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As most people who work with eCTD are aware, agencies will accept clinical study reports structured in one of two ways:

  • The “Legacy” format where the study report body and appendices, exclusive of datasets and CRFs, are combined into a single PDF.  In some cases, the PDF has to be subdivided in order to remain within the ICH file size limit of 100 MB.
  • The “Granular” or “E3” format, where the study report, especially the appendices, are submitted as a set of individual files.

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:

  • One company created an overall approval sheet, stored with the study, that listed the components and gathered approvals for each component
  • One company reported assigning ownership to a specific medical writer who was responsible for all aspects of authoring, review and approval
  • Some companies still produced a consolidated study report for review purposes or for sending to external parties
  • All agreed that it is a significant and time-consuming process to manage the creation and approval of the granular components

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.

RPS codes – here, but not ready for prime time

posted by Jason Rock @ 11:55 PM
Thursday, March 19, 2009

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

  • Legacy Study Report
  • Synopsis
  • Study Report Body
  • Protocol or Amendment
  • Sample Case Report Form
  • IEC IRB Consent Form List
  • List Description Investigator Site
  • Signatures Investigators
  • List Patients With Batches
  • Randomisations Scheme
  • Audit Certificates Report
  • Statistical Methods Interim Analysis Plan
  • Inter Laboratory Standardisation Methods Quality Assurance
  • Publications Based on Study
  • Publications Referenced in Report
  • Discontinued Patients
  • Protocol Deviations
  • Patients Excluded from Efficacy Analysis
  • Demographic Data
  • Compliance and Drug Concentration Data
  • Individual Efficacy Response Data
  • Adverse Event Listings
  • Listing Individual Laboratory Measurements by Patient
  • Case Report Forms
  • Individual Subject Data Listing
  • Data Tabulation
  • Data Tabulation Dataset
  • Data Tabulation Data Definition
  • Data Listing
  • Data Listing Dataset
  • Data Listing Data Definition
  • Analysis Datasets
  • Analysis Dataset
  • Analysis Program
  • Analysis Data Definition
  • Annotated CRF
  • Annotated ECG waveform datasets
  • Image files
  • Subject Profile
  • Safety Report
  • Available on Request
  • Integrated analysis of efficacy - integrated summary of efficacy report
  • Integrated analysis of safety - integrated summary of safety report
  • Antibacterial microbiology report
  • Antiviral microbiology report
  • Special pathogens (e.g, fungi, parasites, mycobacteria) and immune modulator reports
  • Postmarketing periodic adverse event drug experience report description

Improved and Reorganized iRegulatory eCTD resource pages

posted by Kathie Clark @ 3:10 AM
Friday, August 8, 2008
Many of you have probably benefited from the “eCTD Resource Page” in the past. For both previous and new users, there’s some good news - the site iRegulatory eCTD resource pages has been updated and expanded.

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.)

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