Regulatory Affarirs

1.What is Regulatory Affairs?

Ans-Regulatory Affairs in a Pharmaceutical industry, is a profession which acts as the interface between the pharmaceutical industry and Drug Regulatory authorities across the world. It is mainly involved in the registration of the drug products in respective countries prior to their marketing.

2.What are the goals of Regulatory Affairs Professionals?

Ans- 

• Protection of human health

• Ensuring safety, efficacy and quality of drugs

• Ensuring appropriateness and accuracy of product information

3.What are the Roles of Regulatory Affairs professionals?

Ans- 

• Act as a liaison with regulatory agencies

• Preparation of organized and scientifically valid NDA, ANDA,INDA ,MAA,DMF submissions

• Ensure adherence and compliance with all the applicable cGMP, ICH, GCP, GLP guidelines, regulations and laws

• Providing expertise and regulatory intelligence in translating regulatory requirements into practical workable plans

• Advising the companies on regulatory aspects and climate that would affect their proposed activities

• Apart from the above main roles, there are various other roles which Regulatory Affairs professionals play.

4.What is an Investigational New Drug (IND) application?

Ans- It is an application which is filed with FDA to get approval for legally testing an experimental drug on human subjects in the USA

5.What is a New Drug Application?

Ans- The NDA is the vehicle through which drug sponsors formally propose that the FDA approve a new pharmaceutical for sale and marketing in the U.S.  The data gathered during the animal studies and human clinical trials of an Investigational new drug become part of the NDA

In simple words, “It is an application which is filed with FDA to market a new Pharmaceutical for sale in USA”

6.What is an Abbreviated New Drug Application (ANDA)?

Ans- It is an application filed with FDA, for a U.S. generic drug approval for an existing licensed medication or approved drug.

In simple words, “It is an application for the approval of Generic Drugs “

7.What is a Generic Drug Product?

Ans- A generic drug product is the one that is comparable to an innovator drug product in dosage form, strength, route of administration, quality, performance characteristics and intended use. 

8.What is a DMF?

Ans- A Drug Master File (DMF) is a submission to the Food and Drug Administration (FDA) that may be used to provide confidential detailed information about facilities, processes, or articles used in the manufacturing, processing, packaging, and storing of one or more human drugs.

Important facts regarding DMFs

• It is submitted to FDA to provide confidential information
• Its submission is not required by law or regulations
• It is neither approved nor disapproved
• It is filed with FDA to support NDA, IND, ANDA another DMF or amendments and supplements to any of these
• It is provided for in the 21 CFR (Code of Federal Regulations) 314. 420
• It is not required when applicant references its own information

 9.What are the types of DMF’s?

Ans-

Type I: Manufacturing Site, Facilities, Operating Procedures, and Personnel (No longer accepted by FDA)

Type II: Drug Substance, Drug Substance Intermediate, and Material Used in Their Preparation, or Drug Product

Type III: Packaging Material

Type IV : Excipient, Colorant, Flavor, Essence, or Material Used in Their Preparation

Type V: FDA Accepted Reference Information (FDA discourages its use)

10.What is a 505 (b)(2) application ?

Ans- 505 (b)(2) application is a type of NDA for which one or more investigations relied on by applicant for approval were not conducted by/for applicant and for which applicant has not obtained a right of reference.

11.What kind of application can be submitted as a 505(b)(2) application?

Ans-  

• New chemical entity (NCE)/new molecular entity (NME)

• Changes to previously approved drugs

12. What are the examples of changes to approved drug products for which 505(b)(2) application should be submitted ?

Ans-  

• Change in dosage form.

• Change in strength

• Change in route of administration

• Substitution of an active ingredient in a formulation product

• Change in formulation

• Change in dosing regimen

• Change in active ingredient

•  New combination Product

• New indication

• Change from prescription indication to OTC indication

• Naturally derived or recombinant active ingredient
• Bioinequivalence

13.What are the chemical classification codes for NDA?

Ans-  

Number	Meaning
1	New molecular entity (NME)
2	New ester, new salt, or other noncovalent derivative
3	New formulation
4	New combination
5	New manufacturer
6	New indication
7	Drug already marketed, but without an approved NDA
8	OTC (over-the-counter) switch

14.What are the differences between NDA and 505 (b)(2) application ?

Ans-  

S.No.	New Drug Application (NDA)	505 (b)(2) Application
1.	All investigations relied on by applicant for approval were conducted by/for applicant and for which applicant has right of reference	One or more investigation relied on by applicant for approval were not conducted by/for applicant and for which applicant has not obtained a right of reference
2.	Generally, filed for newly invented pharmaceuticals.	Generally, filed for new dosage form, new route of administration, new indication etc for all already approved pharmaceutical.

