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Ask Me Anything: Regulatory Strategy for Drugs and Devices

  • 1.  Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 24-Sep-2020 17:23

    Hi RegEx members,

    Recently, RAPS released its' quarterly Regulatory Focus Article Series: Regulatory Strategy for Drugs and Devices. We will be hosting an "Ask Me Anything" session on Wednesday, 30 September, from 1:30-2:30 PM ET here on RegEx. We will have two regulatory experts, @Jennifer Multari and @Manfred Ruthsatz, who will be discussing the articles in real-time and available to answer your questions.

    If you cannot make the session, please feel free to submit any questions ahead of time by sending me an email at regex@raps.org. All of your questions will be answered on this thread at the time of the event. 

    Looking forward to seeing your questions!

    Best,
    Annie

    ​​

    ------------------------------
    Annie O'Brien
    Community Manager
    Regulatory Affairs Professional Society
    regex@raps.org
    ------------------------------


  • 2.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 13:29

    The AMA is starting--post your questions for our experts below!



    ------------------------------
    Annie O'Brien
    Community Manager
    Regulatory Affairs Professional Society
    regex@raps.org
    ------------------------------



  • 3.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    This message was posted by a user wishing to remain anonymous
    Posted 30-Sep-2020 13:32
    This message was posted by a user wishing to remain anonymous

    In what ways would harmonized processes and standards for understanding baseline healthy microbiota promote development of strategies for nutrition and clinical applicability?




  • 4.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 13:36
    Hi there, we need to have a baseline to measure the effect e.g. of dysbiosis. this baseline could likely be personal for each healthy consumer or patient. MIRRI21 and other EU Commission projects are working on it.


    ------------------------------
    Manfred Ruthsatz PhD, RAC, RPH, FRAPS
    PhD
    Vevey
    Switzerland
    ------------------------------



  • 5.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 13:45
    currently, reagents, computer modeling, organ targets, ... is still quite individual, not yet comparable across the scientific community.

    ------------------------------
    Manfred Ruthsatz PhD, RAC, RPH, FRAPS
    PhD
    Vevey
    Switzerland
    ------------------------------



  • 6.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 13:37
    What are the overall conclusions and future plans according to the author, Jen Multari, on the conclusion of Project BRIDGE. Does she say a centralized training and hub in companies to train staff at local hubs. IF yes, how does she see it translate it to people like me who are planning on a career in regulatory strategy and are fairly new to the regulatory affairs. Would it be benefecial to specialize in a geographical region or a particular product life-cycle stage!? Article: https://www.raps.org/news-and-articles/news-articles/2020/5/outsourcing-in-regulatory-operations

    ------------------------------
    Shailaja Kunda
    Research Professional, Neurology, Mayo Clinic
    Denver CO
    United States
    ------------------------------



  • 7.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 13:41
    @Shailaja Kunda thank you for the question. I truly believe if companies are not outsourcing yet, they're definitely thinking about it. Given my experiences with implementing our centralized process and vendor hubs, I would say it is best to go-live in stages. I found rolling out to 1 hub at a time with those affected countries worked best and allowed us to learn a lot from the experience, to then make it better for the next hub and set of countries. To answer your question about your career, I think it depends on how mobile you want to be in the future. Do you see yourself staying at one company and one region or do you want to move around? Specializing in US RA, for example, could help you in similar countries like Canada, China, Australia, even the EU to a certain extent. Specializing in a particular product type or life-cycle stage could help you become a SME in that area, but it might be limiting. At the end of the day, the name of the game is agility - be open to learning, become a change agent within your sphere of influence, and never stop growing.

    ------------------------------
    Jennifer Multari RAC
    Head GSM & GSS Global and Regulatory Operations
    Taunusstein
    Germany
    ------------------------------



  • 8.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    This message was posted by a user wishing to remain anonymous
    Posted 30-Sep-2020 13:44
    This message was posted by a user wishing to remain anonymous

    Could you talk more about efforts to establish a baseline and standards for comparison of the human microbiome to help the understanding of what constitutes a 'normal' microbiome?




  • 9.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 13:49
    good point. see also my expanded answer under #5. We all might define 'normal' / healthy microbiome slightly differently. Here is where dysbiosis biomarkers, methods ... would need to be established and agreed upon globally.
    I would consider that this is still in a very early stage​

    ------------------------------
    Manfred Ruthsatz PhD, RAC, RPH, FRAPS
    PhD
    Vevey
    Switzerland
    ------------------------------



  • 10.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    This message was posted by a user wishing to remain anonymous
    Posted 30-Sep-2020 13:50
    This message was posted by a user wishing to remain anonymous

    Question for Jen Multari: You mentioned in your article that your team would be considering a 'follow-the-sun' approach to publishing this year to address shorter time to submission and flexibility and scalability. Could you talk more about the 'follow-the-sun' approach and share any updates you might have on the rollout?




