
As most people who work with eCTD are aware, agencies will accept clinical study reports structured in one of two ways:
There are advantages and disadvantages to each, which are outside the scope of this posting (you can request GlobalSubmit’s white paper “What Makes an eCTD Clinical Study Easily Reviewed by the FDA?” if you are interested in more detail). And in fact, thorough our work with the FDA, GlobalSubmit has found that some clients take a “hybrid” approach and submit a legacy report along with other files. Whatever approach is taken, the study, through the mechanism of the study tagging file, must be constructed so that each component is properly tagged and identified.
In a recent gathering with representatives from a number of Pharma companies, the question was raised (mainly regarding US submissions) as to which of the two formats sponsors were using.
The companies who have been submitting eCTD for some time appear to have made the switch to the granular/E3 format for the most part. However, they had different ways of meeting the review and approval challenges that are brought on when you no longer have a single document (or set of paper binders) to approve:
Sponsors need to understand how clinical reviewers will be seeing the studies they submit. You can see some FDA presentations on this subject on GlobalSubmit’s Agency Presentations page. Sponsors can also contact us to learn more about the FDA’s eCTD viewer, which is a GlobalSubmit product.
The codes needed to implement Regulated Product Submission (RPS) are here and can be found at the following location:
http://nciterms.nci.nih.gov/NCIBrowser/ConceptReport.jsp?dictionary=NCI_Thesaurus&code=C79148&bookmarktag=1
Unlike eCTD, where XML element names define your table of contents, coded terminology determines table of contents in a RPS submission.
The codes provided are only the table of contents sections for ICH’s Common Technical Document (CTD) and the US FDA’s regional table of contents.
US FDA’s food submissions content is pending. Codes for other countries or other product types within the United States have not developed for their respective table of contents.
The CTD codes provided are not perfect and are not complete.
Most of the attributes (e.g. manufacturer, study id; a.k.a. keywords in RPS speak) of the CTD, section1.11.4, Description: Multiple Module Information Amendment in the US FDA’s regional section and the study heading, mainly defined by ICH’s E3 specification are missing.
The FDA and NCI are working to update the code list.
The following are the list of study heading that where codes need to be created
The site features basic background, links to regualatory agencies, vendors and other eCTD resource pages, and a discussion forum for posting comments or questions. It’s a great opportunity for the eCTD community to exchange information, so I encourage you to check it out and post your comments or questions. (But remember I’m still looking for comments and responses to postings on this forum
since I haven’t received any yet.)