Comments Offered on e-Submissions of Manufacturing Info

Share

Genentech says it supports FDA’s consolidation and move to electronically coded manufacturing establishments information. Late last year, the agency published a draft guidance, Providing Regulatory Submissions in Electronic Format—Submission of Manufacturing Establishment Information, discussing the requirements and implementation of the Federal Food, Drug, and Cosmetic Act on valid electronic submissions of manufacturing establishment information (MEI). The document says that 24 months after the draft has been finalized, MEI in NDAs, ANDAs, BLAs, and amendments, supplements, or resubmissions of these application types must be submitted electronically in the format specified in the guidance.

 

In just-posted comments on the guidance, Genentech recommends alignment and use of an international common standard in the electronic transmission of registration information. “For example, the use of ISO IDMP Health Informatics standard (e.g. ISO 11615) for Manufacturing Establishment Information was not discussed in the draft guidance,” it says. “While this may be implied by the development of the standard in conjunction with the Common Product Model in HL7 (e.g. use of HL7 V3 messaging to transmit information), additional elaboration and clarity would be helpful.”

 

In separate comments to the agency, the Active Pharmaceutical Ingredients Committee (APIC) says that the “MEI is an additional submission of information which is already available to FDA by different means. Establishment information for drug substance manufacturers is submitted via CTD section 3.2.S.2.1 (per application or [Drug Master File]. Establishment information is also contained in the ‘administrative page’ being part of the Annual Report on the Master File... On a higher level, MEI information is also submitted to FDA via the electronic site registrations (not per application but per site).”

APIC also recommends that FDA reassess existing guidances to clearly define the information they want to see in CTD section 3.2.S.2.1. This could eliminate the “administrative page” of the Annual Report pertaining to a Master File to avoid excessive documents, the group says.

Read more