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  • 1.  In house eCTD publishing opinions needed

    Posted 02-May-2016 13:32

    Hello All,

    We are considering publishing eCTD in house and I would like some opinions regarding how practical it is for a small company that typically handles one to three aNDA's per year to publish in house.

    Thank you,

    Sarah Green

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    Sarah Green
    Corporate and Regulatory Document Administrator
    Cyclomedical International Inc.
    Knoxville TN
    United States
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  • 2.  RE: In house eCTD publishing opinions needed

    Posted 02-May-2016 13:47
    Sarah,

    It is doable once your IT is willing to help you and your team understands all the requirements for modules.  

    In fact, I can build eCTD for ANDAs, NDAs, or BLAs on my own.

    In case you need medical writing firm and submission through eCTD, I would recommend you consider women-owned medical writing firm at https://www.whitsellinnovations.com/ 

    Thank you.  

    s/ David
    ______________________________________________
    Dr. David Lim, Ph.D., RAC, ASQ-CQA 
    Phone (Toll-Free): 1-(800) 321-8567



    "Knowledge is power only when it is practiced and put into action." - Regulatory Doctor

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  • 3.  RE: In house eCTD publishing opinions needed

    Posted 16-May-2016 01:15

    Hi Sarah,

    It's possible to publish eCTDs, provided you have the right software solution for your company.  If you don't have eCTD publishing software, there's many considerations you'll have to make regarding which software to purchase.

    As a starting point, there are three obvious ways to access eCTD publishing software: a local installation of the software; a "cloud"/"software-as-a-service" hosted instance of the software; or outsourcing the publishing to a 3rd party vendor. Each of these solutions will be able to publish your eCTDs, however with different limitations, functionalities and, importantly for small companies, different price points.

    You'll find it worthwhile to do some research to determine what will best suit your company's needs. I hope this information is a good base to start from.

    Kind regards, Daria

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    Daria Wain
    Pharma To Market Pty Ltd
    Queensland
    Australia



  • 4.  RE: In house eCTD publishing opinions needed

    Posted 17-May-2016 05:01

    Dear Sarah, 

    to add to Daria's very valid points, you will also need to take into consideration that software will require maintenance. With hosted solutions such as SaaS, this may not weigh in as heavily, but if you consider implementing eCTD software in-house you also have to plan for the future and the involved efforts and of course you will need to have that internal IT support.

    In my experience, especially for smaller companies, it is more viable and cost effective to have a service partner to do the work for you. This enables your company to concentrate on the subject matter expertise, such as product strategies, etc.

    Most of service providers also offer options for the partner companies to have at minimum review access to their submissions within the publishing environment, offering a real time overview within all stages of putting the eCTD together.

    Kind Regards, 

    ------------------------------
    KATJA KOESTERKE-WAGNER
    Global Head, Training & Process Development
    European Operations Manager
    CSC Life Sciences Business Process Services



  • 5.  RE: In house eCTD publishing opinions needed

    Posted 17-May-2016 08:38

    Hi folks.

    Let me just add in one other key consideration in my mind.  While you are talking about a "small company" today with possibly very few, if any, documents needing eCTD....please also consider the future of what the company will look like 1, 5 or 10 years from now.  Keep in mind, whatever your decision today, to obtain the best ROI for the solution it must be scalable, longitudinally manageable, and cost effective.  Scalable I don't think needs a definition.  Nor do I believe cost effective needs a separate definition in this case. What I mean by longitudinally manageable is that over time your needs, requirements, expectations, and processes are likely to change and often they will become more specific to your particular company, company culture and product types.  In order for a good eCTD decision to be made regarding proper publishing process and therefore proper publishing choices, you need to consider that aspect as well.  If you choose to go with the "simple" fix of outsourcing your process that will work for many types of companies but you must remember that you are still ultimately responsible for the information provided through your vendor and there are vendor acceptance requirements that will need to be met and audited.  If you choose a more "complex" fix of bringing all of the information build in-house then you still have vendor requirements but you also have the need for additional support internally (or possibly outsourced - remember vendor requirements here as well) and the need to update/upgrade over time with patches, fixes, new options, etc. 

    So my point here is really be sure what you want to do with the programs and projects before you go deciding on how you will get there.  Far too often in my personal experience have I been in a meeting 3 months into "implementation" or "validation" or "verification" programs only to find out that the company has not really understood what they plan to do, who is expected to do it, what resources are available, what the expertise of the individual contributors might be, and what the "true" costs of the system actually are.   When you get to this point, you have a lot of capital sunk into the project already and most companies won't want to "abandon" the project at this point and start over which makes the project that much more difficult to manage and deal with.  So know what you want, who you have, what capabilities are available on staff (or in potential increased headcount for the group) and seriously consider what you will need longer-term in order to get the best cost effectiveness out of your choice.  Without knowing this when you embark on review and decision-making for this type of thing, you are unfortunately doomed to failure at some point - it might work just fine for a while even but it is going to come back to haunt the company in the long term if you don't understand these issues up front and make it a point of providing this information to any of the developers that you consider moving forward with to pricing, presentations and ultimately purchases.

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    Victor Mencarelli
    Sr. Manager - Regulatory Affairs
    Hain Celestial Group
    United States



  • 6.  RE: In house eCTD publishing opinions needed

    Posted 20-May-2016 09:22

    I see this as less of a "practical" issue than a business decision, based largely on the cost of outsourcing versus the cost of establishing and maintaining the resources to publish in-house.  I think others here have already given you a good list of factors to consider in weighing this decision.  I will add data security as an issue to consider.

    As a purely practical issue, I think the biggest question is whether management will resource the function adequately if it is brought in-house.

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    Julie Omohundro, ex-RAC (US, EU), still an MBA
    Principal Consultant
    Class Three, LLC
    Durham, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com