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A new member within EIPG


The European Industrial Pharmacists Group (EIPG) is pleased to announce the Romanian Association (AFFI) as its newest member following the annual General Assembly of EIPG in Rome (20th-21st April 2024). Commenting on the continued growth of EIPG’s membership, EIPG President Read more

The EU Parliament voted its position on the Unitary SPC


by Giuliana Miglierini The intersecting pathways of revision of the pharmaceutical and intellectual property legislations recently marked the adoption of the EU Parliament’s position on the new unitary Supplementary Protection Certificate (SPC) system, parallel to the recast of the current Read more

Reform of pharma legislation: the debate on regulatory data protection


by Giuliana Miglierini As the definition of the final contents of many new pieces of the overall revision of the pharmaceutical legislation is approaching, many voices commented the possible impact the new scheme for regulatory data protection (RDP) may have Read more

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The ICMRA collaborative hybrid inspection pilot (CHIP)

January 22, 2024 , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , ,

by Giuliana Miglierini

Hybrid inspections emerged during the pandemic as a new way to approach the assessment of pharmaceutical plants and productions by regulators. More in particular, under this approach regulatory authorities from different geographical areas join efforts to reach a shared regulatory decision based on results of either on-site or remote inspections (see here more information on EMA’s website).

Hybrid inspections are the focus of a pilot project launched by the International Coalition of Medicines Regulatory Agencies (ICMRA), following a workshop held in July 2023 and organised in collaboration with the International Federation of Pharmaceutical Manufacturers and Traders (IFPMA).

Among the main objectives of the collaborative hybrid inspection pilot (CHIP) is the assessment of existing technologies and virtual inspection methods in supporting a stronger collaboration among regulators. The development of a global Pharmaceutical Quality Knowledge Management System (PQ KMS) would be one of the main consequences of such collaboration. The CHIP pilot is now open to new applications from the pharmaceutical industry. More information is available on ICRMA website, together with the summary report of the PQ KMS workshop and related documentation. We summarise the main features of the pilot.

The CHIP pilot on hybrid inspections

The methodology used to run the CHIP pilot, together with inspection expectations to be met by the industrial partners, are described in the dedicated page of the ICMRA website. The implementation plan is available at this link.

The first phase of the pilot ran in 2023 and included the collaborative assessments of post-approval changes as a useful tool to improve cross-regional access to critical medicines. This part of the project led, in May 2023, the European Medicines Agency (EMA) and the US Food and Drug Administration to approve on the same day, without any delay between the two areas, the addition of three new manufacturing sites in the supply chain of a treatment for a rare type of cancer. The Japanese regulator PDMA also participated to the project as observer.

The new phase of the project will involve other regulators and will focus on the collaboration between regulatory authorities (RAs) and industry to implement and promote innovative regulatory approaches and technologies.

In hybrid inspections, only one leading RA is present on-site with its inspectors (the local RA, whenever feasible), while the other regulators participate from remote to follow the on-site inspection team procedures. The new approach is expected to reduce efforts, cost and time for both regulators and inspected pharmaceutical companies, as a single inspection will allow multiple authorities to agree on a site’s compliance. Marketing authorisation holders (MAHs) may also experience a smoother submission process, as they would possibly receive a single list of information requests, comments, and questions from multiple regulatory authorities. The pilot is also expected to lead to the definition of a suitable approach to handle post-authorisation inspections (routine inspection).

Preparing for the hybrid inspection

Hybrid inspections start with pre-inspections activities, to be launched 30-60 days prior to the actual inspection. The main goal of the pre-inspection is to ensure the target facility has all the needed resources to host, support and accommodate the hybrid inspection.

In this phase, the on-site lead inspectorate is called to liaise with the site to arrange for all the organisational and logistical aspects, as well as networking with all the other participating RAs to plan the activities to be observed during the inspection. The anticipated agenda and length of the hybrid inspection should be determined in advance by participating RAs and shared with the company by the lead inspectorate. Hybrid inspections should be no longer than normal on-site inspections.

The planned scope of the inspection has also to be agreed upon during pre-inspection, and it should be the same for each participating RA. To this instance, the leading on-site inspectorate is in charge of obtaining from the company all the requested information, on the basis of accepted global standards (i.e., Site Master File based on PIC/S). The inspected facility is entitled to receive details of the closing meeting between RAs prior to the conduct of the inspection.

As for the number of participants in the inspection (including investigators and coordinator roles), it should reflect realistic staffing levels for long-term implementation. The planning phase should also be comprehensive of the establishment of a communication channel (including testing the stability of the connection) between RAs and the facility, and a second one for RAs to communicate between the on-site and remote teams.

A coordinating officer, assigned by the lead inspectorate team, should oversee the logistics for the remote team, and a facilitator from the company should also be identified to manage the remote team’s requests and upload all the documentation. This last one should be shared using the appropriate exchange platforms, as specified by each authority, and agreed during the pre-inspection phase.

