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Archive for August, 2009

Regulatory Software Technology Trends Survey

posted by Kathie Clark @ 6:56 PM
Monday, August 24, 2009

Recently, I caught up with my old friend Steve Gens (of Gens and Associates Inc.) to talk with him about a very interesting global survey he just completed on “Benchmarks of Emerging Technologies and Approaches for Collaboration and Document Management” in the Pharma industry.  The 2009 survey was completed in partnership with Steve Scribner of International Life Sciences Solutions, as a follow-up to their well-received 2007 survey.  Steve and Steve worked with 37 Pharma companies (including 17 of the top 20, but no very small companies) to understand their collaboration and document management practices, program priorities and challenges, technology landscapes, outsourcing, and total cost of ownership.  Some of their findings may surprise you.   

Here are a few key points from the Gens & Scribner survey (including both the expected and the surprising):

  • Over 90% of respondents feel that their Electronic Document Management (EDM) solution for submission documents is effective, with less than 10% considering their solution ineffective; however 44% will be changing their systems within the next three years.  All of the respondents had implemented an EDM solution.
    • Top priorities for companies in the EDM area are integration with collaboration systems, enhancing system performance, improving searching, and reducing TCO
  • Speaking of collaboration, just over 50% feel that they have an effective solution.  The survey also provided insight on specific aspects of collaboration, such as collaboration with partners and regulators, with details available in the figure below.

collaboration-effectiveness1

  • Adoption of XML authoring remains rare outside of the obvious areas of labeling, with less than 10% of companies reporting other applications such as clinical and nonclinical reports and protocols.  Even in the labeling area, only 25% of companies are doing XML authoring themselves. Many companies are projecting to conduct pilots in 2010 & 2011.
  • eCTD adoption was nearly universal, with only a couple of the participants (both Japanese) still researching or unsure about adoption.
  • PIM, on the other hand, has been adopted by only about 15% of companies, with another 10% in the process.  (and lots researching, probably due to the news that PIM will be mandated in the relatively near future).
    • Out of the 37 companies, only 8 are submitting PIM right now – four top 20 and (surprisingly to me) four mid-tier
  • Dossier publishing was outsourced to low cost regions at least in part by 15 out of the 37 companies, with India (4) and China (4), with 10 companies planning to expand outsourcing.  Although companies are increasingly driven to overseas outsourcing due to economic reasons, they are also very concerned with Intellectual Property issues in many outsourcing regions.
  • Twenty-four percent of EU participants outsource NeeS production.  Out of that group, 31% were satisfied with their outsourcing arrangements and about 31% actively dissatisfied.   Interestingly, satisfaction rates with eCTD outsourcing were significantly higher.

One conclusion that was surprising to Steve was that a great many companies do not yet collect metrics on cycle times and the efficiency and value of their EDM-related programs. Companies are also much slower to implement regulatory tracking than projected, most likely due to issues regarding data cleansing and harmonization/adoption of a global system by stakeholders used to many specialized if less capable local systems.

What’s Next?

Steve and Steve will be conducting individual debriefing sessions with the survey participants in the coming weeks.   These sessions help the participating companies understand where they stand with respect to their peers in the industry.  In previous years, the extremely detailed information provided to the participants has proven invaluable in confirming their direction and priorities or helping them re-plan.    Having seen the detailed information and analysis that will be presented in the debriefing sessions (a subset was presented at the DIA Annual Meeting in June), I can well believe that the participants in the 2009 survey will conclude that the time they spent participating in the survey was a good investment.

If you didn’t participate in the survey, you may still be able to get more detailed information since Steve and Steve will most like make some of it available in a series of articles or presentations in upcoming months. Contact information is as follows: Steve Gens (sgens@comcast.net) and Steve Scribner (SteveScribner@nc.rr.com). They have over 40 years experience in the Life Science industry and both their companies provide consultancy services (Strategy, Implementation Planning, and Program Management).

Analysis: New EU M1 Spec Version 1.4

posted by Kathie Clark @ 4:09 AM
Friday, August 14, 2009

As promised, the EMEA released Version 1.4 of the EU Module 1 Specification on schedule in August.  The new spec has some changes that will impact eCTD assembly, publishing, verification and viewing software tools.  The EMEA has reached out to the vendor community to ensure that they are aware of the changes to ensure that they can modify their products in advance of the required implementation timeline.  It’s worth reproducing that timeline here – quoting from EU Module 1 Implementation Guidance:

1.    Applicants are advised that, from 1st January 2010, when the new variation regulation comes into force, the EU M1 v1.4 must be used for any eCTD submission for any European procedure that contains grouped variations or is subject to a worksharing agreement. Grouped variation or worksharing eCTD submissions provided from this date using any previous version of the EU M1 specification (v1.0. v1.1, v1.2.1 or v1.3) will not be accepted. All European Regulatory Authorities must therefore be able to accept eCTD submissions built using EU M1 v1.4 from 1st January 2010.

2.    Applicants are further advised that, from 1st July 2010, the EU M1 v1.4 must be used for all eCTD submissions for all European procedures, and any eCTD submissions provided from this date using any previous version of the EU M1 specification (v1.0. v1.1, v1.2.1 or v1.3) will not be accepted

The nature of this timeline is related to the most significant change in V1.4: the Specification and DTD have been amended so as to support the New Variations Regulation. The envelope has been reviewed so as to support the different modes of submission for variations: single, grouping and worksharing.

A new envelope element, submission ‘mode’ is now provided for use with variations and line extensions.  A related change involves the use of a “high-level” submission number for worksharing submissions and certain grouped submissions.  Submission publishing tools will require user interface changes to accommodate these requirements, and publishers will need to be aware of their correct usage.  EMEA has also provided a number of sample submissions to illustrate the correct use of these elements.

Another significant change is a new limit on folder path length. The Specification has been amended to update the maximum length for file path. The new maximum length has been set to 180 characters.  That is, the overall folder and file name path length starting from the sequence number should not exceed 180 characters, for any file in any module. This is an EU regional requirement, and it is acknowledged that this is less than the ICH agreed overall path length.  This may cause issues for anyone using attribute-related folder paths (such as drug substance, indication, etc.) of more than a dozen characters or so.  Although this won’t affect sequences already submitted, it will mean that some sponsors may have to modify their conventions in this area (keep in mind that the HAs have said that folder names do not have to actually match metadata in the eCTD backbone).

A few more minor changes:

·         The ATC number metadata in M1 has been retired

·         A few new values have been added for submission type

·         A new stylesheet has been supplied

·         Naming conventions for the tracking table have been updated

 

Sponsors need to prepare to accept and validate updated versions of their publishing tools and will need to work with vendors to ensure that updates will be available in advance of the portion of the deadline that applies to them based on their submission plans.  They will also need to update some procedures.

It’s worth reviewing the EU Module 1 V1.4 Release Notes to make sure you understand all the changes… 

In other EMEA news, a The NeeS validation criteria v1.0 (a set of technical validation criteria to be applied to all non-eCTD electronic submissions has been drafted.  Finally, Practical guidelines on the use of the eCTD format for the Plasma Master File (PMF), for the submission of MAAs for plasma derived medicinal products and medical devices that include a PMF certificate, and for 2nd step procedures, has been released by EMEA.

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