Priority Review New Drug Submission Health Canada

PRIORITY REVIEW NEW DRUG SUBMISSION PROCESS HEALTH CANADA

In Canada, Health Canada has various licensing pathways for drugs, medical devices and other health products and they continue to work towards different pathways like the Priority Review New Drug Submission to facilitate market access of key health products, particularly those for unmet medical needs.

The regulatory strategies and submission work are done by regulatory experts; professionals well-versed and experienced in how each regulatory body evaluates and approves New Drug Submissions (NDS), Medical Devices License Applications as well as other health product applications in Canada or their equivalent outside Canada. This article will focus on what is called Priority Review New Drug Submission Process by Health Canada.

If you are looking to conduct a clinical trial in Canada or submit for the marketing authorization of a new health product, it is important to be familiar with the overall new drug submission process in Canada

 

Priority Review New Drug Submission Process in Canada – PR NDS

A Priority Review (PR) New Drug Submission (NDS) is a type of regulatory filing submitted to Health Canada for the review of a new drug, at the end of its clinical development program, that is considered to have the potential to provide significant benefit over existing therapies (when available) for serious or life-threatening conditions. PR NDSs are prioritized over standard NDSs and are scientifically reviewed within 180 days, rather than the standard review time of 300 days. This expedited review process is intended to help bring new, innovative treatments to patients in need more quickly.

To apply for a Priority Review NDS, a sponsor must demonstrate that the drug is to be used for a serious, life-threatening, or severely debilitating condition when there is substantial evidence of clinical effectiveness that shows the following:

  • effective treatment, prevention or diagnosis of a disease, for which no therapy is available in Canada, or
  • significant increase of efficacy and/or decrease in risk, supporting an improved benefit/risk profile over available treatment, prevention, or diagnostic agent for a disease, not adequately managed by available agents in Canada.

In summary, Priority Review New Drug Submission Process in Canada allows for drugs with a complete clinical program that address important unmet medical needs. The sponsor has to apply for a PR through an official request supported by a Clinical Assessment Package, justifying scientifically and with sufficient data why the submission should be granted PR rather than following the standard NDS process.

The Priority Review process differs from the regular NDS process as presented below:

 

After the Notice of Compliance – NOC

Once Health has reviewed the submission and determined that the drug is safe and effective for its population, they will issue a Notice of Compliance (NOC), which grants the sponsor permission to sell the drug in Canada.

 

The Role of Regulatory Experts in Canada

It is the role of regulatory experts to strategize with you about which pathway to follow, and to navigate these applications through Health Canada or their equivalent outside of Canada, to liaise with regulatory body officials, and lead the submission process.

 

FURTHER INFORMATION

For further information about the drug review & approval process in Canada, or about the New Drug Submission Process with Health Canada or to have a complementary discussion about your needs, please contact SPharm directly.

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2025 Drug Regulatory Conferences for Canada

Drug Regulatory Conferences for Canada

In Canada, as with all countries with regulatory agencies, there are specific regulatory pathways and processes for health products to be authorized for use in clinical trials or to obtain market approval. Here we highlight a handful of drug regulatory conferences for Canada that you can attend to learn more about Health Canada’s criteria and perhaps even meet organizations, regulatory experts or consulting firms that can help with your regulatory needs for Canada. 

List of Drug & Medtech Regulatory Conferences for Canada

Medtech Canada Regulatory & Quality Conference

April 23 - 25, 2025

Ottawa, Canada

Event Summary

Canada’s Regulatory & Quality Medtech Conference 2025, presented by Medtech Canada, brings together regulatory and quality professionals from across the MedTech industry for informative sessions and valuable networking opportunities.

Attendees will hear from and be able to engage with Health Canada and other stakeholders in an open-dialogue environment. The conference is set to take place on April 23, 24 & 25, 2025 at the John G. Diefenbaker Building (11 Sussex Drive, Ottawa, Ontario). In-person and virtual participation options will be available.

What to expect from the conference

Your time is valuable! Medtech Canada’s Education & Training Committee is working hard to ensure the most relevant topics are brought forward during this conference and would like to thank all of those that participated in providing their feedback on the 2024 conference. Below are just some of the features of Canada’s Regulatory & Quality Medtech Conference:

  • 3 day event, allowing for more content
  • Networking opportunities including an afternoon reception
  • Recorded sessions which can be viewed through the virtual event portal

Informaconnect- Pharma & Medtech Compliance Congress Canada

June 2 & 3, 2025

Toronto, Canada

Event Summary

Delivering Everything You Need For Pharmaceutical & MedTech Compliance Excellence. 

PCC Canada returns this year to Toronto with advanced insights on the hottest topics and key challenges facing Canadian bio/pharmaceutical  and medical technology professionals today. As the industry’s must-attend event covering the Canadian healthcare compliance landscape, this  Congress keeps you on the pulse of the latest code considerations and explores innovative strategies to optimize compliance operations and risk management. With session topics focused on showcasing key regulatory considerations and top emerging risk areas such as AI and privacy and two featured customizable track options, this conference covers it all. Join experts across the life sciences community in this exclusive opportunity to unite with industry peers to benchmark, collaborate and explore how to stay ahead of evolving code changes and future-proof your compliance program against top emerging risk areas. 

SOCRA - Conducting Clinical Trials in Canada

June 12 & 13, 2025

Toronto, Canada

Event Summary

Goal: The Society of Clinical Research Associates (SOCRA) recognizes the continuing need for education for Clinical Research Professionals responsible for the activities at the research site or institution. The purpose of this workshop is to assist Research Professionals in improving their skills and their understanding of the responsibilities of conducting clinical research in Canada.

Objective: The goal will be accomplished through lecture and practical application facilitated by clinical research professionals. Information will be presented and discussed regarding the administration of clinical trials according to Health Canada Regulations and International Council for Harmonisation (ICH) guidelines as well as practical procedures and site / sponsor / CRO relationships.