The actual hybrid inspection

The opening meeting is the first act of the hybrid inspection, during which all participants (both on-site and remote) introduce themselves and define the lead inspector in charge of the coordination of all activities. The coordinating officer is also nominated in the opening meeting, and the inspection team schedule is presented to the facility’s key personnel. The hosting site can introduce the facility, including the Quality management system and production schedule.

The possibility to run a virtual tour for remote RAs of the areas and activities to be inspected has to be assessed and agreed on during the pre-inspection phase. Should this not be possible due for example to difficulties with the Internet connection, remote RAs may rely on the observations made by the on-site team, which will inspect the plant according to the defined scope of the inspection, with reference to critical manufacturing activities.

Inspectors may start their tour of the plant following the same logical flow of the process they are assessing, from inwards warehouses to production areas, QC areas and outwards warehouses. Some breakout rooms may be created along this flux in order to allow inspectors to check the relevant documentation and run interviews with personnel. To this instance, the remote team should request in advance documents through the coordinating officer, and possibly access them off-line during the inspection should different time zones apply. Questions to be proposed during the interviews should also be provided in advance by the remote team to the lead inspector or through the coordinating officer.

The results of the activities performed during the inspection is discussed by RAs at the end of each-day, in order to plan the activities for the following day; the lead inspector shall then communicate them to the facility.

Closure of the inspection

The closing meeting is the final act of the inspection, during which the lead inspector should report on the observed GMP deficiencies. In case of a different perception of a certain issue by different RAs, they should try to reach a common position on its significance during a pre-meeting. Any difference in GMP deficiencies or outcomes should be illustrated to the company by the lead inspector during the closing meeting.

This should also be the place to discuss post-inspection activities and their timelines, that should be aligned between the different participating RAs. Collaboration between regulators should also extend to the coordinated assessment of the documentation on corrective and preventive actions (CAPAs) submitted by the manufacturer.


EMA, new features for the PRIority Medicines (PRIME) scheme

May 19, 2023 , , , , , , , , , , , , , , , , , , , , , , , , , , ,

By Giuliana Miglierini

Based on the review of results obtained in the first five years of implementation of the PRIority Medicines (PRIME) scheme, the European Medicines Agency has launched a set of new features to further enhance the support to developers of new medicinal products in areas of unmet medical needs (see the revised guidance for applicants seeking access to PRIME scheme).

The guideline complements contents of other documents, i.e. EMA’s Guidance on accelerated assessment, the guidance on the preparation of the PRIME kick-off meeting and submission readiness meeting, the one specific for applicants seeking scientific advice and protocol assistance, and the toolbox guidance for robust CMC data packages.

The new set of measures to speed up approval

The major goal of the PRIME scheme, introduced by EMA in 2016, is to accelerate the regulatory pathway for new medicines seeking approval and that may have a high impact on severe conditions currently lacking treatment options. The scheme aims to facilitate the generation of robust data packages supporting the compliance to regulatory requirements for all aspects of development and production of a new medicine.

A critical aspect to ensure efficiency of this process is the ability to build a constructive and continuous dialogue between regulators and sponsors, fundamental for the continuous monitoring of development activities. To this regard, EMA will establish a new roadmap for each PRI-ME development, that will parallel and complement the already existing product development tracker. The combination of the two should allow the optimisation of early scientific advice and regulatory support provided by EMA committees. It should also facilitate the prompt identification of critical aspects and emerging issues in the development, requiring further discussion between regulators and sponsors to positively solve them.

Should issues occur with a specific programme that has already received comprehensive initial advice, EMA is now entitled to provide expedited scientific advice specifically for PRIME developments. The new approach will be tested in a one-year pilot project started in March 2023. Requests of expedited scientific advice have to meet some criteria: the request is a follow-up advice, subsequent to the initial scientific advice procedure; it refers to issues with a specific, well-defined scope; and its urgency has to be justified, in comparison to standard scientific ad-vice timelines. The PRIME Scientific Coordinator is the first point of contact for sponsors to discuss these requests, which have to be submitted via IRIS, as well as all other issues referred to the PRIME scheme.

The pilot phase also includes the new roadmap and tracker to replace the previous PRIME annual update for any products that have not yet been discussed in a Kick-off meeting. Contents of both the roadmap and development tracker are detailed in the updated guidance.

Submission readiness meetings are the third new measure introduced by EMA. The meetings will serve as the final checking point to assess the status of development, with respect to the implementation of the regulatory advice previously provided by the Agency, and the resulting data package intended to support the MA application. Mature plans for post-marketing evidence generation should also be presented, as needed. Applicants are expected to start organise the submission readiness meeting approx. 15 months prior to the intended MAA submission date; the meetings should occur approx. 9-12 months prior the same date. Confirmation of eligibility to accelerated assessment should be checked 2-3 months before submission of the MA application.

