FWQRC™ intended to provide a decision pathway for drug & medical devices manufacturers in their first steps towards implementation of eCTD publishing and submission

Hi, Welcome to FWQRC™ Regulatory Focus News Letter

About Blog: FWQRC™ Regulatory focus pharma news, views and analysis of healthcare in a rapidly changing world. Not only do we keep you connected with the latest trends in pharma, we can also help you develop and bring to life your own thoughts, ideas and inspirations to enable you and your business to become key pharma influences

Many of us aware that eCTD is mandatory for DMF submissions from Jan 2020.

• At the beginning of the decision process it is very important to make an evaluation of the current submission processes (“where are we”) in comparison with the eCTD requirements (“where do we need to be”).
• The conclusions drawn from this analysis, together with a careful evaluation of the boundary conditions within the company are the basis for the definition of the User Requirements Specifications (URS). 
• In the URS all the needs and boundaries of the expected processes are described and this information is used to find the optimal solution.Three possible solutions are described in detail, with their related advantages and disadvantages

1. In-house software,
2. Software as a Service (SaaS) and
3. Outsourcing  

• The last step of the process is the implementation of the chosen solution.
• It has to be considered whether a consultant should help with the creation of this URS document. Especially for the generation of the new processes the experience of a consultant can be helpfulThe URS is part of the official validation documentation according to GAMP and should be established for any new system

• Selection of solution

• Once the URS has been finalised, the most suitable solution has to be found.  For this analysis the URS requirements should be classified in some way, e.g. “crucial” and “nice to have”.

• The three possible solutions (In-house Software, Software as a Service and Outsourcing) are described in detail in the following sections.  Table 1 compares the most relevant characteristics of the 3 solutions, Table 2: Running an eCTD software system in-house: advantages and disadvantages and Table 3: Host system option: advantages and disadvantages

Table 1: Comparison of the 3 solutions

Item	In-House software	Software as a Service	Outsourcing
Freedom of configuration	High	limited	No
Responsibility for update and Maintenance	High	No	No
IT support in-house needed	Yes	No	No
Link to other IT systems in-house possible	Yes	No	No
Initial costs	High	Low	No
Ongoing costs	In-house	Yes	Yes
Lead time	Long	Medium	Short
Scalability	Depends on set-up	Easy	Easy
Need of resources and competence for use of eCTD software	Yes	Yes	No
confidentiality / data security issues	No	Yes	Yes

Table 2: Running an eCTD software system in-house: advantages and disadvantages

Advantages	Disadvantages
Full freedom for configuration	High initial costs for setting up the system
Free choice of hardware and software components	Relatively long lead time needed to set up the system
The software is part of the company-owned software and fits into the IT concept of the company	Full responsibility for update and maintenance
Everything stays in house (no data-transfer via internet / confidentiality etc.)	Personnel for technical set-up and maintenance must be available.
Link-up to other IT-systems possible (e.g. SAP)
Maintenance costs stay in-house
On-going costs are lower compared to the host software or outsourcing options

Table 3: Host system option: advantages and disadvantages

Advantages	Disadvantages
Speed: time from the decision to a pilot eCTD is often shorter compared to the in-house software solution	Dependency on an external partner which increases if also the DMS shall be hosted
Lower cost for initial implementation as there is no or a smaller initial investment (e.g. initial set-up, user and software licenses, maintenance)	Data transfer via internet (confidentiality, upload / down load capacity)
Scalable: ability to scale as business needs change	Data hosted at an external company (confidentiality)
No on-going system maintenance	Limited freedom for software configuration
	On-going costs for renting the system/service

Table 4: Outsourcing option: advantages and disadvantages

Advantages	Disadvantages
Speed: time from the decision to a pilot eCTD is very short	Dependency on an external partner for each project and throughout the life cycle of a submission
No initial investment and no reoccurring costs for system maintenance and technical support	On-going costs for each service during the whole lifecycle of a product/submission (initial submission(s), variations etc.)
No direct costs for software, licenses, hardware, system validation and maintenance, training	Data transfer (confidentiality, upload / down load capacity)
No need to establish, maintain technical knowledge in building and publishing eCTDs, no need for respective in-house resources (eCTD builder/publisher)	Data hosted at an external company (confidentiality)
Scalable: ability to scale as business needs change
Can also substantially-reduce risk of failed initial submissions

• There are 4 main scenarios that can drive the decision for outsourcing

1. there is no in-house software available to build / publish eCTDs or
2. the in-house capacities are too little
3. to gain experience for the creation of eCTD ready documents and eCTD submissions in-house
4. the number of eCTD submissions is too small, seldom use of the system

• Conclusion: The option with the lowest impact on processes and systems in a company is outsourcing. There are various different extents of outsourcing. Common to all is that the external partner will provide the necessary infrastructure / software as well as the personnel to prepare the eCTD.