Learning Objectives: Upon completion of the conference, the attendee should be able to:

  • Discuss opportunities and challenges facing the clinical research industry.
  • Discuss the challenges, opportunities, and best practices with Decentralized Clinical Trials.
  • Discuss the responsibilities of an investigator as outlined in ICH E6(R2) Guidelines Sections 4.1to 4.13.
  • Discuss regulation of investigational testing of medical devices in human in Canada, including limitations and key considerations.
  • Discuss the regulatory framework governing CTA and review process at Health Canada.
  • Discuss FDA’s role in the oversight of clinical trials that are conducted in Canada.
  • Discuss tools and resources researchers can access to learn more about best practices in RDM.
  • Discuss the sources of data and data itself that Data Management collects outside of the CRFs or EDC System.
  • Discuss how REDCap has been used Health Canada regulated clinical trials.
  • Discuss challenges and potential solutions for improving diverse clinical trials participation.
  • Discuss how to build a better site/sponsor relationship, with an emphasis on the monitor role.
  • Discuss how to best be prepared for a GCP inspection or audit.

BIO International Convention - Canada Pavillion

June 16 to 19, 2025

Boston, United States

Event Summary

The BIO International Convention is the largest and most comprehensive event for biotechnology, representing the full ecosystem of biotech with 20,000 industry leaders from across the globe.

Once again,  BIOTECanada led the Canadian delegation and managed the installation of the Canadian Pavilion with partners from across Canada. BIOTECanada is the national industry association voice for the Biotech industry in Canada. BIOTECanada along with the provincial Accord members, the Government of Canada and the Quebec provincial government offered fantastic Canadian programming, and the agenda of activities built on the policy initiatives Canada has established to showcase the innovation and research capacity driving new economic success.

Over 4 days, the Canada Pavilion showcased our life sciences ecosystem and the many opportunities for collaboration within the sector, program panelists and dignitaries provided invaluable perspectives on the rapidly evolving industry.

CAPRA Pharmaceutical Symposium

October 2025

Toronto, Canada

Event Summary

The Canadian Association of Professionals in Regulatory Affairs (CAPRA) is a non-profit organization that serves the pharmaceutical, biologics, medical device, cosmetic and natural health product industries in Canada.

CAPRA hosts a one-day pharmaceutical symposium with Health Canada and Industry leaders. This unparalleled collaborative event will provide a unique opportunity to hear about the Canadian Pharmaceutical industry directly from those involved in the Regulatory sector..

DIA Canada Annual Meeting

October 27 & 28 2025

Gatineau, Canada

Event Summary

The DIA Canada Annual Meeting will provide an in-depth exploration of the current pharmaceutical, medical device, and diagnostic landscapes in Canada, emphasizing Canada’s pivotal role in global healthcare product development. Offering three specialized tracks on Regulatory, Clinical, and Safety and Pharmacovigilance, the meeting will cover topics spanning from Health Canada’s latest regulatory initiatives, international collaboration, and innovative clinical practices to approaches that harness AI in drug safety and increase representation from equity-denied groups.

Attendees will have the opportunity to engage with leaders and experts from academia, regulatory bodies, and the pharmaceutical and medical device industries by gaining insights into best practices, lessons learned, and strategies to address the challenges facing stakeholders in Canada.

FURTHER INFORMATION

For further information about the drug review & approval process in Canada, or about the New Drug Submission Process with Health Canada or to have a complementary discussion about your needs, please contact SPharm directly.

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Top Traits of Drug Regulatory Affairs Consultants

TOP TRAITS OF DRUG REGULATORY AFFAIRS CONSULTANTS

We have often been tasked to “find solutions” to the problems that arise when a regulatory professional isn’t brought in early-on in the health product development process. As such, we thought we’d share with you what the role of a Regulatory Affairs consultant is and what traits and attributes you will want to see in the person or consultant you hire.

 

Hire a Regulatory Consultant Early

Studies that are not well-planned are at risk of being unacceptable from a regulatory authority perspective, and yet still get conducted. As the study proceeds, development is consequently slowed or expanded as people address requirements ad-hoc.  Submissions with inappropriate or insufficient data are prepared, causing submission review delays and its associated costs. There may even be instances where there is a need to go back to the drawing board and start from scratch or close to.

If the rationale behind not bringing a regulatory professional on board early was savings, companies often discover too late that it may end up costing them more on the back end. So, the selecting of an excellent regulatory professional is key and bringing them on at the planning stage, is tantamount.

One question worth asking is: Is there a specific certification that makes someone an effective regulatory professional or is it experience that makes you an expert? Well, the RAC certification from RAPS (of which I am a proud co-author) is well reputed for expertise and is an important foundation. That being said, the patina that develops over time managing a variety of challenging regulatory dossiers makes the most effective experts, in my view.

GOOD, JUST ISN’T GOOD ENOUGH

Here, we look in more detail at the benefits an excellent regulatory professional brings to each stage of the regulatory process (because good just isn’t good enough when we’re talking about the time, money, and value that this industry requires).

STAGE 1: RESEARCH & DISCOVERY

An excellent regulatory professional ensures that the planned development of a health product adheres to international Regulatory Agency requirements with a clear market aim in mind; this includes planning that considers the possibility of expanding the development geographically and facilitating the process of doing – lending flexibility to a development that may need to expand or could benefit from expanding.

STAGE 2: PRE-CLINICAL RESEARCH

In this stage, a regulatory professional ensures that the pre-clinical and the quality (CMC) development programs meet both local and international requirements prior to a first in-man study. This is where the traits of the professional become particularly important. Thorough and detail oriented, a keen logistical ability and regulatory intelligence separate those who are good from those who are great.

