaluation of the clinical efficacy of the medicinal products
MHLW
Request for Data Submission Request for Data Submission
evaluation evaluation
-
Or Designation of Re Or Designation of Re
E
Trove of Information Trove of Information
E
Provision of Provision of
Clinical Trial Clinical Trial
Implementation of Implementation of
E
Trove of Information Trove of Information
E
Compilation of Compilation of
Marketing Surveillance Data, etc. Marketing Surveillance Data, etc.
-
Post Post
When Approved When Approved
Data of the Clinical Trial Data of the Clinical Trial
Internal Data Reduction Internal Data Reduction
Notification of the Result Notification of the Result
Internal Data Submission Internal Data Submission
Food Sanitation Council Food Sanitation Council
Pharmaceutical Affairs and Pharmaceutical Affairs and
Compiled Result of the study Compiled Result of the study
Business Organization Business Organization
Collected Information Collected Information
Technical Evaluation of Technical Evaluation of
EBM Guidelines, etc. EBM Guidelines, etc.
based on the recent medical standard based on the recent medical standard
Evaluation of the clinical efficacy of the medicinal product Evaluation of the clinical efficacy of the medicinal products
May 2005
Guidance on pharmacogenomics
MHLW, PFSB, Evaluation and Licensing Division
Deputy Division Head
Mr. Kazuhiko Chikazawa
Key points of the presentation 11
Pharmacogenetics and Drug Review
. What are the technical hurdles in scientific
drug review?
. What are the hurdles in clinical development?
. How to facilitate a sound drug development?
Basic Needs for PGt/PGx 12
. Using Drug in the optimal condition, most effective
and safest regime is ultimate goal of appropriate use
. A personalized or tailored medication to the patient
with expected efficacy & safety would be ideal
. Scientific approach toward individual difference will
be a key issue
11 Presentation was done by using English-language screen slides and delivered in Japanese. The
style and language of the presentation are largely preserved here.
12 PGt, pharmacogenetics; PGx, pharmacogenomics
May 2005
Background guidance of PGt/PGx in PK/PD 13
. Guidance on clinical pharmacokinetics /
pharmacodynamics (ELD Notification No. 796) . 1 June
2001 14
2. In case genetic polymorphism is likely to affect
individual difference in pharmacokinetics, a
sponsor is recommended to select subjects with or
without specific genetic factor, based on
objective criteria such as genotyping tests.
. Guidance on drug-drug interaction study (ELD
Notification No. 813) . 4 June 2001 15
3. In case a metabolic enzyme reflecting genetic
polymorphism significantly affects metabolism of
the investigated drug in individual subjects, a
sponsor is recommended to study drug interactions,
considering phenotypes and/or genotypes of
individual subjects.
13 PK/PD, pharmacokinetics/pharmacodynamics
14 PMSB/ELD Notification No. 796 (dated June 1, 2001)
15 PMSB/ELD Notification No. 813 (dated June 4, 2001)
May 2005
Areas in progress for PGx/PGt (for personalized medicines)
. Cancer therapy seems to be most in progress and
accepted
4. Example 1: “trastuzumabEallows insurance coverage
for HER2 DNA tests
5. Example 2: A post-marketing PGx study on
interstitial pneumonia associated with “IressaE
are being studied by the sponsor company and the
institute of Tokyo University.
. CYP geno-typing to determine PM/EM metabolizes
(Japanese CYP2CI9 subtype)
. These cases require less mental/social obstacles for
patients
Approval of Trastuzumab
. Indications
6. For treatment of patients with metastatic breast
cancer whose tumors overexpressed the HER2 protein
. Precautions related to the indications
7. Assessment for HER2 overexpression should be
performed by pathologists or laboratories with
demonstrated proficiency
Tests under national health insurance
.. Biochemistry: HER2 protein in plasma
(EIA)
.. Pathology: HER2 protein (EIA), HER2 DNA
(FISH)
May 2005
Regulatory Implications of PGx
Questions:
. Is genotyping valuable for enrichment
in clinical trials?
. Is a PGx targeted drug of therapeutic
value?
. Does PGx CT become mandatory for
genotyping requirement in the
labeling?