Stay in connected with FWQRC™ for implementation of eCTD publishing & submission

New year greetings

We wish that all your wishes are fulfilled this year.

Stay connected with FWQRC…

Merry Christmas to all

First FDA-approved vaccine for the prevention of Ebola virus disease

Hi, Welcome to FWQRC Regulatory focus news letter……….

The U.S. Food and Drug Administration announced today the approval of Ervebo, the first FDA-approved vaccine for the prevention of Ebola virus disease (EVD), caused by Zaire ebolavirus in individuals 18 years of age and older.

Cases of EVD are very rare in the U.S., and those that have occurred have been the result of infections acquired by individuals in other countries who then traveled to the U.S., or health care workers who became ill after treating patients with EVD.

“While the risk of Ebola virus disease in the U.S. remains low, the U.S. government remains deeply committed to fighting devastating Ebola outbreaks in Africa, including the current outbreak in the Democratic Republic of the Congo,” said Anna Abram, FDA Deputy Commissioner for Policy, Legislation, and International Affairs.

“Today’s approval is an important step in our continuing efforts to fight Ebola in close coordination with our partners across the U.S. Department of Health and Human Services, as well as our international partners, such as the World Health Organization.

These efforts, including today’s landmark approval, reflect the FDA’s unwavering dedication to leveraging our expertise to facilitate the development and availability of safe and effective medical products to address urgent public health needs and fight infectious diseases, as part of our vital public health mission.”

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Investigation of Listeria monocytogenes

Welcome to FWQRC Regulatory focus news LetterHere we are going to review on the Outbreak Investigation of Listeria monocytogenes Linked to Hard-Boiled Eggs, December 2019FDA, CDC, and state and local partners are currently investigating a multistate outbreak of Listeria monocytogenes infections linked to foods that contain hard-boiled eggs. On December 20, 2019, Almark Foods recalled and suspended production of hard-boiled and peeled eggs in pails due to the potential for contamination with Listeria monocytogenes. These hard-boiledand peeled eggs were sold in pails under the following names: Rainbow Select Hard-cooked Eggs, Rainbow Select Hard-cooked Eggs in Vinegar, Nic’s Salad Hard-boiled Eggs, Almark Hard-cooked Eggs, and Sutherland Select Hard-cooked Eggs. A full list of recalled products is included below.RecommendationFood processors, restaurants, and retailers should not sell or serve any of the recalled hard-boiled and peeled eggs in pails from Almark Foods. These products were not sold directly to consumers.Additionally, FDA recommends that food processors, restaurants and retailers who have received Almark Foods bulk, fresh hard-boiled eggs, use extra vigilance in cleaning and sanitizing any surfaces that may have come in contact with these products, to reduce the risk of cross-contamination.Background:As of December 17, 2019, a total of seven people infected with the outbreak strain of Listeria monocytogenes have been reported from five states. In interviews, ill people answered questions about the foods they ate and other exposures in the month before they became ill. Of the five people for whom information was available, four reported eating products containing eggs. Three of these people reported eating hard-boiled eggs in deli salads purchased from grocery stores and in salads eaten at restaurants. Illnesses started on dates ranging from April 10, 2017 to November 12, 2019.Additionally, based on whole-genome sequencing, the Listeria monocytogenes found in environmental samples collected at the firm’s processing facility during an FDA inspection conducted in February 2019 is a genetic match to the outbreak strain. FDA is conducting additional inspections and sampling. Almark Foods has been cooperating with the ongoing investigation and announced a voluntary recall of hard-boiled and peeled eggs in pails on December 20, 2019.This outbreak strain was found during environmental sampling in 2017 of one other food facility. That facility is not currently handling food and ceased operation in 2018.Thank you for viewing FWQRC blogs….