STAGE 3: CLINICAL TRIALS AUTHORIZATION

With the aim of obtaining authorization to conduct clinical trials, at this stage the role of a regulatory professional is to ensure that both local and international requirements are met. A regulatory professional coordinates pre-submission meeting, performs efficient and strategic medical and regulatory writing, performs QA and reviews submission documents for local and global compliance, prepares submissions to Health Authorities and ensures regulatory interfacing with them during the preparation, review processes and afterwards as needed.

Considering the significant sums of money involved, it’s not enough to have someone who has done it before or knows what to do, since the attributes of the person/the team can affect outcomes.

STAGE 4: REGULATORY PROCESS AND APPROVAL FOR MARKET ACCESS

In this fourth stage, the regulatory professional provides support and knowledge during each step of the registration process. Specifically, your expert should assist you in successfully navigating submission preparation, identify potential concerns ahead of submission time and proactively find solutions. In this phase, expert should perform efficient and strategic medical and regulatory writing, QA and reviews submission documents for completeness as well as local and global compliance, interface with health authorities and makes the regulatory process more predictable until drug approval. Here also, expertise is key.

STAGE 5: COMPLEMENTARY INITIATIVES

Regulatory professionals act not only as guides through the drug development processes at the pre-clinical, clinical phases and registration for market access phases. Experts also prepare provincial reimbursement submissions and provide support in reimbursement negotiations with decision makers. They also review marketing material and advertisement initiatives for compliance with the Food and Drug Regulations and PAAB Code and liaise between PAAB decision makers and sponsor, activities that are also key in the market access profession (combination of provincial initiatives in addition to the Federal ones).

STAGE 6: ONGOING POINT OF CONTACT

When the registration process is complete, and a health product can reach the market, a regulatory professional remains the point of contact with Health Authorities, to ensure compliance behind maintaining a registration.  A true regulatory expert will evaluate the reportability of pharmacovigilance activities in compliance with regulations, evaluate the type of post-approval variations and documents required, prepares and coordinates all post approval submissions to Health Authorities, and coordinates telecoms or face-to-face meetings with them as needed.

IN SUMMARY

Regulatory affairs professionals are your quintessential regulatory process concierge; experts to call on the moment you first begin thinking about planning any medical device, drug or other health product development so that each stage of the process is navigated smartly and skillfully.

Considering the significant sums of money involved in the development process of a drug, medical device or other health product, it is simply not worthwhile to hire or work with someone who is not considered an excellent regulatory expert.

Why choose SPharm as your regulatory experts for Canada?

SPharm specializes in health products (including drugs and medical devices) regulatory affairs, development & approval services. Our team of experts assists pharmaceutical, biotechnology, natural health product and medical device companies from around the world through the various phases of product development, regulatory approvals, market access and life cycle management post approval. 

SUBMISSION SUCCESS RATE

Near 100%

HIGH CLIENT SATISFACTION

Resulting in long term business relationships

EXPERIENCE MATTERS

Three decades leading in Canadian regulatory affairs

STRATEGIC RELATIONSHIPS

With health authorities, clients & partners

UNMATCHED EXPERTISE

With Canadian health regulations and guidance

CHALLENGING GUIDELINES

Experience with submissions that challenge regulatory guidelines

PROJECT MANAGEMENT

That respects established timelines

APPEALS PROCESS

Experience with successful appeals procedures

Overcoming Obstacles in the Drug Approval Process in Canada

Staying abreast of drug regulatory landscapes is understandably a challenge; the environment can be challenging to master because of its complexity and the fact that it is continuously changing. Innovations in both science and data collection/reporting methods keep the landscape fluid; it takes rigor and devotion to stay current.

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New Drug Submission Process in Canada

NEW DRUG SUBMISSION PROCESS HEALTH CANADA

 

In Canada, as in all countries with regulatory agencies, there are specific regulatory pathways and processes for health products to be authorized for use in clinical trials or to obtain marketing approval. This article will focus on what is called the New Drug Submission Process in Canada. If you are looking to conduct a clinical trial in Canada or submit for the marketing authorization of a new health product, it is important to be familiar with the new drug submission process in Canada and what other regulatory processes look like, including the pathways that are available to you to achieve this.

We will present the principal regulatory process for drug approval with Health Canada. The regulatory process for other health products, including Medical Devices, will be covered in subsequent articles.

 

Drug Regulatory affairs in Canada

Regulatory affairs in relation to clinical trials or investigational testing refers to the process of ensuring that a trial conducted with patients or healthy individuals adheres to all relevant laws and regulations during the drug, medical device, or other health product clinical development process. This includes getting necessary authorizations from regulatory agencies governing the country where the sponsors wish to launch a trial.

In Canada, that regulatory agency is Health Canada (HC). The goal of HC, its Food and Drug Regulations, and regulatory processes is to protect the health and safety of the participants in those trials and ensure the accuracy and integrity of the data collected; this includes the reporting of any serious adverse events that occur during the studies. HC is interested not only in the safety of trial participants; data accuracy and integrity are as important and are needed for the eventual market access application you will submit at the end of the clinical development process.

Most countries have their own regulating body, for example, the Food and Drug Administration (FDA) in the United States (US), European Medicines Agency (EMA) in the European Union, Therapeutic Goods Administration (TGA) in Australia and the Central Drugs Standard Control Organization (CDSCO) in India, to name a few.

What they have in common is that the approach to trials, drug development, and market access process be transparent and efficient whilst ensuring the safety, efficacy, and quality of the product for their citizens.

 

Regulatory and licensing pathways for drugs in Canada

In Canada, Health Canada has various licensing pathways for drugs, medical devices and other health products and they continue to work towards different pathways to facilitate market access of key health products, particularly those for unmet medical needs.

