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WHO Essential Drugs Strategy

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... FDA registration, registration with PICs member countries for procurement ... Quality Assurance and Safety: Medicines, Medicines Policy and Standards, ... – PowerPoint PPT presentation

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Title: WHO Essential Drugs Strategy


1
PREQUALIFICATION General overview and procedures
and practical implications of WHO PQ, FDA
registration, registration with PICs member
countries for procurement agencies involved in
procurement
Technical Briefing Seminar for Consultants on
Procurement and Supply Management for HIV/AIDS,
TB and Malaria Organized by WHO and AMDS
Network Copenhagen, Denmark 31 January
2006
Maija Hietava
M.Sci.Pharm Quality Assurance and Safety
Medicines, Medicines Policy and Standards,
Health Technology and Pharmaceuticals
Cluster Tel 41.22.791.3598 Fax
41.22.791.4730 World Health Organization E-mail
hietavam_at_who.int
2
Prequalification of essential medicines
  • The UN prequalification program is an action plan
    for expanding access for the hardest hit by
  • HIV/AIDS
  • Tuberculosis
  • Malaria
  • for ensuring quality, efficacy and safety of
    medicines all the way through the medicines
    supply chain.

3
Why the prequalification is needed
  • Problems
  • Millions of people living with HIV/AIDS,
    tuberculosis and malaria, have no or limited
    access to treatment
  • Procurement and supply of substandard and
    counterfeit products in different countries
  • Weak/absent QA systems of medicines supply chain
  • Lot of money invested in procurement ?no
    harmonized quality assurance system available for
    procurement organizations
  • Risks
  • Sourcing of poor quality products or even
    counterfeit medicines? risk to patients,
    treatment failure, resistance

4
Challenges of prequalification
  • Demand for affordable antiretrovirals,
    anti-malaria drugs and anti-tuberculosis drugs is
    increasing
  • Numerous generic manufacturers offering products
  • Challenges for UN family and procurement
    agencies/organizations

5
Is quality of pharmaceuticals a
problem?
Substandard drugs is a big problem - antibiotics,
antimalarials, antituberculosis antiretrovirals
drugs included
Percentage breakdown of data on 325 cases of
substandard drugs - reported from around the
world to WHO database
6
Prequalification basic principles
  • Voluntary for participating manufacturers
  • Legitimate - General procedure and standards
    approved through WHO Expert Committee system
    involving all WHO Member States and WHO Governing
    bodies
  • Widely discussed
  • FIP Congress, Nice 2002
  • Supported by ICDRA in 2002 and 2004, representing
    more than 100 national drug regulatory
    authorities
  • Transparent (all significant information
    available on the web site http//mednet3.who.int/p
    requal/ )
  • Open to both innovators and multisource/generic
    manufacturers
  • No cost for applicants during pilot phase

7
Expected outcome of prequalification
  • List of products and manufacturers/CROs
  • Meeting international norms and standards on
    quality, safety, and efficacy (Q, S E)
  • Harmonization
  • Co-operation, training, capacity building
    NDRAs, WHO, NGOs
  • Facilitate access to treatment
  • Procurement mechanisms (e.g. tender, competition)
  • Ongoing monitoring of Quality, Safety Efficacy
  • WHO commitment to developing

8
Objectives
  • Propose a list of prequalified manufacturers and
    products of which the quality, efficacy and
    safety have been assessed, inspected and
    controlled to meet international norms and
    standards.
  • Gives assurance that international norms and
    standards are applied at all the steps of the
    prequalification and at the process itself.
  • Make possible and speed up access to good quality
    of medicines. Fast track process for listing can
    take as little as two months from the date of
    application.

9
Objectives cont
  • Follow-up and regular monitoring of the quality
    of manufacturers and products
  • Ensure re-qualification and update of the list of
    prequalified products and manufacturers as new
    products and manufacturers meet the standards
  • Ensure the appropriate control of variations and
    changes
  • Develop the local capacity for quality production
    and clinical studies.
  • National regulatory authorities (DRA) are
    involved in dossier assessment and inspections
  • Producers receive invaluable specific technical
    feedback
  • Help the national DRA to build up capacity in
    assessment, inspection and control meeting
    international norms and standards