  • 11.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 13:58
    Hi and thank you for the question! Follow-the-sun approach means work can be easily handed off from one hub to the next in order to keep the work flowing. This enables, for example, larger submissions to be continually worked on as the day progresses, even after one hub is offline for the day. It requires a strict approach to the publishing process and permissions within your publishing system.

    Follow-the-sun is also useful if, for example, one hub is overloaded with work and tasks can be moved easily between locations.

    For the past year or so we had been following this approach, meaning moving tasks between hubs to accommodate for resource constraints and workload. When a large original submission, or a larger submission in general, is required for submission, the team and hubs will be ready to take this on because of the task distribution using the follow-the-sun approach.

    ------------------------------
    Jennifer Multari RAC
    Head GSM & GSS Global and Regulatory Operations
    Taunusstein
    Germany
    ------------------------------



  • 12.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 13:56

    Here is one scenario that I would want to hear others' opinions on:

     

    This is about a new drug submission of a generic drug that will come off patent during the review, therefore getting the Marketing Authorization with

    the least number of requests from the regulator is crucial.

    The regulations indicate that the dossier needs to include at a minimum 6 months of Room Temperature data.

    The RA head knows that the data will not be available on time for the target date for submission.

    We assume that the product will have passing results at the end of the 6 months.

    The RA head decides to keep the filing date of the dossier with this strategy:

     

    1. dossier is submitted with empty nodes for the 6 M RT  data– it contains passing results for the 3 M accelerated that is provided in the dossier.

        The node can't be empty. It will fail validation at the regulator's end of the electronic transmission

        The company receives a validation failure notification and is asked to re-submit the complete electronic dossier as soon as possible.

        The dossier is resubmitted after – let's say – 3 business days, that include a week-end.

    2. The complete electronic dossier is sent with the "wrong batch" 6 M RT data

        This is caught by the regulator's reviewer during the screening – a screening deficiency notice is issued to respond to in 45 calendar days.

    3. Finally, the correct, passing, RT 6 M data is provided in a subsequent sequence of the eCTD dossier almost 2 months later that it should have been.

     

    Question for the RA people:

    Would you do this?

    Please tell us why, for both yes and no answers.



    ------------------------------
    Sorin Alb RAC
    Project Manager, Regulatory Affairs
    Scarborough ON
    Canada
    ------------------------------



  • 13.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:04
    @Neeta Sharma and @Ginny Hu perhaps you can weigh in on this? ​​

    ------------------------------
    Annie O'Brien
    Community Manager
    Regulatory Affairs Professional Society
    regex@raps.org
    ------------------------------



  • 14.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:07
    I am interested in how people can get better hands on training for developing INDs and NDAs.
    I see lots of good examples of 510Ks are available on the FDA site via FOIA. Is there anything like that for INDs/NDAs?
    I have been to lots of training/workshops, but none of them seem that hands on.


    ------------------------------
    Len Smith
    Counsel (Patents/IP/Contract/Regulatory)
    Scottsdale AZ
    United States
    ------------------------------



  • 15.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:15
    @Len Smith Do you mean preparation of content or eCTD structure, for example?

    ------------------------------
    Jennifer Multari RAC
    Head GSM & GSS Global and Regulatory Operations
    Taunusstein
    Germany
    ------------------------------



  • 16.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:20
    Hi Jennifer and AMA team.  I am interested in learning about details with actual examples.  The FDA's posting of FOIA'd 510Ks is a great way to learn a great deal about 510 practice.  What is the counterpart to that in pharmaceuticals?  Alternatively, is there a training that is not focused on the high level rules, but actually exemplifies implementation (using a few hypothetical scenarios, maybe)?  Is this something covered in MS programs?

    ------------------------------
    Len Smith
    Counsel (Patents/IP/Contract/Regulatory)
    Scottsdale AZ
    United States
    ------------------------------



  • 17.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:26
    @Len Smith, Hi and thanks for the question. I cannot answer specifics but I can tell you about my MSc program in European Regulatory Affairs I completed in 2018 at the Donau University in Vienna. ​There were a few modules pertaining specifically to MAAs and went very much into detail on construction and content requirements. There are many MS and PhD programs offered in the US as well, and might be worth researching if you are really interested in furthering a career in RA!