The regulatory strategies and submission work are done by regulatory experts; professionals well-versed and experienced in how each regulatory body evaluates and approves New Drug Submissions (NDS), Medical Devices License Applications as well as other health product applications in Canada or their equivalent outside Canada.

 

Specifically, the drug approval pathways in Canada are summarized as follows:

Regular New Drug Submission Process in Canada – NDS:

NDS stands for “New Drug Submission” in Canada, other acronyms would apply outside Canada. It is the regulatory process required by Health Canada that pharmaceutical companies are required to go through to bring their new drugs to the market. The submission must include all relevant data and information about the drug, including non-clinical, clinical, and quality data, which address safety and efficacy as well as the overall quality (chemistry, manufacturing, and controls) of that drug. Health Canada reviews this information to determine if the drug is of good quality, safe and effective (positive benefit vs. risk ratio) for its intended use. Only then can it be approved for sale to the public.

The standard timeframe for scientific review of the NDS is 300 days, preceded by a screening period of 45 days and 10 days of technical processing, as indicated below:

 

New Drug Submission Process in Canada

 

Priority Review New Drug Submission Process in Canada – PR NDS

A Priority Review (PR) New Drug Submission (NDS) is a type of regulatory filing submitted to Health Canada for the review of a new drug, at the end of its clinical development program, that is considered to have the potential to provide significant benefit over existing therapies (when available) for serious or life-threatening conditions. PR NDSs are prioritized over standard NDSs and are scientifically reviewed within 180 days, rather than the standard review time of 300 days. This expedited review process is intended to help bring new, innovative treatments to patients in need more quickly.

To apply for a Priority Review NDS, a sponsor must demonstrate that the drug is to be used for a serious, life-threatening, or severely debilitating condition when there is substantial evidence of clinical effectiveness that shows the following:

  • effective treatment, prevention or diagnosis of a disease, for which no therapy is available in Canada, or
  • significant increase of efficacy and/or decrease in risk, supporting an improved benefit/risk profile over available treatment, prevention, or diagnostic agent for a disease, not adequately managed by available agents in Canada.

In summary, Priority Review New Drug Submission Process in Canada allows for drugs with a complete clinical program that address important unmet medical needs. The sponsor has to apply for a PR through an official request supported by a Clinical Assessment Package, justifying scientifically and with sufficient data why the submission should be granted PR rather than following the standard NDS process.

The Priority Review process differs from the regular NDS process as presented below:

New Drug Submission Process in Canada with Priority Review

Notice of Compliance with Conditions – NOC/c NDS:

The Notice of Compliance with Conditions (NOC/c) pathway allows a sponsor to bring a new drug to market during the clinical development process, and therefore more quickly, in exchange for accepting to complete the clinical development program agreed to with Health Canada. An approval under the NOC/c policy contains conditions that a sponsor needs to comply with after the drug approval.

Eligibility

Eligibility for advanced consideration for a NOC/c applies to NDSs and SNDSs for serious, life-threatening, or severely debilitating conditions when there is promising evidence of clinical effectiveness based on the available data that shows the following:

  • effective treatment, prevention, or diagnosis of a disease, for which no therapy is available in Canada, or
  • significant increase of efficacy and/or decrease in risk, supporting an improved benefit/risk profile over available treatment, prevention, or diagnostic agent for a disease, not adequately managed by available agents in Canada.

NOC/cs are possible for drugs with promising clinical data that addresses important unmet medical needs. The NOC/c process differs from the regular NDS process as presented below:

New Drug Submission Process in Canada -NOC with Conditions

Drug Submissions Relying on Third-Party Data (Literature and Market Experience):

This refers to the use of existing scientific literature or third party published data in lieu of clinical study reports to support the safety and efficacy of a drug. Literature can be used to support a New Drug Submission (NDS) or a Supplemental New Drug Submissions (SNDS) in Canada.

This approach saves time and resources for both the sponsor and HC, provided that the submission complies with the criteria established by HC. The literature must be relevant, reliable, and adequate to support the safety and efficacy of the drug in question and meet current regulations, guidelines and recommendations. The chemistry, manufacturing and controls (quality) data requirements are the same as for any other NDSs or SNDSs.

In addition to the pathways summarized above, HC does explore additional pathways to facilitate drug development to address unmet medical needs and to streamline their own processes, for example: Australia-Canada-Singapore-Switzerland (ACSS) Consortium and use of foreign reviews and decisions.

Project Orbis is another example of an international partnership HC is a part of which is designed to give cancer patients faster access to promising cancer treatments, alongside the US FDA. Products eligible for Project Orbis include oncology products that are either new active substances or new indications for previously approved drugs. Project Orbis submissions are expected to meet the criteria for “FDA Priority Review” and Health Canada PR or NOC/c criteria.

The various programs or pathways presented above can be explored with the assistance of regulatory experts, when a sponsor wishes to obtain a marketing authorization for a new drug in Canada. The various submission types have to respect specific criteria established by HC, which further underscores the need to work with regulatory experts that can orient the sponsor towards the most relevant and efficient pathway to use.

After the Notice of Compliance – NOC

Once Health has reviewed the submission and determined that the drug is safe and effective for its population, they will issue a Notice of Compliance (NOC), which grants the sponsor permission to sell the drug in Canada.

After an NOC has been granted for a new drug in Canada, maintaining the drug on the market requires various compliance activities, including pharmacovigilance and lifecycle management to ensure that the drug continues to be compliant with the requirements of the Food and Drug Regulations. Life cycle management activities could include a Supplemental New Drug Submission with new data from clinical trials to support a new indication or other important changes to the labelling of the drug. Likewise, major changes to the manufacturing process, or adding new formulations or a new dosage form, for example, would also require a submission to HC to ensure compliance with the regulations. For major changes that require approval from HC, a new NOC will be issued once HC has reviewed the submission and supporting data and, determined that the changes are acceptable; only then these changes can be implemented.