. Is value of PGx in terms of pharmacoeconomics
clear?
Which direction are we going?
May 2005
Use of PGx for products approval
Should doses, indications or warnings related
to genotyping in the product labeling be
addressed mandatory?
. Scientific benefit of using PGx and
genotyping for personalizing medicine?
. Clinical benefit overweighs the cost
for genotyping?
So farE
. Can efficacy and safety be highly expected,
compared to the currently available medicines?
. Can safety be only assured with genotyping?
. Can efficacy be only expected for particular
patients with specific gene or genotype?
. Can we ethically eliminate patients who do not come
under the criteria of genotyping (precision)?
Still the implication of PGx/PGt to approval
process is not clear, but may be too far from the
NDA with non-PGx enrichment clinical data.
May 2005
Expected values of PGx/PGt
. At least:
- To secure pipeline of developing a drug with narrow
range of safety margin for specific patient
subpopulation (a drug with wide safety margin and
with wide applicability to whole patient population
is ideal)
- To add values for recommending more appropriate
patient sub-population and/or appropriately tailored
drug dosing
May 2005
How is PGx being applied for Drug Development?
PGx “EnrichmentEmethod in drug evaluation
. Efficacy / Safety consideration:
- The more targeted the drug is, needs the less number
of patients for clinical study (Sales vs. R&D costs)
- It is a potential fear that preclusion of subjects
might lead to overlook low ratio but serious ADRs)
- Confirmatory study on the correlation (gene
identification/ effect) should be needed
. Quality of test and other drug response mechanism:
- Specificity and precision of the test used (and
economical availability)
- Uncertainty: Are other individualsEfactors than
genetic polymorphism well specified? (Human
physiological mechanism is so complex)
- Can genetic test results only be a determinant to
rule out the patients with lower expectancy of drug
response?
May 2005
Is prediction of responder/non-responder using biomarkers
“easyE
. Example: MHLW sponsored a prospective exploratory
clinical study to find potential biochemical parameters
to be associated with responder/non-responder (non-
PGx/PGt) of pioglitazone (2000-2003) showed:
Figure. 7. Logistic model analysis of blood concentration
of HbAlc & reptin before administration of pioglitazone 16
Expected
Responder
Expected
Nonresponder
PGx/PGt might be,
to some extent,
analogous to this
non-PGx parameter
analysis
A single
biomarker (even
genomic
biomarker) may
not necessarily
predict
everything?
Real
responder
39
34
Real nonresponder
23
73
precision
63%
68%
16 As shown at http://www.mhlw.go.jp/shingi/2003/10/s1022-3.html (in Japanese)
May 2005
Is PGx necessarily shifting the efficacy/safety value of a
product?
. From the viewpoint of conventional drug evaluation,
therapeutic superiority / non- inferiority to the
existing comparator drugs is evaluated in any
controlled trials
. Do you evaluate the following types of drugs?
.. Not superior to the existing drug for a given
therapeutic population
.. Reasonably superior to the existing drug for the
particular sub-population
For the future
. Using Drug in the optimal condition, most effective
and safest regime is ultimate goal of appropriate use
. A personalized or tailored medication to the patient
with expected efficacy & safety would be ideal.
. If GYP genotyping is mandatory when
clinical data is generated to resolve a
specific well-established (in the future)
safety issue?
. If PM/EM diagnosis is to be performed by
genotyping before administration (more
effectively than TDM)?
. If there is an increase in number of gene
targeted drugs, following trastuzumab?
May 2005
Ethical Consideration
1. Public acceptance of genotyping itself
2. Securing privacy and protecting patient Information
3. Type of the anonymization
4. Use of specimens collected at clinical trial in the
past (retrospective use of genomic information and
banking)
Ref. Japan’s “Ethical Guideline on Clinical Human Genomic
StudyE17
(Inter-ministerial common guideline, independent of GCP
for drug clinical trials)
- Prior informed consent to subjects
- Ethics Committee
- Handling anonymized data of individual
patients and security of personal genomic
information
17 Human genomic studies are distinct from human cloning and related procedures (see more in the
JKS Document Store:
http://www.jouhoukoukai.com/Merchant2/merchant.mvc?Screen=PROD&Product_Code=1_D_B00
2&Category_Code=1D )
May 2005
Approaches to regulatory guidance
. Regulatory guidance development is usually
retrospective process based on the experiences of
approved data; however, PGx studies are still under
development.