Key features of PRIME scheme

At the end of 2022, the PRIME scheme supported the development and final recommendation for approval for 26 medicines. Sponsor can voluntarily file an application to access the scheme, providing evidence the eligibility criteria are met, in particular with reference to a potential major public health interest. These include conditions for which there is an unmet medical need in prevention, diagnosis or treatment, a new therapeutic method is introduced providing significant benefit over the existing ones or bringing a major therapeutic advantage to patients in a given indication.

The PRIME scheme articulates its support through different actions along the planned pathway. Depending on the type of medicinal product under development, the early appointment of a Rapporteur from the Committee for Medicinal Products for Human Use (CHMP) or the Committee for Advanced Therapies (CAT) allows for the discussion of all preparatory aspects of the ap-plication from both a technical and scientific perspective. Opinions may be also provided by other relevant EMA’s Committees and Working Parties, as needed.

Sponsors can also benefit from an initial Kick-off meeting with all the above-mentioned regulators and experts, to obtain preliminary guidance on the overall development plan. Key development steps subject to future scientific advice and the recommended regulatory strategy should be addressed during this meeting.

Special provisions are set forth to facilitate access to the PRIME scheme for SMEs and academic applicants. Upon demonstration of proof of principle, these may be granted Early Entry PRIME status, allowing for introductory meetings to raise awareness on regulatory requirements, and provide early advice on the overall development plan and relevant milestones. The requested proof of principle should be based on compelling non-clinical data in a relevant model providing early evidence of promising activity, and first-in-human studies indicating adequate exposure for the desired pharmacotherapeutic effects and tolerability.

Advice on the generation of proof of concept data is also provided at this stage by the EMA pro-duct team, and it must be fulfilled in order to confirm transition to full PRIME eligibility. In this instance, appointment of the CHMP/CAT Rapporteur is also activated.

The main steps of the procedure

Upon a first checking of acceptability of the application and related documentation, a Scientific Advice Working Party (SAWP) reviewer and a EMA scientific officer are appointed (plus a CAT reviewer in case of advanced-therapy products), and sponsors are informed of the start of the procedure and expected timelines. The SAWP committee should provide its comments to the reports by day 30, followed by final adoption by CHMP by day 40. A flowchart describing the criteria to determine eligibility is reported in Annex 1 of the guideline. The opinion of the CHMP is followed by the issuing of a letter detailing the reasons for the positive/negative decision. The outcomes of the CHMP meetings including discussions of PRIME developments are published as part of the highlights on the monthly adopted recommendations.

The confirmation of eligibility to the centralised procedure triggers the appointment of the CHMP Rapporteur, according to the specific procedure. A letter of intent to submit an MAA (approximately 6-7 months prior to submission of the MAA) is also requested.

In the case of SMEs accessing Early Entry PRIME, the appointment of the Rapporteur follows the generation of data confirming eligibility at proof of concept stage. SMEs or academic applicants also benefit from a full fee waiver for scientific advice or follow-up requests.

The Kick-off meeting is usually scheduled around 3-4 months after granting of the PRIME eligibility; submission of relevant background information and a detailed regulatory roadmap is requested to applicants in order to prepare the meeting.


The opportunity for repurposing of oncology medicines

September 10, 2021 , , , , , , , , , , , , , , , , , , , , , , , , , , , , ,

by Giuliana Miglierini

Rare cancers, which account for approx. 22% of new cases in Europe, represent an area of low business interest for the pharmaceutical industry, due to the limited number of patients compared to the very high costs to develop targeted treatments. It is thus important to consider the possibility for already existing medicines to be repurposed for a new indication. Lower costs of development and risk of failure, and a shorter time frame to reach registration are upon the main advantages of repurposing compared to de novo development, highlights the Policy Brief presented during the Joint meeting of EU Directors for Pharmaceutical Policy & Pharmaceutical Committee of 8 and 9 July 2021.
The experts addressed more specifically the possibility to achieve non-commercial repurposing of off-patent cancer medicines, which are commonly used off-label to treat patients not responsive to other more innovative types of therapies.

The issue of non-commercial development
The request of a new indication for an already marketed medicine has to be submitted by the Marketing authorisation holder (MAH). This greatly hampers the access to noncommercial repurposing by independent research institutions, as they would need to find an agreement with the MAH, the only responsible for all the interactions with regulatory authorities, at the central (EMA) or national level.
Considering the issue from the industrial point of view, this type of external request may prove difficult to be answered positively, when taking into consideration the very low return on investment that can be expected from a repurposed off-patent medicine. Even EU incentives schemes, such as those on data exclusivity and orphan designation, may not be sufficiently attractive for the industry. Current incentives schemes, for example, allow for an additional year of exclusivity in case of a new indication for a well-established substance, a 10-year market exclusivity
plus incentives in case of an authorised medicine granted with orphan designation, or the extension of the supplementary protection certificate for paediatric studies (plus 2 years market exclusivity for orphans).
The following table summarises the main issues and potential solutions involved in the setting of a specific reference framework for the repurposing of off-patent medicines for cancer, as reported in the WHO’s Policy Brief.