The Role of Regulatory Experts

Whichever pathway you utilize, it is imperative that the approach be one that is streamlined, transparent, and efficient, while ensuring the quality, safety, and efficacy of the product. It is the role of regulatory experts to strategize with you about which pathway to follow, and to navigate these applications through HC or their equivalent outside of Canada, to liaise with regulatory body officials, and lead the submission process.

 

FURTHER INFORMATION

For further information about the drug review & approval process in Canada, or about the New Drug Submission Process with Health Canada or to have a complementary discussion about your needs, please contact SPharm directly.

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How to Determine your Regulatory Affairs Needs

DETERMINING YOUR DRUG REGULATORY AFFAIRS NEEDS


Well-defined and appropriately supported regulatory needs increase the likelihood of successful submissions and market access. So how does one go about determining what those regulatory needs are or might be, especially when embarking in a health product development process at its initial stages?

Also, are there different considerations for pharma, biotech, and investigator led trials?

The short answer is yes.

It takes experience to establish a good health product development strategy and to build trust and communication channels that clearly communicate its details. Get it right, and you can reduce possible errors, save time and money, and lessen the steep learning curves that are common at the start of a mandate.

Together we will look more closely at the considerations for starting to define needs as a whole whether you are Pharma, Biotech or an Academic institution. Let’s look at the unique needs for each:

 

REGULATORY AFFAIRS FOR PHARMA

As a pharma, you have regulatory professionals on board. In instances when in-house staff does not have the expertise required in a specific situation, you will need to hire for a specific need, an expert to work in collaboration with your team. (i.e. orphan drugs, oncology, products that can be considered for priority reviews or NOC with condition, literature-based dossiers, etc.). In instances when workload is very high, or during peaks of activity, external professionals will act as an extension of your team and alleviate congestion, avoid delays and ensure timelines are respected.

 

REGULATORY AFFAIRS FOR BIOTECH

For a biotech, particularly start-ups, it is unlikely to have a regulatory expert on staff. Development is costlier with biology / biotech products which means that cost efficient health product development is key.  Considering the greater health product development costs for biotechnology companies, the impact of failures and errors is more significant.  As a biotech, one of the most significant impact that a regulatory professional’s expertise and regulatory intelligence will have is in streamlining the regulatory process. They will increase efficiency to save you time and money.

 

INVESTIGATOR DRIVEN CLINICAL TRIALS

It isn’t uncommon for investigator driven clinical trials to commence without at least an initial consultation with regulatory agencies. This typically happens when the investigators are unfamiliar with the characteristics and requirements of the regulatory process or don’t consider that the obligations apply equally to investigators as they do pharma and biotech start-ups. For some others, it’s seen as a viable cost-cutting measure until they see once in the trial that, had they had a regulatory professional to draw on in the planning stages, it would save more time, cost less money, and increase efficacy. The obligations are the same whether the sponsor is a manufacture or an investigator and it’s important that the clinical trial initiatives are developed in line with regulatory obligations and Good Clinical Practices (GCPs).  A regulatory affairs professional will be able to ensure the study starts off in observance of the applicable regulations and GCPs.

Also, all studies conducted with a health product have the potential to be included in a registration dossier, making having a regulatory professional involved from the moment you begin to think about planning a study is a significant advantage. An expert who can help plan the health product development efficiently, including clinical development, such that no investment is lost via suboptimal planning is particularly important.

 

HIRE REGULATORY EXPERTS EARLY

Whether you are a sponsor in pharma, a biotech, or an investigator, you will need regulatory support from inception to submission, and a good way to begin a needs assessment is with questions at the research planning stages that shape the thinking process; there are three in particular that are wise to consider at the start.

Best practices assert that the earlier a regulatory expert is brought on, the better the outcomes. A way to look at this is, bringing in a regulatory professional on for the first time at the submission stage, would be akin to hiring a boat maker after you’ve already built a boat and want help to put it in the water.

Hiring at the start to define needs and formulate a strategic regulatory plan produces three significant advantages:  

  1. Ensure the research is relevant and that it will address a medical need / allow for market access so that funds are not misspent.
  2. Establish a smooth relationship with Health Canada teams built on the positive reputation of the regulatory professional.
  3. Accelerate Health Canada’s confidence in the company developing the product because the person interfacing speaks the same language as the regulatory agency.

Deciding whether to hire for the entire process, or part of it.

Needs change and issues can arise because both the product development and regulatory landscape evolve. New laws and regulations, requirements, and even innovations have the potential to affect health product development strategies. Regulatory professionals understand this and work it into their strategic plan, making it possible to anticipate changes and overcome challenges should they arise.  The importance of being responsive to these events means that needing to find, hire and transfer knowledge (and all that this entails) would be wasteful of all resources as compared to having a team or dedicated professional involved (and informed) from the start.

Is it possible to use different professionals for different parts of the process?

Throughout every study there is a need for different skill sets and experience. A team (it can be a small one with proven experience) comprised of professionals with deep knowledge of specializations within the health product development and lifecycle management, not only will enable time to not be lost on learning about the project, but also consistency will be maintained in communications with regulatory authorities.

Still, if you opt to go the route of trying out different professionals for different parts of the process, keep in mind the importance of using a polyvalent expert to optimize information and reduce the time and money investment. It speaks directly to the costs associated to the project(s) learning phases. Subject matter expertise is a driving force in how well the development process unfolds because specialists are able to help you avoid and overcome concerns, changes, challenges or other issues along the way. Their work can help reduce overall cost, alleviate workload, and improve timelines.

To ensure that you’ve hired an excellent professional or firm, please read our post on the subject.