. For an emerging innovative technology, is prospective
guidance development needed? Why?
. Regulatory guidance does not necessarily suppress R&D,
but would provide efficient/acceptable ways for
collecting/evaluating data, based on scientifically
sound consensus.
Current Policy
. Fact finding activity initiated for technical
guidance
. Sharing experiences should be crucial and
internationally coordinated approach to PGx/PGt
matters should be anticipated (toward ICH informal
discussion)
. Proper Information treatment will be promoted in
conjunction with GCP
. Transparent regulatory guidance will give:
.. Public acceptance and confidence on new
technologies
.. Support for development policy
May 2005
Guidance of Information Submission for developing PGx
Clinical Trial Guidelines
. On 18 March 2005, the guidance was issued 18
. Manufacturers are recommended voluntarily to submit;
- List of PGx studies (planning, being conducted, or
conducted in the past)
- Tandem development of IVDs or medical devices 19
. Submission period: 30 September 2005
. Regulatory authorities will grasp the overall PGx
situations and may request further relevant
information for guidance/guideline development
. Information submitted must be disclosed
. Results to support “indicationEand/or “dosageEin
the approval will be subject to submission for new
drug application (e.g. in case that co-relation of
CYP genotyping and clinical safety were confirmed)
18 PFSB/ELD Notification No. 0318001 dated March 18, 2005 . the scope of the Notification is to
solicit a feedback from the public (manufacturers, physicians, patients, etc.) in order to more
effectively develop the future guidelines.
19 Development of in vitro diagnostic products or medical devices for pharmacogenomics diagnosing,
in parallel with the new drugs themselves.
May 2005
US FDA’s policy
Guidance for Industry: Pharmacogenomics Data Submissions
. FDA published the guidance for industry on
pharmacogenomics data submission on 22 March 2005
. FDA is collecting PGx data to develop guidance for
drug development using PGx
. This addresses the basic rules to deal with genomic
data within FDA, depending on the purposes of data
submission. Voluntary data submission is not subject
to regulatory decision making
EMEA (European Agency for the Evaluation of Medicinal
Products)
Position Paper on Terminology in Pharmacogenetics
. EMEA published the Position Paper on 21 November 2002
(Leaflet on 29 July 2004)
. “PharmacogeneticsEand “PharmacogenomicsE
. Definitions applicable to DNA samples and data in
clinical trials including pharmacogenetic testing
. Sample coding procedure (to) be documented according
to GCP
ICH Work Plan
. Brussels, Belgium, on May 9-12, 2005 Steering
Committee (SC) / Expert Working Groups (EWGs)
. Chicago, USA, on November 7-11, 2005 SC / EWGs
May 2005
QECD Workshop
An International Perspective on Pharmacogenetics: The
Intersections between Innovation, Regulation and
Health Delivery
Rome, ITALY, 17-19 October, 2005
Session 1: New paradigms in biomedical research
and drug discovery
Session 2: Pharmacogenetics today: What do we
know?
Session 3: Social and public policy Issues in
pharmacogenetic data, sample collection and
storage
Policy Forum: Managing regulatory uncertainty in
rapidly emerging areas such as
pharmacogenomics 20
Session 4: Pharmacogenetic testing: What’s
different, what’s not?
Session 5: Impacts on human health and health care
systems
To be continued
PMDA’s study and building expertise
Open dialogues and forums with industry and academia
Fact finding
ICH discussions
Guideline development
20 A presentation “Japan-MHLW/PMDA Perspectives and StrategiesEis scheduled
May 2005
Evaluation and consultation for clinical trials in the
newly integrated system
Pharmaceuticals and Medical Devices Agency
Priority Evaluation Coordinator
Mr. Takeyuki Sato
Key points of the presentation:
Appropriate and speedy evaluation of medicinal products
. Improvement of the evaluation system
. Introduction of the process control system of the
evaluation
. Clearance of the delayed evaluation
. Others
Improvement of the consultations on clinical trials of new
drugs
. Clearance of the delay of the consultation
. Reorganization of the consultation system to respond
to more requests for consultation
May 2005
Figure 8. New review system
(Reference)
New Review System
(Consistency of Review Team and Counseling/Review)
Applicant
Expert Member
MHW Pharmaceutical Affairs and
Food Sanitation Council
Pharmaceuticals and Medical Devices Agency
Counseling/Review
of Clinical Trial
(Review Team
Approval Report
Advisory
Surveillance of
Conformance, etc.