10
How prequalification is organized
  • Role of WHO Managing and organizing the project
    on behalf of the United Nations.
  • provide technical and scientific support and
  • guarantee that international norms and standards
    are applied all through the process including
    assessment, inspection (GMP, GCP/GLP) and quality
    control
  • Partners
  • UNICEF, UN Population Fund (UNFPA), UNAIDS and
    with the support of the World Bank
  • Anti-malarial and anti-TB products Roll Back
    Malaria and Stop TB (Global Drug Facility)
  • US FDA tentative approvals recognition based on
    information exchange (Confidentiality agreement)
  • Actors Mainly assessors and inspectors of
    National DRAs as well as National Quality Control
    Laboratories of PIC/S and ICH member countries

11
Steps of prequalification
  • 1. Expression of interest (EOI) from a
    prospective supplier interested in a voluntary
    participation in the program.
  • 2. Receipt of the dossier at UNICEF in
    Copenhagen and the Site Master File in WHO
    Geneva.
  • Explicative notes and guidelines are published on
    the WEB in order to explain how to bring together
    a product dossier meeting the requirements for
    prequalification.
  • 3. Screening of the dossier, "Quality" part,
    "Clinical" part and samples. ? possible
    inspection
  • 4. Assessment of the dossier and writing of the
    assessment report and assessment letter.
  • 5. Outcome of the evaluation communicated to
    supplier

12
Steps of prequalification cont
  • 6.Inspection of the site (s) of manufacturing
    and follow-up inspection when necessary ? GMP
    compliant list of manufacturers
  • 7.Inspection of the Research Laboratory or
    Contract Research Laboratory (CRO) where the
    bioequivalence study has been performed ? GCP
    compliant list of CROs
  • 8.Conclusion and listing of the product in the
    prequalification list
  • 9.Publication of the Public Assessment (WHOPAR)
    and Inspection (WHOPIR) Reports
  • 10.Assessment of the variation when submitted,
    market survey, de-listing if necessary
  • 11.Re-qualification after 3 years

13
Assessment procedure
  • Assessment of products dossiers i.e. quality,
    specifications, pharmaceutical development,
    bioequivalence etc.
  • teams of professionals from national drug
    regulatory authorities (DRA) Brazil, Canada,
    Denmark, Estonia, Finland, France, Germany,
    Hungary, Indonesia, Malaysia, Philippines, Spain,
    South-Africa, Sweden, Switzerland, Tanzania,
    Zimbabwe ...
  • Copenhagen assessment week
  • 8 to 12 assessors together during one week at
    least every two months at UNICEF in Copenhagen
  • Every dossier is assessed by at least two
    assessors.
  • An assessment report is issued signed by two
    assessors
  • Letter summarizing the findings and asking for
    clarification and additional data if necessary.
  • Letter is sent first by e-mail to the applicant
    followed by surface mail

14
Assessment procedure-Product dossiers
  • Innovator products
  • Assessment report from DRAs
  • WHO Certificate of Pharmaceutical Product (CPP)
  • Batch certificate
  • Update on changes.
  • Multisource products (generics)
  • Full dossier with data and information
  • Quality information on starting materials and
    finished product including API details,
    specifications, stability data, formulation,
    manufacturing method, packaging, labelling etc
  • Efficacy Bio-equivalence study or clinical study
    report
  • US FDA tentative approvals recognition based on
    information exchange (Confidentiality agreement)
  • Commercial sample

15
Inspection procedure
  • Inspections
  • Manufacturing site (FPP, packaging)
  • Active pharmaceutical ingredient (API)
  • Research laboratory/Contract Research
    Organization (CRO)
  • Teamwork of inspectors
  • WHO representative (qualified GMP inspector)
  • Inspector from well-established inspectorate
    (Pharmaceutical Inspection Convention Scheme
    PIC/S countries)
  • National inspector(s) Canada, India, China,
    France, Italy, Switzerland, South-Africa,
    Thailand
  • Quality control analysis - upon need but not
    always necessarily before
  • prequalification and supply increasingly as part
    of follow-up

16
Prequalification of quality control laboratories
  • To increase the local capacity to control the
    quality of pharmaceutical products
  • Quality Control Laboratories in sub Saharan
    Africa as priority
  • WHO norms and standards for QC laboratories
  • Prequalification process
  • Expression of Interest (EOI)
  • Laboratory Information File (LIF), evaluation
  • Inventory Audit help/evaluate
  • Inspection with the team of inspectors
  • Prequalified laboratories list public in WHO web
    site (2 listed)
  • Reassessment system