The more consistent the team, the lesser mistakes and errors are encountered. Adherence to regulatory requirements are best achieved with the guidance and support of a regulatory affairs professional. This has many benefits, including increasing the worth of the clinical study or development strategy by respecting regulatory paths, for future inclusion of studies/science in a registration dossier.

 

THE TAKEAWAY

Hire a professional early – very early, in fact, at the planning stage so that your needs can be delineated by an experienced professional who can established a plan that will allow the drug development strategy to be responsive to changes. Regulatory needs may change depending on whether you’re in pharma, biotech, or an independent investigator, consult with a regulatory expert before you begin to ensure that nothing is missing within your health product development strategy and / or your study design, in other words, you will want to make sure that your plans will build a boat that floats.

How long does it take a drug product to be approved in Canada?

How long does it take a drug product to be approved in Canada?

 

WHAT ARE HEALTH CANADA’S TIMELINES TO PROVIDE AUTHORIZATION FOR A DRUG TO BE SOLD ON THE CANADIAN MARKET?

The Canadian review timeline for a New Drug Submission (NDS) is competitive.

  • A standard review consists of a maximum of 10 days eCTD validation,
  • followed by 45 days administrative screening where it is verified that the content is acceptable and that no key information is missing,
  • following the screening period, a 300-day scientific review of the quality, non-clinical and clinical data packages, applies

Therefore, a total of 355 review days applies, before a sponsor obtains a final review decision.

Should the NDS qualify for an accelerated review either under a Priority Review or a Notice of Compliance with condition, the review timelines are shorter.

Please read our Canadian Drug Review & Approval  Guide for further information on the drug approval process in Canada. 


 

For questions about the Canadian Drug Review & Regulatory approval process that is not covered in this section, please go ahead and contact us directly.


How to Pick a Drug Regulatory Affairs Consultant

HOW TO PICK THE RIGHT DRUG REGULATORY AFFAIRS CONSULTANT

“Know thy self” is as important in life as it is in the development lifecycle of a health product – be it a drug (pharmaceutical, biologic or biotechnical), a medical device or other; particularly as you embark on finding the “right” drug regulatory affairs consultant.

In fact, the accelerated use of technologies in life sciences, such as stem cell research, gene therapy, real world evidence, mobile medical devices, and cloud computing to name a few, underscores the necessity for picking the right regulatory affairs expert, consultant, expert or professional.

 

MEETING THE CHALLENGES AHEAD

Organizations in the Life Sciences continue to advance effective risk and compliance programs, for instance, by incorporating cyber security practices to safeguard patient data as well as corporate assets. As this new landscape emerges, regulatory affairs professionals will, more than ever, need to be agile and informed enough to meet upcoming and unexpected challenges.

Determining who that regulatory professional is depends largely on your goals. Regulatory consultants, experts or professionals (or other names you call them) must be skilled at taking into consideration complex global dimensions – including multinational supply chains for product manufacturing, global shipping, sales, and various marketing and post-approval surveillance requirements for multiple regions.

In January 2016, the FDA released post-market guidance outlining its cyber security expectations for medical device manufactures already in the field and in the pipeline. Other similar initiatives are being either considered or implemented in various countries.

As of January 2019, agencies such as Health Canada require companies to undergo MDSAP audits. knowledge in this area is essential as companies react to the slow adoption of a global regulatory assessment process.

Because the health product/medical device development process is a complex and ever-changing one; you want to be confident and at ease with who you will have chosen to be at the helm. Here, we will look at what credentials matter, where to find Regulatory Professionals, and fit (i.e. how well the person is likely to interface with your team).

 

WHAT CREDENTIALS MATTER

Most people who make the transition into the regulatory profession have relevant prior experience in related fields (e.g., research and development, quality or a clinical profession). Typically, they will hold at minimum a bachelor’s degree in science, preferably in chemistry, biochemistry, pharmacy, pharmacology, or pharmaceutical technology. However, this alone doesn’t make a good regulatory affairs professional.

There are several organizations and university departments that offer training / certifications in regulatory affairs, whether the candidate is experienced or not. Look for a professional who has the following credentials or training when hiring:

-Regulatory Affairs Certification, the RAC credential, is a well reputed, accredited, post-academic, professional credential for the regulatory professional working in the healthcare product arena, overseen by RAPS.

-RAPS (Regulatory Affairs Professionals Society) is a renowned organization that offer certification in regulatory affairs for medical devices and/or pharmaceuticals. Their numerous online courses cover essential concepts of healthcare product regulation and regulatory issues at each stage of the product lifecycle and for different regions of the world.

D.É.S.S. en développement du médicament of the University of Montreal, offers courses specific to the global health product development.

-AAPS (Academy of Applied Pharmaceutical Sciences) This certification program provides the comprehensive background and training required of regulatory affairs professionals to address domestic and international regulatory statutes and laws. Its program includes courses on International, Health Canada, and FDA’s laws, regulations, and Guidelines, investigational and marketing applications, technical writing, negotiation skills, development of New Drug Application (NDA) submissions, labeling and drug Information, Common Technical Documents (CTD), Notice of Compliance (NOC), Good Clinical Practices (GCPs), requirements for ongoing post-marketing surveillance and post-marketing changes, communication and management skills essential for the successful regulatory affairs professional in an industry work environment.

Now, as helpful as a candidate’s background or certifications may be, there is one thing that trumps both: experience.

In an industry that is as ever-changing and complex as this one, professionals with a vast amount of experience bring to the table the most valuable skills, knowledge, insight and results.

 

WHAT TRAITS MATTER MOST

There are attributes that are essential parts of all roles and positions. In regulatory affairs, the traits of a candidate matter as much as their experience.

