INDIAN REGULATORY REQUIREMENTS
INDUSTRIAL PHARMACY ll
B.PHARMA SEMESTER 7
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Central Drug Standard Control Organization (CDSCO) and State Licensing Authority: Organization, Responsibilities, Certificate of Pharmaceutical Product (COPP), Regulatory requirements and approval procedures for New Drugs. |
INTRODUCTION
The Central Drug Standard Control
Organization (CDSCO) regulates drugs, cosmetics, diagnostics and devices in India.
It is headed by the Drug Controller General of India (DCGI), responsible for
safety, efficiency and quality standards for pharmaceuticals and medical device
and publisher of the Indian Pharmacopoeia. The DCGI is advised by the Drug Technical
Advisory Board (DTAB) and the Drug Consultative Commission (DCC).
State Government is responsible
for licensing, approvals, inspection and recalls of drugs manufactured within
their domain.The CDSCO works with the World Health Organization to promote Good
Manufacturing Practice (GMP) and international regulatory harmony.
CENTRAL DRUG STANDARD CONTROL ORGANIZATION (CDSCO)
The CDSCO is the main regulatory body for regulation of pharmaceuticals, medical devices and clinical trials. The head office of CDSCO is located in New Delhi and it is functioning under the Control of Directorate General of Health Services, Ministry of Health and Family Welfare, Government of India.
Drug Controller
General of India (DCGI): is responsible for approval of new drugs, medical
devices and clinical Trials to be conducted in India. The person who is appointed
by the Central Government under the DCGI the state drug control organization will
be functioning.
Zonal Office: Mumbai, Kolkata,
Chennai, Ghaziabad, Ahmadabad, Hyderabad
Sub-zonal Office: Chandigarh, Jammu, Bangalore.
Central Drugs
Testing Laboratories:
·
Kolkata.
·
Mumbai
·
Chennai
·
Kasauli
·
Guwahati
·
Chandigarh.
These laboratories are responsible for quality
control of Drugs and Cosmetics in India.
Functions
of CDSCO:
·
Approval of new drugs and clinical trials.
·
Import Registration and Licensing.
·
Amendment to D and C Act and Rules.
·
Banning of drugs and cosmetics.
·
Grant to Test license, Personal License, NOC’S
for export.
·
Testing of drugs by Central Labs.
·
Publication of Indian Pharmacopoeia.
·
Monitoring adverse drug reactions.
·
Guidance on technical matter.
STATE
DRUGS CONTROL ORGANIZATION
Functions of State Licensing Authorities:
1. Licensing of drug testing laboratories.
2. Approval of drug formulation
for manufacture.
3. Monitoring of quality of Drugs and Cosmetics, manufactured by respective state and those marketed in the state.
4. Investigation and prosecution
in respect of contravention of legal provision.
5. Administrative actions.
6. Pre and post licensing
inspection.
7. Recall of substandard drugs.
APPROVAL
OF NEW DRUG
1. The drug approval process
varies from one country to another.
2. In some countries, only a
single body regulates the drugs
3. New drug will not be imported,
except under permission granted by the Licensing Authority,
4. The licensing authority, after
being satisfied that the drug if permitted to be imported as raw material or a
finished permutation will be effective and safe for use in the country may
issue import permission.
5. For new drug discovered in
other countries, phase-I trials are not usually allowed to be initiated in
India.
Approval for
Clinical Trials:
1. Approval for clinical trials
and application to conduct clinical trials in India should be submitted along
with the date of chemistry, manufacturing, control and animal studies to DCGI.
2. The data regarding the trail
protocol investigators brochures and informed consent documents should also be
attached.
3. A copy of the application must
be submitted to the ethical committee and the clinical
trials are conducted only the
after approval of DCGI and ethical committee.
Schedule Y
Rule 122A – Permission to import
new drug.
Rule 112B – Permission to
manufacture new drug.
Rule 122DA – Definition of
clinical trials.
Rule 122E – Definition of new
Drugs.
Import,
Registration and Licensing:
Manufacturing sites and products
are required to be registered. Issue of import license in form 10/10 A.
Rules 21 to 30: Rules related to
grant of registration certificate and import license.
Schedule DI and
DII: Information
required for registration of manufacturing site and
product.
Time line for
RC: As
per D and C rules, 9 months; however in practice, 2 months.
For import license 2-3 weeks.
As per Rules 21A (5), there is
provision to import manufacturing site for which
manufacture has to pay 5000 USD.