17
Training activities
  • In 2005 three comprehensive 5-day training
    courses on quality, GMP and BE for TB drugs and
    ARVs (Malaysia, China, Ukraine)
  • Course on quality, GMP and BE planned for Jan-06
    (China)
  • Two GMP training courses for NDRA inspectors
    (South-Africa, China)
  • Recent GMP training course in Tanzania (with PQ
    participation)
  • Training of QC lab officials
  • Training of PQ staff and inspectors working for
    WHO in BE study inspections (January-February
    -06)

18
Current status December 2005
  • Started with HIV/AIDS products in 2001 malaria
    and TB products joined later
  • Prequalified products (Dec 2005) Dossiers arrived
  • 105 HIV related medicines - 316 (Aug-05) 343
    (Dec -05)
  • 8 anti-tuberculosis medicines - 156 165
  • 2 anti-malarial medicines - 48 49
  • 115 520 557
  • Ongoing assessments and follow-up
  • Products
  • Manufacturing sites
  • CROs

19
Current status Manufacturers of finished
products
  • In the prequalification list 15 sites of
    generics
  • Asia 9 sites
  • Europe 4 sites
  • Africa 2 sites

20
Ongoing monitoring and requalification
  • Samples taken after supply
  • Routine inspections and additional inspections
  • Changes and variations controlled
  • Products and manufacturers
  • Requalification (re-assessment) every 3 years
  • World Health Assembly resolution WHA57.14 of May
    2004
  • Public reports requested
  • WHOPIRs (WHO Public inspection report) and
    WHOPARs (WHO Public Assessment Report) are now on
    the prequalification web site
  • Increasing interest in WHO Public Inspection
    Reports (WHOPIR)

21
PQ web site information for procurement
  • List of prequalified products
  • List of manufacturers of manufacturers for APIs
    (Active Pharmaceutical Ingredient) and FFPs
    (Finished Pharmaceutical Product), which are GMP
    compliant
  • List of GCP compliant Contract Research
    Organisations (CROs), bio-equivalence centers and
    research laboratories, which are GCP/GLP
    compliant
  • WHOPIRs (WHO Public Inspection Report)
  • WHOPARs (WHO Public Assessment Report)

22
Global Fund Quality assurance policy related to
procurementPractical implications of FDA
registration, registration with PICs member
countries for procurement
  • Grant funds to procure products meeting following
    standards
  • (A) such product is acceptable under the WHO
    Prequalification Program or
  • (B) such product has been authorized for use by a
    stringent regulatory authority, FDA tentative
    approvals
  • 2 manufacturers ? option A or B applies AND the
    product is available (conditions defined)
  • (C) If the Principal Recipient determines that
    there is only one or no (pharmaceutical product that meets the standards
    of either (A) or (B) or if the Principal
    Recipient determines that the products that meet
    these standards are unavailable (Defined as
    inability of the manufacturer to supply a
    sufficient quantity of finished product within 90
    days from date of order), then Grant funds may be
    used to procure another equivalent pharmaceutical
    product, provided that such product is selected
    in accordance with the following, in order of
    priority
  • Application submitted to the WHO Prequalification
    Program or to a stringent regulatory authority
    and product manufactured at a GMP compliant site
    or
  • Product manufactured at the GMP compliant site
    (WHO or ICH or PIC/S)
  • (Random quality analysis of products being
    procured according to these criteria)
  • (C) UNTIL 30 APRIL 2005 approval by the NDRA of
    the recipient country.
  • ICH or PIC/S countries see next slide

23
New Policy, Global Fund
(i) In pipeline of Option (a) or (b)
Manufactured in a facility compliant with GMP
following inspection by WHO or stringent
regulatory authority IF NOT, THEN (ii)
Manufactured in a GMP-compliant manufacturing
facility
24
Global Fund Quality assurance policy related to
procurementPractical implications of FDA
registration, registration with PICs member
countries for procurement
  • Access to a list of countries that belong to ICH
    or PIC/S
  • http//www.theglobalfund.org/pdf/guidelines/List_o
    f_Countries_ICH_PICS.pdf