We delved into the role of a regulatory affairs expert and outlined the traits necessary for an excellent professional. You can read the full article here.  In the meantime, these are some of the skills and traits to look for:

TRAITS: Collaborative Leader, Logical, Analytical, Meticulous, Collaborative & Flexible, Diligent, Passionate

SKILLS: Able to perform under stress, Regulatory Intelligence, Project Management, Excellent verbal & written communication

 

WHERE TO FIND QUALIFIED REGULATORY PROFESSIONALS

-RAPs, AAPS, may be able to direct you to a list of graduates.

-LinkedIn is an excellent platform to find professionals who have the experience and certification you are looking for, in particular, look at the various groups within the industry such as:

  • CAPRA – Canadian Association of Professionals in Regulatory Affairs
  • Clinical Research Canada
  • Clinical Research Professionals
  • Drug Regulatory Affairs
  • Pharma Connection Worldwide
  • Professionals in the Pharmaceutical and Biotech Industry
  • RADSP – Regulatory Affairs & Drug Safety Professionals
  • Total Orphan Drug

-When hiring an individual to join your staff, look at the scope and length of experience directly associated to the work you need done. This is a role that a person needs to come in knowing how to do well, not a role that they can take time learning on the job. You’ll want someone seasoned and well connected; someone with the ability to adapt to such difficult circumstances. Flexibility too, is a desirable quality for working in such a complex and changeable landscape; it also happens to be one of the cornerstones of successful consultancies.

-When looking to hire an independent drug regulatory expert or consultant or an outside regulatory firm like SPharm, understand that these consultants have gained a range of experiences in different markets and industries, allowing them to bring diversity of thought, experience and expertise to clients. They have also established a strong network relationships within the industry through dealing with multiple clients, colleagues and regulatory agencies. This network is an invaluable asset.

-When hiring a regulatory consultancy, much like SPharm, look at the profiles of their staff and how the team as a whole reflects the necessary broadness of skills and experience. Read any articles, posts and reports they produce because they will demonstrate depth of knowledge. If there are webinars, slide decks, whitepapers, eguides or books they have prepared or authored, watch those to also gauge their depth.

By its very nature, a regulatory consultancy must be absolutely well versed and informed on any and all regulatory specific changes, both locally and internationally. This knowledge presents an enormous advantage and opportunity for businesses seeking to hire them.

In addition to the traits above and the requisite skills and experience, you want to know that the person or company you hire has the respect and recognition of Regulatory Agencies and peers. A large and important aspect of the job is facilitating and navigating the complex regulatory landscape.

 

A MATCH MADE IN REGULATORY HEAVEN

Finding the right regulatory professional has less to do with the role itself and more to do with alignment to your company culture. This is where the notion of “Know Thy Self” becomes particularly important.

When hiring an individual, look at whether their aspirations match the job. Does the candidate fit into your growth plan for your business beyond filling a need you have right now? How do they want to grow their career in next several years and do they think this job with you can help them fulfill their aspirations? Getting a sense of both aspects will help you determine whether or not there is alignment between the candidate and your company’s goals.

Next, vet them appropriately. Applicable to both candidates and consultancies, it is important to understand how they work and who they are as a co-worker/service provider. You know the experience and traits you’re looking for, now it’s a matter of matching their past performance to the desired output you want. This involves vetting their references and asking pertinent questions to get an idea of their capabilities and work ethic.

Pay attention to the questions they ask; their questions show preparedness and engagement on the part of the candidate. The best hires care about the team they’ll be on or the company they are providing services to; they care about how they can help take your company forward. Questions will demonstrate their knowledge of the industry, and how apt they are – especially service providers – to understand the unique needs and goals of your organization.

Finally, be crystal clear about expectations. They might end up wearing several hats and going above and beyond. Working in the regulatory space isn’t easy, and while it is rewarding, it’s important to make sure candidates know they are going to work in frequent shifting conditions.

Always trust your instincts. You might be in a hurry to hire but hiring right matters more than hiring now.

Can SPharm Help?

If you are looking for help navigating the drug approval process in Canada or the medical device approval process in Canada, or assistance with clinical trial applications or new drug submissions, then perhaps reaching out to SPharm experts may be worthwhile. 

The Ultimate Glossary of Drug Regulatory Terms for Canada

The Ultimate Glossary of Drug Regulatory Terms for Canada

 

What’s with all these Drug Regulatory Acronyms and Definitions in Canada?

The pharmaceutical industry is complex. The terms, expressions, abbreviations and industry vernacular are also as complex and confusing. We have attempted to put some order within this process by providing what we call the ultimate glossary of the most common abbreviations and terms used in the drug regulatory industry in Canada.

All terms and acronyms have been organized alphabetically.


What is Annual Drug Notification – ADN?


Annual Drug Notification is a notification sent to Health Canada annually, before October, by a drug sponsor/manufacturer, confirming that all information previously supplied with regard to that drug is correct, in order to comply with section C.01.014.5 of the Food and Drug Regulations. The Annual Drug Notification Form (ADNF) is available to assist manufacturers in complying with the said regulations.

 

What is Adverse Drug Reaction – ADR?


Adverse drug reaction is a noxious and unintended response to a drug, which occurs at doses normally used or tested for the diagnosis, treatment or prevention of a disease or the modification of an organic function. It includes lack of efficacy.

 

What is Adverse Event – AE?


Adverse event is any adverse occurrence in the health of a clinical trial subject who is administered a drug, that may or may not be caused by the administration of the drug, and includes an adverse drug reaction.

 

What is Abbreviated New Drug Submission – ANDS?


Abbreviated new drug submission is a regulatory dossier that needs to be submitted and approved by Health Canada for a manufacturer to be granted authorizations to sell (Marketing Authorization) a generic drug on the Canadian market. This dossier typically requires a Bioequivalence study or a physico-chemical comparison (or both) against the Canadian Reference Product (innovator) plus a complete Chemistry and Manufacturing (Quality) package. Some exceptions can apply.

 

What is Adverse Reaction – AR?


