Regulatory Open Forum

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  • 1.  eCTD structure

    Posted 31-Jan-2023 16:46
    Hi, 

    I am preparing a response for the FDA request and I need to attach few CAPAs and, Investigations and reports with my submission.
    Where I would place these documents within the eCTD (which section)? 

    Thank you

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    Valeria Shkuratova
    Canada
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  • 2.  RE: eCTD structure

    Posted 01-Feb-2023 06:55
    Hi Valeria, 

    In my experience those documents would be included in Section 3.2.R Regional Section.  Documents included in this section provide supporing information but are not maintained with the eCTD lifecycle.  

    Good luck with the FDA request.

    Best regards,
    Carolyn

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    Carolyn Dougherty
    Kalamazoo MI
    United States
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  • 3.  RE: eCTD structure

    Posted 01-Feb-2023 07:58
    Hi Valeria,

    Since submission of CAPAs is not defined in the eCTD structure, I probably would put the documents in Module 1.11 Information not covered under modules 2 to 5. If the CAPA is for manufacturing, then it would go in 1.11.1. If for other quality assurance requests, it could go in another appropriate section.

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    Glen Park PharmD
    Vice President, Regulatory Affairs and Quality Assurance
    New York NY
    United States
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  • 4.  RE: eCTD structure

    Posted 01-Feb-2023 09:31

    Hi Valeria,

    I agree with Glen, I would put it in 1.11.  I would also explain in the cover letter that the submission is in response to the Agency's request and include a copy of the request, if the request was in writing, or a summary of a voice conversation for context when the reviewer sees the submission.  You can link to the CAPAs, etc. in the cover letter.



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    Ken Rose
    Painesville OH
    United States
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