Table: Short overview of issues and solutions in repurposing of off-patent medicines for cancer
(Source: Repurposing of medicines – the underrated champion of sustainable innovation. Copenhagen: WHO Regional Office for Europe; 2021. Licence: CC BY-NC-SA 3.0 IGO)

Many projects active in the EU
The European Commission started looking at the repurposing of medicines with the 2015-2019 project Safe and Timely Access to Medicines for Patients (STAMP). A follow-up phase of this initiative should see the activation in 2021 of a pilot project integrated with the new European Pharmaceutical Strategy.
Several other projects were also funded in the EU, e.g. to better train the academia in Regulatory Science (CSA STARS), use in silico-based approaches to improve the efficacy and precision of drug repurposing (REPO TRIAL) or testing the repurposing of already marketed drugs (e.g. saracatinib to prevent the rare disease fibrodysplasia ossificans progressive, FOP). A specific action aimed to build a European platform for the repurposing of medicines is also included in Horizon Europe’s Work programme 2021 –2022; furthermore, both the EU’s Beating Cancer Plan and the Pharmaceutical Strategy include actions to support non-commercial development for the repurposing of medicines.

According to the WHO’s Policy Brief, a one-stop shop mechanism could be established in order for selected non-commercial actors, the so-called “Champions”, to act as the coordination point for EU institutions involved in the funding of research activities aimed to repurposing. This action may be complemented by the support to public–private partnerships involving research, registration and manufacturing and targeted to guarantee volumes for non-profitable compounds.
Among possible non-profit institutions to access funding for repurposing research in cancer are the European Organisation for Research on Cancer (EORTC) and the Breast Cancer International Group. An overview of other existing initiatives on repurposing has been offered during the debate by the WHO’s representative, Sarah Garner.

How to address repurposing
Looking for a new indication is just one of the possible points of view from which to look at the repurposing of a medicine. Other possibilities include the development of a new administration route for the same indication, the setup of a combination form instead of the use of separated medicinal products, or the realisation of a drug-medical device combination.
A change of strategy in the war on cancer may be useful, according to Lydie Meheus, Managing Director of the AntiCancer Fund (ACF), and Ciska Verbaanderd.
Keeping cancer development under control may bring more efficacy to the intervention than trying to cure it, said ACF’s representatives. The possible approaches include a hard repurposing, with a medicine being transferred to a completely new therapeutic area on the basis of considerations about the tumor biology and the immunological, metabolic and inflammatory pathways, or a soft repurposing within the oncology field, simply looking to new indications for rare cancers.
From the regulatory point of view, a possible example for EMA on how to address the inclusion of new off-label uses of marketed medicines is given by the FDA, which may request a labeling change when aware of new information beyond the safety ones.

The Champion framework
The Champion framework, proposed as a result of the STAMP project, is intended to facilitate data generation and gathering compliant to regulatory requirements for a new therapeutic use for an authorised active substance or medicine already free from of intellectual property and regulatory protection.
A Champion is typically a not-for-profit organisation, which interacts with the MAH in order to include on-label what was previously off-label, using existing regulatory tools (e.g innovation offices and scientific and/or regulatory advice). The Champion shall coordinate research activities up to full industry engagement and would be responsible for filing the initial request for scientific/regulatory advice on the basis of the available data. The pilot project to be activated to test the framework will be monitored by the Repurposing observatory group (RepOG), which will report to the Pharmaceutical Committee and will issue recommendations on how to deal with these types of procedures.

AI to optimise the chances of success
Artificial intelligence (AI) may play a central role in the identification of suitable medicines to be repurposed for a target indication, as it supports the collection and systematic analysis of very large amounts of data. The process has been used during the Covid pandemic, for example, when five supercomputers analysed more than 6 thousand molecules and identified 40 candidates for repurposing against the viral infection.
AI can be used along drug development process, making it easier to analyse the often complex and interconnected interactions which are at the basis of the observed pharmacological effect (e.g drug-target, protein-protein, drug-drug, drug-disease), explained Prof. Marinka Zitnik, Harvard Medical School.
To this instance, graphic neural networks can be used to identify a drug useful to treat a disease, as it is close to the disease in “pharmacological space”. The analysis may also take into account the possible interactions with other medicines. This is important to better evaluate the possible side effects resulting from co-prescribing; annual costs in treating side effects exceed $177 billion in the US alone, according to Prof. Zitnik.