Five Steps for Complying with New eCTD
requirement for DMF Submissions
08th Feb 2016
I Sumit
Gupta
U.S Drug Master files are filled by various companies involved in
the business of Bulk Drug, Excipients, Primary packaging Material
and other products/services dealing with pharmaceutical products. US
DMF is divided into 5 categories
Type1 - Plant Master file - NO longer Used
Type 2 - API - Bulk Drug
Type 3 - Primary Packaging Material
Type 4 - Excipients
Type 5 - FDA Accepted Reference Information.
U.S FDA will no longer accept paper submission after 5th May
2017 for DMF submission, all DMFs, amendments, annual updates will
have to be filled electronically as specified by the FDA in eCTD
guidance.
Its official anyone planning to do a DMF submission to USFDA after
5th May 2017 will have to add eCTD to their plans, all companies who
have their annual budget fixed at the start of the year consider
adding eCTD to their budget from now itself as implementing any new
system or software requires time.
“Start Early Finish Early”
The big question or matter of confusion for most people
is what happens of old Submission which are made in paper format
??,Good news is you don’t have to resubmit entire DMF in eCTD
format, but all your further subsequent amendments, LOA, or annual
reports will be required in eCTD only.
Now that you know eCTD will soon be compulsory, let’s look at the
some steps that will help you comply with this new requirement.
1) Buying an eCTD Software
There are many vendors available in the market with eCTD
software and each one of them have so many features it becomes
really difficult to choose one. So you need to remember the basic
objective while selecting one
a) Easy to
USE
b) Can Make Validated and good
submission to the Agency you are targeting
c) It should be 21CFR Part 11
compliant
d) Should be Cost Efficient
e) Link Validation and PDF Validation
should be an integral feature of the software
Some eCTD Software do come with Document management systems
which are very handy when it comes to large amount of data to be
processed or there are many users in a company working on same
products.Many companies
are today adopting eBMR, and going digital with all their
records right from production, QC, QA, Regulatory to final
dispatch and further track and trace.
"Digitalization of documentation is a BIG Plus for Smooth
eCTD transition"
2) Trained & skilled Manpower
With Specialized software new regulation training becomes an
integral part of the whole transition process. Training is the
KEY for implementing the new system and making successful
submission. Companies can train their existing RA team in eCTD
by hiring external Professionals who have good experience in the
field or they can approach training institute to provide the
same
** GIRA provides Practical
training in eCTD - Click
eCTD Training for Details
3) Now that you have the tools (software)
trained manpower for eCTD you should look forward to validating
your system by making a dummy submission to US FDA and getting
the technicalities of eCTD Approved from them.
4) The First Step in eCTD Dummy Submission
is opening an ESG Gateway Account with US FDA to transmit your
eCTD Submission.
5) Next you Create a Sample eCTD submission
validate the same and submit it to U.S FDA for reviewing.
Please note US FDA won’t review technical information and
sample submissions are not considered official submissions
The Support team will check your submission for various test
including, DTD Validation, Verification of file checksums,
verification of the presence of modified files and
identification of missing files.
Once the entire test is complete a report will all the errors
will be sent to you. Once all the errors are corrected you can
re-submit the corrected sample submission to the team for
further review.
After Successful completion of above steps the submission should
be technically ready for official submission.
Wola you have Successfully Completed your first eCTD
Submission and now you are in time to comply with the new
regulation come 5th May 2017.
About the Company Perfect Pharmaceutical Consultants Pvt Ltd
PPC has more than 30 years of Regulatory experience in
Pharmaceutical field we can help you :
a) Convert existing Paper Submission to eCTD
b) File Annual reprort/ Amendment in eCTD format with US FDA
, Health Canada , EU nations, and other eCTD Accepting
countries.
c) We write , compile and submit Drug Master file for US FDA
and other countries