Note: 505 (b)(2) application is a type of NDA. 

15.What is a Marketing Authorization Application?

Ans- It is an application filed with the relevant authority in the Europe (typically, the UK's MHRA or the EMA’s Committee for Medicinal Products for Human Use (CHMP)) to market a drug or medicine.

As per UK’s MHRA-

Applications for new active substances are described as 'full applications'.

Applications for medicines containing existing active substances are described as 'abbreviated’ or ‘abridged applications’.

16.What is an ASMF?

Ans-Active substance master file is a submission which is made to EMA, MHRA or any other Drug Regulatory Authority in Europe to provide confidential intellectual property or 'know-how' of the manufacturer of the active substance.

In simple words, “It is a submission made to European Drug regulatory agencies on the confidential information of Active Substance or Active pharmaceutical Ingredient (API)”.

17.What are the types of active substances for which ASMFs are submitted?

Ans-

• New active substances

• Existing active substances not included in the European Pharmacopoeia (Ph. Eur.) or the pharmacopoeia of an EU Member State

• Pharmacopeial active substances included in the Ph. Eur. or in the pharmacopoeia of an EU Member State

18.What is the difference between DMF and ASMF (with respect to submission)?

Ans-ASMF is submitted as Applicant’s Part (Open Part) and Restricted Part (Closed Part)

There isn’t any differentiation of DMF’s into parts

19.What is ICH?

Ans-International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH): is a project that brings together the regulatory authorities of Europe, Japan and the United States and experts from the pharmaceutical industry in the three regions to discuss scientific and technical aspects of pharmaceutical product registration.

20.What is CTD?

Ans-The Common Technical Document (CTD) is a set of specification for application dossier, for the registration of Medicines and designed to be used across Europe, Japan and the United States.Quality, Safety and Efficacy information is assembled in a common format through CTD .The CTD is maintained by the International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH).

CTD format for submission of drug registration applications/dossiers is widely accepted by regulatory authorities of other countries too like Canada, Australia etc. 

21.What are the ICH guidelines to be referred for preparation of registration dossiers/applications of medicines (With respect to format and contents in each module)?

Ans-

M4   Guideline

M4Q Guideline

M4S Guideline

M4E Guideline

22.What are the modules in CTD?

Ans- 

The Common Technical Document is divided into five modules:

Module 1. Administrative information and prescribing information

Module 2. Common Technical Document summaries (Overview and summary of modules 3 to 5)

Module 3. Quality 

Module 4. Nonclinical Study Reports (toxicology studies)

Module 5. Clinical Study Reports (clinical studies)

22.What is Orange Book?

Ans-

• It is the commonly used name for the book “Approved Drug Products with Therapeutic Equivalence Evaluations”, which is published by USFDA.

• It contains the list of drug products, approved on the basis of safety and effectiveness by the Food and Drug Administration (FDA) under the Federal Food, Drug, and Cosmetic Act.

23.What is Hatch-Waxman act?

Ans-It is the popular name for Drug Price Competition and Patent Term Restoration Act, 1984. It is considered as the landmark legislation which established the modern system of generic drugs in USA. Hatch-Waxman amendment of the federal food, drug and cosmetics act established the process by which, would be marketers of generic drugs can file Abbreviated New Drug Application (ANDA) to seek FDA approval of generic drugs. Paragraph IV of the act, allows 180 day exclusivity to companies that are the "first-to-file" an ANDA against holders of patents for branded counterparts.

In simple words “Hatch-Waxman act is the amendment to Federal, Food, Drug and Cosmetics act which established the modern system of approval of generics ”

24.What are the patent certifications under Hatch-Waxman act?

Ans-As per the Hatch and Waxman act, generic drug and 505 (b) (2) applicants should include certifications in their applications for each patent listed in the “Orange Book” for the innovator drug. This certification must state one of the following:

(I) that the required patent information relating to such patent has not been filed (Para I certification);

(II) that such patent has expired (Para II certification);

(III) that the patent will expire on a particular date (Para III certification); or

(IV) that such patent is invalid or will not be infringed by the drug, for which approval is being sought(Para IV certification).

A certification under paragraph I or II permits the ANDA to be approved immediately, if it is otherwise eligible. A certification under paragraph III indicates that the ANDA may be approved when the patent expires.

25.What is meant by 180 day exclusivity?

Ans-The Hatch-Waxman Amendments provide an incentive of 180 days of market exclusivity to the “first” generic applicant who challenges a listed patent by filing a paragraph IV certification and thereby runs the risk of having to defend a patent infringement suit.

180 Day Exclusivity could be granted to more than one applicant. The recent example is- 180 day exclusivity was granted to Ranbaxy and Watson Laboratories for marketing generic version of  Lipitor ( Atorvastatin calcium).