Counseling of Clinical Trial
Guidance
Application for Approval
Notification of the Result
Inquiries
/Replies
Technical
Conference
(Reference)
New Review System
(Consistency of Review Team and Counseling/Review)
Applicant
Expert Member
MHW Pharmaceutical Affairs and
Food Sanitation Council
Pharmaceuticals and Medical Devices Agency
Counseling/Review
of Clinical Trial
(Review Team
Approval Report
Advisory
Surveillance of
Conformance, etc.
Counseling of Clinical Trial
Guidance
Application for Approval
Notification of the Result
Inquiries
/Replies
Technical
Conference
May 2005
Priority Review System
. Criteria for priority: Determined comprehensively
based on the severity of the applied disease and the
clinical efficacy of the drug
. Necessary requirement: Study results and data
suggesting the clinical efficacy
.. Summary of the investigational drugs
.. Explanatory materials for clinical efficacy
.. Summary of the study results
. Given priorities: Priorities in counseling on the
clinical tests, and on the reliability compliance
. Current situation: 8 items designated by May 1, 2005:
.. Antitumor agents: 4 items
.. CNS drugs: 1 item
.. Cerebral circulation and metabolism improvers: 1
item
.. Therapeutic products for severe infection: 1 item
.. Antiviral drugs: 1 item
May 2005
Figure 9. Internal flow of PMDA
Review Management
Division
Scheduling/Application for
Counseling/Background Data
Internal Flow of Pharmaceuticals and Medical Devices Agency
Inquiries
Person in Charge
Consultor
Review Officer in
Charge
Adviser
Face-to-face
Advisory
Review Division Consulting
Advisory
Scheduling, etc.
Record Notification
Replies
Record
Designation of the Division
Generalization of
Counseling
Agency
Review Management
Division
Scheduling/Application for
Counseling/Background Data
Internal Flow of Pharmaceuticals and Medical Devices Agency
Inquiries
Person in Charge
Consultor
Review Officer in
Charge
Adviser
Face-to-face
Advisory
Review Division Consulting
Advisory
Scheduling, etc.
Record Notification
Replies
Record
Designation of the Division
Generalization of
Counseling
Agency
May 2005
Approach to unapproved drugs in Japan and how the clinical
trials should be in the future
MHLW, PFSB, Evaluation and Licensing Division
Deputy Division Head
Mr. Yoshikazu Hayashi
Key points of the presentation:
Basic Agreement of December 15, 2004 between the Minister
of Health, Labor and Welfare and the Minister of State in
charge concerning so-called “Mixed payment for medical
examination and treatmentE21
Use of medicinal products not approved domestically
The use of medicinal products not approved
domestically is tied with conducting certain clinical
trials and the establishment of system for covering
the health insurance
Concrete targets
1. Steady implementation of the clinical trials
2. Support system of investigator-initiated clinical
trials
3. Introduction of additional clinical trials
4. Health insurance coverage for whole treatment even
after the clinical trial
21 Also known as “mixed insuranceEand “mixed co-paymentE
May 2005
Use of medicinal products not approved domestically
8. Steady implementation of the clinical trials
. Establishment of the Committee for the
Examination of the Use of Unapproved Medicinal
Products
. Periodic comprehension and scientific
evaluation of the academic societies / patient
demands and requests
. Sorting into either company-initiated (MHLW
requests the manufacturers when the review
results show that the clinical trials should be
conducted on the relevant drugs) or
investigator-initiated clinical trials (such as
orphan drugs)
. Regular meeting of Committee to be carried
periodically four times a year; Review of
results within three months
. New medicinal products already approved in US,
UK, Germany and France (and other countries
approved by the review meeting to have the
equivalent quality in regulations to Japan) are
automatically considered for approval in Japan
9. Support system of investigator-initiated clinical
trials
. Substantial information services to the
investigator, simplification of various
procedure, etc.