    ------------------------------
    Jennifer Multari RAC
    Head GSM & GSS Global and Regulatory Operations
    Taunusstein
    Germany
    ------------------------------



  • 18.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:10
    1) I have a hobby that is developing Ai to play chess by creating a neural network that constantly learns with massive chess game datasets. This is similar to how other neural networks become proficient including medicine. I can alter the learning rate of the net and have it score outcomes differently but I cannot determine how it actually prefers one move to another; that's hidden from everyone's view. How will regulators consider SW validation with regards to AI?

    ------------------------------
    Edward Panek
    VP, QA/RA
    Blue Spark Technologies
    Research into Neural Nets - https://www.twitch.tv/edosani
    ------------------------------



  • 19.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:16
    Hi @Ed Panek, interesting question. I am not an expert in this field by any means, but more and more agencies are looking at software as a medical device. It might be that something like this would be classified as a medical device. Worth looking into!​

    ------------------------------
    Jennifer Multari RAC
    Head GSM & GSS Global and Regulatory Operations
    Taunusstein
    Germany
    ------------------------------



  • 20.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    This message was posted by a user wishing to remain anonymous
    Posted 01-Oct-2020 09:09
    This message was posted by a user wishing to remain anonymous

    For @Ed Panek, regulators like the FDA have published position papers on how they would handle AI, and specifically, the locked vs unlocked algorithm. They have proposed using something analogous to the comparability protocols on the drug, related to how changes would handle. FDA has indicated they will likely need additional congressional authority to implement, hence it is just for discussion right now.

    Other regulators are publishing position papers as well.


  • 21.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    This message was posted by a user wishing to remain anonymous
    Posted 30-Sep-2020 14:10
    This message was posted by a user wishing to remain anonymous

    Also for Jen:

     

    Has having Project BRIDGE in place helped your company deal with the disruptions caused by the pandemic? If so, how, and have you had to make any adjustments?




  • 22.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:14
    Hi, and thank you for the question. When lockdowns started across the globe, we proactively had measures put in place with our legal and sourcing teams to ensure our vendor colleagues could easily work from home with and without BI equipment. This was key to ensure the work continued uninterrupted.

    ------------------------------
    Jennifer Multari RAC
    Head GSM & GSS Global and Regulatory Operations
    Taunusstein
    Germany
    ------------------------------



  • 23.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:12
    Another question for @Manfred Ruthsatz:

    Could you discuss the regulatory needs relating to microbiomes, specifically the regulatory framework, harmonization, safety etc, and outcome benefits?



    ------------------------------
    Annie O'Brien
    Community Manager
    Regulatory Affairs Professional Society
    regex@raps.org
    ------------------------------



  • 24.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:20
    The intended use defines the way forward   Yet, the microbiome regulatory science is still quite diverse between US and even within the EU (e.g. FMT, probiotics).. Plenty of variables still to address, considering that plenty is still unknown (e.g. possibility to culture microbiome; 40% of protein functions).

    ------------------------------
    Manfred Ruthsatz PhD, RAC, RPH, FRAPS
    PhD
    Vevey
    Switzerland
    ------------------------------



  • 25.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:19
    Karen from Canada submitted this question:

    I was interested in your comments on the effect the SEND requirements for preclinical studies is having on US IND submissions. The time and cost of preparing SEND datasets for legacy studies makes submission in the US far less attractive for small businesses. Any more thoughts to share?

    ------------------------------
    Annie O'Brien
    Community Manager
    Regulatory Affairs Professional Society
    regex@raps.org
    ------------------------------



  • 26.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 14:24
    @Neeta Sharma and @Ginny Hu, do you have thoughts on this? ​​

    ------------------------------
    Annie O'Brien
    Community Manager
    Regulatory Affairs Professional Society
    regex@raps.org
    ------------------------------



  • 27.  RE: Ask Me Anything: Regulatory Strategy for Drugs and Devices

    Posted 30-Sep-2020 15:28
      |   view attached

    Karen, on SEND, have a look @ the paragraph on page 12, incl. the 2 additional references.

     

    Kind regards,

    Manfred

     

    Dr Manfred Ruthsatz

    RPh, DABT, RAC, FRAPS, CC

    Executive Director, Nutrition+HealthCARE

    Cell: +41 79 826 2283 - ManfredRuthsatz@gmail.com LinkedIn

     




    Attachment(s)

    pdf
    Biomolecules 2020.pdf   13.16 MB 1 version