26.What are the procedures for Approval of Drug in EU?

Centralised Procedure (CP)

Decentralised Procedure (DCP)

Mutual Recognition Procedure (MRP)

National Procedure (NP)

27.What is the Full form of abbreviation, CEP?

Certificate of Suitability to the monographs of the European Pharmacopoeia (or) Certificate of suitability of monographs of the European Pharmacopoeia (or) Certification of suitability of European Pharmacopoeia monographs

It is also informally referred to as Certificate of Suitability (COS)

28.What is a CEP?

It is the certificate which is issued by Certification of Substances Division of European Directorate for the Quality of Medicines (EDQM), when the manufacturer of a substance provides proof that the quality of the substance is suitably controlled by the relevant monographs of the European Pharmacopoeia.

29.What are the recently approved new Drugs by FDA (Under NDA Chemical Type 1)? (As on 14^th March, 2012)

Ans-

S.NO.	NDA #	NAME OF DRUG	NAME OF ACTIVE INGREDIENT	COMPANY
1	203188	KALYDECO	IVACAFTOR	VERTEX PHARMS
2	203388	ERIVEDGE	VISMODEGIB	GENENTECH
3	202324	INLYTA	AXITINIB	PFIZER
4	202833	PICATO	INGENOL MEBUTATE	LEO PHARMA AS
5	202514	ZIOPTAN	TAFLUPROST	MERCK SHARP DOHME
6	021746	SURFAXIN	LUCINACTANT	DISCOVERY LABORATORIES INC

30.Full forms of some of the Abbreviations related to Regulatory Affairs-

S.No.	Abbreviation	Full Form
1	NDA	New Drug Application
2	ANDA	Abbreviated New Drug application
3	IND	Investigational New Drug Application
4	DMF	Drug Master file
5	ASMF	Active Substance Master File
6	MAA	Marketing Authorisation Application
7	CEP	Certificate of Suitability to the monographs of the European Pharmacopoeia
8	ICH	The International Conference on Harmonisation of technical requirements for registration of Pharmaceuticals for human use.
9	CTD	Common technical document for the registration of pharmaceuticals for human use.
10	AP	Applicant’s Part
11	RP	Restricted Part
12	OP	Open Part
13	CP	Closed Part
14	NME	New Molecular Entity
15	NCE	New Chemical Entity
16	SmPC	Summary of Product Characteristics
17	PL	Packaging Leaflet
18	RMS	Reference Member State
19	CMS	Concerned Member State
20	CHMP	The Committee for Medicinal Products for Human Use
21	CPMP	Committee for Proprietary Medicinal Products
22	CVMP	Committee For Medicinal Products For Veterinary Use
23	SUPAC	Scale-up and post approval changes
24	BACPAC	Bulk Active Chemicals Post approval Changes
25	cGMP	Current good Manufacturing Practice
26	GCP	Good clinical Practice
27	GLP	Good Laboratory Practice

31.Well known Drug Regulatory Agencies across the world-

S.No.	Country /Region	Regulatory Agency
1	United States of America	United States Food and Drug Administration (USFDA)
2	United Kingdom	Medicines and Healthcare products Regulatory Agency (MHRA)
3	European Union	European Medicines Agency (EMA)
4	European Union	European Directorate for the Quality of Medicines (EDQM)
5	Australia	Therapeutic Goods Administration (TGA)
6	Canada	Therapeutic Products Directorate  (TPD) in Health Product and food branch (HPFB) of Health Canada (HC)
7	Japan	Pharmaceutical and Medical Devices Agency (PMDA)
8	France	Agence Francaise de Securite Sanitaire des Produits de Sante (AFSSAPS) Translated into English as- French Agency for the Safety of Health Products
9	Germany	Bundesinstitut für Arzneimittel und Medizinprodukte, (BfArM) Tanslated into English as- Federal Institute for Drugs and Medical Devices
10	Brazil	Agência Nacional de Vigilância Sanitária (ANVISA) Tanslated into English as- The National Health Surveillance Agency
11	India	Drugs Controller General of India (DCGI) who heads Central Drugs Standard Control Organisation (CDSCO)
12	Switzerland	Swiss Agency for Therapeutic Products (SWISSMEDIC)
14	Singapore	Health Sciences Authority (HSA)
15	New Zealand	New Zealand Medicines and Medical Devices Safety Authority (MEDSAFE)

Note: 

1.The above Q & A are more suitable for the beginners/entry level positions in the field of Regulatory Affairs

2. Most of the Q & A are reproduced from my previous posts in this blog, hence refer the respective posts for references.