. Clarification of the doctorsEright to charge
patients for medication and expansion of the
scope of the prescription benefits
. Expansion of a large-scale clinical trials
network
May 2005
3. Introduction of additional clinical trials
. Additional clinical trials for the patients who
want to participate in the trials after the
relevant trials were already closed (limited
for the patients not covered by (4) below and
other relevant studies)
10. Health insurance coverage for whole treatment
even after the clinical trial
. Introduction of safety confirmatory test into
clinical trial phase to cover the whole
treatment with the current insurance system 22
22 When the treatment is approved as a part of “clinical trialE then it is covered by insurance system
as Special Healthcare Expenditure. However, after the termination of the clinical trial, it is not
covered by insurance system until listed on NHI price list. This can be regarded as a front-loaded
post-marketing surveillance study (of long-term administration test, corresponding to Phase IIIb in
EU and the US) to relief the patients from bearing the full expenses.
May 2005
Figure 10. Use of unapproved medicinal products in Japan
テキスト ボックス: Working Groupsテキスト ボックス: Requestテキスト ボックス: Surveillance Result角丸四角形: Additional Trial角丸四角形: Unapproved Drugs in Japan角丸四角形: Clinical Trial (Requested by MHW)角丸四角形: Additional Trial角丸四角形: Clinical Trial (Investigator-initiated)テキスト ボックス: Clinical Trialテキスト ボックス: Combined with Insurance Treatment
角丸四角形: Safety Confirmatory Test Conducted as a part of clinical trial (Front-loaded Post-marketing Surveillance Study)テキスト ボックス: Seamless Coverage by insurance systemテキスト ボックス: Clinical Trial (New)テキスト ボックス: Review
テキスト ボックス: NHI Price Listingテキスト ボックス: Insurance Coverage
テキスト ボックス: (1) Steady implementation of the clinical trialsテキスト ボックス: (3) Introduction of additional clinical trialsテキスト ボックス: (2) Support system of investigator-initiated clinical trialsテキスト ボックス: Review Meetingテキスト ボックス: 60 daysテキスト ボックス: (4) Health insurance coverage for whole treatment even after the clinical trial
May 2005
The Committee for the Examination of the Use of Unapproved
Medicinal Products
. Consists of 13 members
. Four meeting were held in the period January-
April 2005, as the meetings re carried
regularly and whenever necessary
. General Rules / open to the public
. Minutes of the meetings and Committee documents
are made public (refer to the web sites 23)
. Special working parties could called out if
necessary
Consideration of review session
. Regular grasp of licensing status in the four
courtiers in Europe and America
. Periodic comprehension and scientific
evaluation of the academic societies / patient
demands
. Scientific verification concerning validity of
necessity for the use and the clinical trials
of unapproved medicinal products
. Further dissemination of company-requested and
a turn to the investigator-initiated clinical
trials
. Execution of certain of safety confirmation
examinations (tentative name) etc.
23 At present the information about the Committee, its meetings and documents are posted at two web
sites of the Japanese Government . the mail site of the MHLW (www.mhlw.go.jp) and the Welfare
and Medical Services site - WAMNET (www.wam.go.jp)
May 2005
Unapproved drugs regarded as subjects for clinical trials
Determined comprehensively based on the severity of the
applied disease and the clinical efficacy of the drugs
. Severity of the applied disease (fatal disease:
irreversible disease seriously affecting the
daily life of the patient, etc.)
. Clinical efficacy (no other treatment or
prevention methods in existence: superiority in
efficacy and safety to the existing methods are
proved in the clinical trials in Europe or in the
US: Established as a standard therapy in Europe
or in the US)
Unapproved drugs to be reviewed under the new system
1. Drugs approved in the four countries (US, UK,
Germany and France) after April of 2005
2. Drugs approved in the four countries (US, UK,
Germany and France) before March of 2005, for
which reviews have been requested by academic
societies or by patient groups within the past
five years
3. Drugs approved in the four countries (US, UK,
Germany and France) within the past two years, for
which reviews have not been requested by societies
or by patient groups but still are regarded as
highly effective in medical use.