25
Countries with "stringent" regulatory authorities
  • PIC/S Pharmaceutical Inspection Convention and
    Pharmaceutical Inspection Cooperation Scheme
    participating regulatory authorities
    (www.picscheme.org)
  • Australia
  • Austria
  • Belgium
  • Canada
  • Czech Republic
  • Denmark
  • Finland
  • France
  • Germany
  • Greece
  • Hungary
  • Iceland
  • Ireland
  • Italy
  • Latvia
  • Liechtenstein
  • Malaysia
  • Netherlands
  • Poland
  • Portugal
  • Romania
  • Singapore
  • Slovak Republic
  • Spain
  • Sweden
  • Switzerland
  • United Kingdom
  • ICH International Conference on Harmonisation
    of Technical Requirements for Registration of
    Pharmaceuticals for Human Use participating
    regulatory authorities (www.ich.org )
  • European Union
  • Japan
  • United States
  • Members include Austria, Belgium, Cyprus,
    Czech Republic, Denmark, Estonia, Finland,
    France, Germany, Greece, Hungary, Ireland, Italy,
    Latvia, Lithuania, Luxembourg, Malta, Poland,
    Slovakia, Slovenia, Spain, Sweden, The
    Netherlands, United Kingdom

26
Important about Quality of Pharmaceutical Products
  • Building in the quality
  • Starts during development phase ? documented
    evidence during the product life cycle that
    product used in bioequivalence studies (sometimes
    pilot batches) is the same as the marketed
    product (big production batches)
  • Reliable regulatory system and control for
    stability studies and product variations during
    the life cycle of a product (if changes are not
    controlled systematically, there could be a
    significant change during the product life
    cycle) capacity problems at the regulatory side

27
Important in the regulatory assessment of GENERIC
pharmaceuticals
  • There are requirements especially for
  • Generics (requirements have not been harmonised
    yet)
  • Bioequivalence studies (not always a requirement
    as such)
  • Bioequivalence (guidance not harmonised yet)
  • Variations changes in the product that may have
    effect on quality (not always strictly followed
    or controlled)
  • Stability studies (not always strictly followed
    or controlled)
  • Requirements are controlled by the authorities
    (capacity problems!)
  • And..

28
Important in the PQ process related to Quality
and Efficacy
  • Dossier evaluation and Inspections (GMP
    manufacturing and GCP for bioequivalence studies)
  • Go hand in hand in the PQ process
  • Sometimes "GMP compliance" alone does not tell
    the whole truth!!

Dossier assessment
Inspections GMP/GCP
29
This is misleading and/or misunderstood
  • WHO type certificate (by WHO Certification
    Scheme) is used worldwide
  • ? But it is not WHO certificate
  • GMP compliance??
  • National GMP requirements are not always those of
    WHO or stringent authority requirements
  • Does not tell everything about the product

30
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!This is
correct!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
  • WHO Prequalification does not give GMP/GCP
    certificates, but the GMP/GCP compliant companies
    are listed in our web site

WHO GMP/GCP CERTIFICATE
31
Recent news and new challenges
  • 2005 changes in GFTAM procurement policy
    challenges for prequalification
  • Confidentiality Agreement with the US FDA
  • Recognition of US FDA tentative approval process
    for ARVs based on the scientific assessment done
    by FDA
  • Additional fields of cooperation with European
    Directorate of the Quality Medicines (responsible
    for European Pharmacopoeia)
  • Jointly funded post established with UNICEF to
    help managing the assessment weeks in Copenhagen
    from Sept 2005
  • Constant upgrading guidelines and guidance
    documents increasing workload
  • Building of the Quality system
  • Resources for 2006/2007

32
Summary and conclusion
  • Good news quality of generics exists
  • Relatively large number of products and suppliers
    comply with the standards
  • Many potential suppliers appreciating feedback
    and willing to improve
  • Unique technical knowledge obtained of products,
    especially generic antiretrovirals and
    antimalarials
  • Bad news quality assurance has the price
  • Only limited number of products have met the
    required standards
  • Takes time to get into compliance
  • Data to be generated, tests carried out
  • GMP upgrade needed
  • Bad quality generics may undermine the public
    confidence in generics

33
Summary and conclusion CONT
  • However REMEMBER
  • Quality
  • can not be assessed, tested or inspected into
    the product, BUT
  • has to be built
  • into the product
  • in all the steps
  • development phase, production, QC, BE study
    etc.
  • with the help of guidelines, regulatory
    requirements etc.!!
  • More technical help to manufacturers in
    developing countries is needed!!

34
Summary and conclusion CONT
  • No more poor quality medicines for poor people!
  • Equitable access to good quality,
  • safe and effective medicines for all!

35
http//mednet3.who.int/prequal/
36
  • THANK YOU VERY MUCH FOR
  • YOUR ATTENTION!!
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