This article is aimed at listing down the simple steps/facts, which I hope will help in solving the big riddle of getting a job in the field of regulatory affairs !

First of all, I would like to share my personal experiences in pursuit of job in the field of Regulatory Affairs. After my B.Pharmacy, I was pretty much sure that I wanted to get into RA., so I enrolled into the course offered by BII-Industry Program in RA, which was famous back then. I also enrolled into a short term industry oriented course for pharma graduates which included RA as one of the topics. I had also began researching regarding RA on the internet, but could get info in bits and pieces (This was the reason for me to start Regulatory One). 

After considerable time of enrolling into the above courses, I got a call for interview in my first company. I had few more freshers (beginners) for competition at the time of interview. I cleared the interview and got the job due to the fact that I had done suitable home work and my research study on DMF (Drug Master files), which was part of my course, was of great help. I am trying to state the fact that, if you want to get a job, you need to have special skills which are not there with your competitors!

The information which I learnt, while I worked on Regulatory One, helped  me to get my 2nd job.

Gaining Skills in Regulatory Affairs - 

• If  you have done M.pharmacy (not in RA)- My suggestion would  be-do a diploma/PG diploma course related to RA through part-time/distance. My personally preferred course and institute is PG Diploma in Pharmaceutical Regulatory Affairs from  Jamia Hamdard University since it is accredited by NAAC in 'A' category and they have contact classes in major cities. The feed back I received regarding the course was that, its good.

•  If  you are B. Pharmacy graduate and want to make a career in RA -I would recommend you to do M.Pharmacy in Pharmaceutical RA .

         The list of institutes offering M.Pharmacy in RA are given in the below link.

          http://www.regulatoryone.com/2011/10/institutes-offering-regulatory-affairs_03.html

•  Browse, through the websites of Regulatory Agencies like FDA, MHRA, CDSCO and try to gain as much knowledge as possible. In the below page of Regulatory One, Link to the updated news section in the websites of premier regulatory agencies of world is provided.       

         http://www.regulatoryone.com/p/updated-news.html

• In FDA's website there are links like CDER learn , Educational Resources and Webinars which contain lots of useful information. Similarly there are training modules in MHRA' s website.Of course, all the above listed useful links are absolutely free to access !

• Among all the ICH guidelines- M4 (and allied guidelines M4Q, M4S, M4S), Q1A , Q1E ,Q2, Q3A, Q3B, Q3C, Q6A are the most important references for RA professionals. Knowing them is very important. 

• Go through all the articles, which I have written in Regulatory One. I personally believe that, if a beginner goes to the interview after reading the articles that I have written, they could easily clear the interview.

• The below listed link is very useful at the time of interview, especially for beginners (freshers).            

         http://www.regulatoryone.com/p/regulatory-affairs-interview-questions.html

Writing Skills -

• For a Regulatory Affairs professional, having good writing skills is very important, since he/she is involved in compilation of dossiers, responding to queries from regulatory agencies. 

Resume -  

• Make sure that, you have a well formatted, unique resume which is different from others. If possible, get the resume reviewed by an expert. Ensure to highlight the course which you have done related to RA and specific skill with respect to RA.
• Upload your resume in job websites like Monster and Naukri. Ensure to fill up all your details and have a complete profile.

Networking -  Networking is an important tool for getting to know about any openings in the field of Regulatory Affairs. In the professional Networking sites like Linkedin, having your complete profile is very important. The following things are to be considered/taken note of, while setting up your profile-

• Have your detailed profile, with special emphasis on your educational qualification, skills related to regulatory affairs. 

• Ensure that the information is given in a properly structured manner, without any grammatical errors.

• Ensure that the photo which you have uploaded is a one in which you are in formal dress and definitely not the one, which you had taken during your vacation in a casual dress!

• Join groups related to Regulatory Affairs like Drug Regulatory Affairs, Global Regulatory Affairs, Regulatory Affairs Job Opportunities etc and take active part in discussions in a relevant way.

• Request people who are in senior positions in RA field to be part of your Networks. If they accept to be part of your network, send them an email,(in a properly structured manner, without any typo/grammatical errors) requesting them to let you know if there are any openings in their company. Respect their privacy, and do not ask them for their personal numbers. If they see your profile and they find you to be good enough, they may definitely let you know, if there are any openings.

General Misconceptions- I guess, some of you might have got the free advice- "Start of your career by working in Quality Control /Quality Assurance. Then you will have a better chance of getting a job in RA". This logic is absolute false. Why will a company prefer a person with experience in QC/QA over a person with experience in RA ?

Guys, a person who is a fresher (beginner) can get a job in RA. The best example is, myself !

Hope, the above article will help you in getting a job in the field of Regulatory Affairs.