May 2005
Additional Trial and Safety Confirmatory Test
Figure 11. Additional Trial and Safety Confirmatory Test
. Additional clinical trials for the patients who want
to participate in the trials after the relevant
trials were already closed (limited for the patients
not covered and other relevant studies)
. Introduction of safety confirmatory test into
clinical trial phase to cover the whole treatment
with the current insurance system
. After the termination of the clinical trial, it is
not covered by insurance system until listed on NHI
price list. This can be regarded as a front-loaded
post-marketing surveillance study (of long-term
administration test, corresponding to Phase IIIb in
EU and the US) to relief the patients from bearing
the full expenses
Notes:
.. These two tests are also the subjects to the evaluation
for approval by MHLW
.. GCP compliance is required
テキスト ボックス: Clinical trial for application for approval
角丸四角形: Additional Trialテキスト ボックス: Safety Confirmatory Test
テキスト ボックス: Post-marketing Surveillance Study
テキスト ボックス: Long-term Administration Testテキスト ボックス: Approvalテキスト ボックス: Application
May 2005
Examples of the examined unapproved medicinal products at
the 4th review session
Unapproved medicinal products in which using with health
insurance treatment with frame of clinical trial together
is demanded from academic society and self-help patient
group
Figure 12. Examples of the examined unapproved medicinal
products
1st review session (January 24, 2005)
.. Oxiliplatin (colon and rectum cancer) 24
.. Pemetrexed (malignant mesothelioma)
.. Thalidomide (multiple myeloma)
4th review session (April 27, 2005)
.. Bortezomib (multiple myeloma)
.. Laronidase (type I mucohyperglycemia)
.. Diazoxide(high insulin blood
symptom-related low blood sugar
symptom)
24 Oxaliplatin (Elplat from Yakult Honsha KK) was approved in March 2005. For more details see
the Japan Approval Database (JAD) at http://www.jouhoukoukai.com/disclosed/jad_intro.htm
May 2005
Study committee on ideal way for clinical trials
Background
4. The situation to date
. Implementation on “Three-year Clinical Trial
Revitalization PlanE
. Promotion of the institutionalization of the
doctor-initiated clinical trials by revision of
the pharmaceutical legislation, etc.
2. Improvement in the environment of clinical trial
execution and necessity such as reduction of burden on
the businesses
5. Considerations for environment of the clinical
trial execution are indispensable to promote
smoothly the use of the domestically unapproved
medicinal products.
Study committee on ideal way for clinical trials
Considerations
Examination of the strategy to execute smoothly the
clinical trials and securing the reliability of the
clinical trials and the safety of the patients
. Deliberation on environmental to execute clinical
trial smoothly
. Enforcement of practical reduction of the burdens
on the businesses in executing clinical trials
Committee composition etc.
May 2005
The committee has membership of 13 people, General Rules
/ open to the public; and special working parties
Study committee on ideal way for clinical trials
Meeting holding schedule
. March 29, 2005 . Inauguration meeting
. April 20, 2005 . 2nd Meeting
. May 26, 2005 . 3rd Meeting 25
. June 30, 2005 . 4th Meeting (scheduled)
Outlook for the future
It is expected to proceed to a discussion dividing
problems into short-term and mid/long-term problems
25 Proceedings available at http://www.mhlw.go.jp/shingi/2005/05/s0526-2.html (in Japanese)
May 2005
References
System for specific medical expenses in relation to the
medicinal products (enforced on April 1, 2005)
. To reduce the economical load of the clinical
trial for doctors and the medical institutions, so
the clinical trials are executed smoothly when the
use chance of the unapproved medicinal product is
offered to the patient in the doctor-initiated
clinical trial, and the range of the insurance
supply is expanded about the clinical trials of
the doctor-initiated clinical trials.
. To be clarified though that the clinical trial
investigator (physician) is not especially
prohibited from requesting the defrayal of the
medicine fee etc. from the patient in the doctorinitiated
clinical trials. At the same time the
necessary measures to be taken so the charge
should not rise unjustifiably when the defrayal
of the medicine fee etc. is also requested from
the patients in the clinical trials.
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.
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