CERTIFICATE
OF PHARMACEUTICAL PRODUCT (COPP)
a certificate issued in the
format recommended by the WHO, which establishes the status of the pharmaceutical
product and of the applicant for this certificate in the exporting country. It
is issued for a single product, because manufacturing arrangements and approved
information for different pharmaceutical forms and strengths can vary.
Scope:
The Certificate of a
Pharmaceutical Product is needed by the importing country when the product in
question is intended for registration (licensing, authorization) or renewal (prolongation)
of registration, with the scope of commercialization or distribution in that country.
Certification has been
recommended by WHO to help undersized drug regulatory authorities or drug
regulatory authorities without proper quality assurance facilities in importing
countries to assess the quality of pharmaceutical products as prerequisite of registration
or importation. In the presence of such COPP, WHO recommends the national authorities
to ensure that analytical methods can be confirmed by the national laboratory,
to review and if necessary to adapt the product information as per local
labeling requirements, and to assess bioequivalence and stability data if
necessary.
WHO: The application
for grant of WHO GMP Certificate of Pharmaceutical Product should be made to
respective zonal/sub-zonal officers as per the requirement. The COPP should be
issued by zonal/sub-zonal officers on behalf of Drugs Controller General
(India) after inspection and satisfactory clearance by CDSCO officers as per
WHO-GMP guidelines.
General
Requirements for Submission of Application for Issue of COPP:
1. Application should clearly
indicate for fresh certification (Grant) or reissue of products applied,
accordingly it will be scrutinized for the products applied.
2. Applications should be
reviewed by CDSCO officers and completed applications in all respects should be
accepted for inspection on first come first serve basis.
3. The forwarding
letter/application shall be accompanied with list of products applied for grant
of COPP, along with a product permission copy (manufacturing license issued by
the SLA) and notarized product summary sheet, site master file as per WHO-GMP
requirement.
List of major/master documents
like master validation plan, quality manuals, specifications, master formula
records maintained by firm and list of SOPs (to indicate the documentation
system of firm).
Manufacturing
Layout:
1. List of personnel (with
designation, qualification and experience), List of equipments, instruments,
utilities along with make and model and capacity.
2. List of primary and secondary
impurity and reference standards/cultures available with the firm (relevant to
the applied products for grant of COPP).
Procedure for
Accepting the Application for Issue of COPP:
The certificate of pharmaceutical
product has been issued under WHO-GMP based on guidelines laid down by health
agency and also aimed at diminishing the risk inherent in pharmaceutical
productions. The certificate helps the regulator to ensure that drugs are consistently
produced and are quality controlled before they leave the country.
Documents
Required for Applying for Grating or Revalidation of COPPs:
1. Application from manufacturer.
2. Site master file (as specified
under WHO TRS 823).
3. Cost of manufacturing license.
4. List of approval products.
5. List of products applied for issuance
of COPPs.
6. List of SOPs and STPs.
7. Stability data (3 batches)
accelerated/Real time.
8. List of equipments and
instruments.
9. List of technical staff, their
qualification, and experience and approval status.
10. Manufacturing layout plan.
11. Process validation for 3
batches of each product.
12. Schematic diagram of water
system specifying circulation loop and MOC
13. Schematic diagram of HVAC
system specifying terminal filter configuration.
14. Export data of last 2 years
in case of revalidation.
15. Product money sheet.
Legal Documents:
1. Documents to be submitted by
Indian agent.
2. Form 40: It should be
signed and stamped by Indian agent.
3. Documents to be submitted by
manufacturer.
4. POA: Power of attorney
should be consulate from Indian embassy of the other country of origin, and
should be co-jointly signed by both the parties
i.e. manufacturer and Indian
agent.
Regulatory
Documents:
1. Notarized plant registration
certificate.
2. Notarized manufacturing and
marketing license
3. Notarized free sale
certificate
4. GMP/COPP certificate
notarized.
Technical
Documents:
(A) Plant master
file:
• Sketch of the plant.
• Profile of the company.
• Organogram of the company.
• Plant and machinery.
• Hygienic and sanitary measure
details.
• IQPQDQOQ.
• HAVAC system.
• Men material movement.
(B) Drug master file:
• Manufacturing process/flow
chart.
• Quality assurance
procedures/process controls.
• The provision to control
contamination and cross contamination in the final product.
• Process control, control of
critical steps and intermediates.
• Container closure system.
• Risk Assessment as per ISO
14971.
• Process
validation/verification.
• Stability data.
• Biocompatibility and
toxicological data.
• Clinical studies and reports.
(C) Labels and
Inserts:
Product labels should show the
address of manufacturer. Product inserts should describe
the brief description of the
product and its intended use.
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