PedroMendez
Acolyte
brilliant post. Thanks for taking the time.For the last 30 minutes, I have been typing a long post to address your general question - then Redcafe crashed before I could hit the post button, and only few paragraphs were saved. I'll do a short version below. Don't hesitate to ask if something isn't clear: Drug registration is more complex than even health care professionals, let alone patients assume.
- All countries have an independent agency that is legally responsible for drug registration and maintenance in that country; I mention maintenance because it is a publicly totally underestimated issue that requires a lot of staff both at agencies and companies.
- Generally, what reviewers do when assessing an application is to draw conclusions about the benefit / risk balance of that drug (or combination of drugs). The three main review areas are efficacy, safety and pharmaceutical quality of the formulation.
- Agencies have requirements for registration and do the assessment according to local guidelines that are designed for the specific population of their country in context of the medical landscape, climate and standard of living; in some countries also health care landscape.
- Most agencies do an independent full assessment, including Chile's. It's not uncommon though that an agency wants to see Q&As and / or assessment reports from registration procedures of that drug at the FDA and/or EMA.
- Some agencies refer to the assessment from bigger agencies (almost always FDA and/or EMA but possibly additional ones) - but only partially. That's what is happening i.e. in some African or Asian countries. Quality data are usually reviewed independently, sometimes combined with independent inspections of manufacturing sites of drug substance (pure pharmacologically active substance) and drug product (formulation = e.g. tablet, sterile solution, syrup, ointment). Most countries would also check if sufficient pharmacokinetics, pharmacodynamics, efficacy & safety data (PK = what's the body doing with the drug?; PD = what's the drug doing with the body?) are available to support the claimed indication and usage in the population of their country; there can be big differences between caucasians and non-caucasians, and the majority of data in pivotal trial (clinical trials designed to establish efficacy and safety) are still from caucasians.
Some background that IMO helps to get a better grasp of the complexity of the subject:
- A drug gets registered by an agency on very specific conditions. The vast majority of these conditions are outlined in what the FDA names product information(PI), the EMA summary of product characteristics (SPC or SmPC), Health Canada product monograph (PM). The agencies decide word by word, comma by comma what gets in. Practically any changes, including fixing typos, require approval.
PIs/SmPCs/PMs are available on the agencies' websites so everybody can read them.
Patient leaflets / package inserts reflect what patients need to know from the PI/SmPC/PM in layman's language (ideally at least). That's where a lot of the complexity, i.e. from the indication wording of a drug, is removed from the patient's eyes but it is still relevant for regulators, prescribers and reimbursement bodies.Hope that helps.
- Most countries offer different types of licenses for drugs. That's a really complex world but as a rule of thumb, the main difference between them is that requirements differ in terms of robustness of evidence (and possibly obligations tied to a certain type of licence).
Obviously, a company isn't entirely free to chose which type of licence it wants to obtain; it depends on the medical environment: A drug for a disease with no or only few insufficient treatment options in this country so far (e.g. limited efficacy, suboptimal safety profile) may qualify for a licence with fewer requirements but a drug that doesn't offer anything substantially new or better than existing treatment options qualifies only for a 'standard' licence.
Do biologics pose a specific challenge? I am thinking about the problem, that intellectual protection/patenting is a bit problematic around for them. It is hard to clearly define them as done with other drugs previously, because molecules might be marginally different. It is possible to design similar drugs around this IP protection. I am not entirely sure how much regulators are concerned by this, but this certainly affects them when it comes to the approval of generics (biosimilars). Due to marginal differences, you need additional clinical trials to show that these generics are really similar enough. Till 2010 there was imo not even a process for this at all and all biosimilars had to start from scratch, because they couldn't use the data of the corresponding biologic. That increased the price a lot. I know that BPCIA came into place with the ACA, but I don't really know what it changed.
Do you think that the current process is suited to deal with these drugs (also remembering, that drug development is costly and very risky) and might be too expensive?