Adverse reaction is a noxious and unintended response to a marketed health product and includes Adverse Drug Reaction as defined in the Food and Drug Regulations and Adverse Reaction as defined in the Natural Health Products Regulations. In the later regulations, AR means a noxious and unintended response to a natural health product that occurs at any dose used or tested for the diagnosis, treatment or prevention of a disease or for modifying an organic function.

 

What is Biologic and Genetic Therapies Directorate – BGTD?


Canadian regulatory authority of biological drugs (products made from living sources) and radiopharmaceuticals (drugs that have radioactivity) for human use in Canada. It is one of Health Product and Food Branch Directorates. Before giving permission to sell these therapies, the directorate must see scientific evidence of it’s safety, effectiveness, and quality, as required by the Food and Drugs Act and Regulations.

 

What is Canadian Agency for Drugs and Technologies in Health – CADTH?


An independent, not-for-profit organization responsible for providing health care decision-makers with objective evidence to help make informed decisions about the optimal use of health technologies, including: drugs, diagnostic tests, medical, dental, and surgical devices and procedures. In addition to evidence, we also provide advice, recommendations, and tools.

This agency was initially established in 1989 as the Canadian Coordinating Office for Health Technology Assessment (CCOHTA), CADTH adopted its new name in April 2006 to better reflect their broad activities.

 

What is Clinical Assessment Package – CAP?


A clinical assessment package is a document which needs to be prepared and submitted to Health Canada’ appropriate review Bureau along with a written request to obtain a Priority Review Status, in advance of the filing of New Drug Submission (NDS).

 

What is a Category IV Drug Product?


Category IV Products makes reference to products that have Category IV Monographs, that are developed for drugs that have a well characterized safety and efficacy profile under specific conditions of use. A manufacturer may reference a Category IV Monograph in a drug submission when the product and its labelling are consistent with the information set out in the document. Products subject to Category IV Monographs, can obtain a DIN through a DINF application.

 

What is Canadian Blood Services – CBS?


Canadian Blood Services was founded in 1998, based on recommendations from the Krever Report on the tainted blood scandal of the early 1990s. CBS is regulated as a biologics manufacturer by Health Canada and primarily funded by the provincial and territorial ministries of health. Canadian Blood Services is a not-for-profit charitable organization.

 

What is the Canadian Institute for Health Information – CIHI?


A Canadian health agency that collects and reports on clinical and non-clinical data.

 

What is the Council for International Organization of Medical Sciences – CIOMS?


The CIOMS refers essentially to the CIOMS I Form, which provides a standardized format for the reporting of suspected adverse reactions to any particular medical product, in Canada as well as worldwide.  The Council plays an important role in the current pharmacovigilance practice.

 

What is a Common Drug Review – CDR?


A common drug review is a national review process for non-oncology drugs that focuses on the cost effectiveness of a drug vs. current therapies. CDR issues a recommendation to the government drug plans (except Quebec – see INESSS) as to whether or a not a  drug should be publicly funded for patients who need access.

What is a Clinical Trial – CT?


A clinical trial is an investigation with a drug for use in human subjects, intended to discover or verify the clinical, pharmacological or pharmacodynamic effects of the drug, identify any adverse events, study the absorption, distribution, metabolism and excretion of the drug, or ascertain the safety or efficacy of the drug.

 

What is a Clinical Trial Application – CTA?


A clinical trial application is a regulatory dossier that needs to be submitted to Health Canada and given a No Objection Letter (NOL) from Health Canada prior to the sponsor proceeding with a clinical trial with an investigational pharmaceutical, biological and radiopharmaceutical product in the Canadian population / patients. In the the context of clinical trial management activities, CTA can also mean Clinical Trial Agreement (which is the agreement between the clinical trial investigational sites/center and the sponsor, in order to conduct the aimed study).

CTA also means Clinical Trial Authorization, the equivalent to a Clinical Trial Application required in Europe (EMA). In the USA (FDA), IND (Investigational New Drug) is the equivalent of the Clinical Trial Application.

 

What is a Clinical Trial Application – Amendment/Notification – CTA-A/N?


CTA-A: Changes to the clinical trial protocol or quality dossier, after the original CTA submission, that will impact the safety of the subjects, will affect the analysis and the interpretation of the safety and efficacy of the drug(s) under investigation or, that may affect the quality or safety of the clinical trial drug supplies.  A 30-day review period applies before these changes can be implemented.

CTA-N:  Changes that do not meet the criteria for a CTA-A, which may be implemented immediately, but Health Canada must be informed in writing, within 15 calendar days of the day of the change.

 

What is a Common Technical Document – CTD?


A common technical document is a globally harmonized Submission format that is accepted by many regions, in an effort to avoid the need to compile different registration dossiers for different regulatory authorities. The CTD format was adopted by Health Canada in 2003.

 

What is a Clinical Trial Site – CTS?


The location where clinical trial-related activities are conducted.

 

What is a Clinical Trial Site Information Form – CTSIF?


Form that is required to be completed and submitted to Health Canada by the sponsor or its representative for each clinical trial site, prior to commencement of the clinical trial or implementation of a Clinical Trial Application-Amendment, at that site.

 

What is a Drug Establishment License – DEL?


A drug establishment license is a license issued to a person in Canada allowing them to conduct licensable activities in a building which has been inspected and assessed as being in compliance with the requirements of the Food and Drug Regulations. Activities covered under a DEL are: fabrication, packaging, labelling, testing, importation, distribution or wholesaling. DEL applies for active pharmaceutical ingredients, finished dosage drugs or bulk process intermediates.

 

What is a Drug Identification Number – DIN?


A drug identification number is an eight (8) digit numerical code assigned to each drug product approved under the Food and Drugs Act and Regulations (except for Schedule C drugs – radiopharmaceuticals). A DIN identifies the following product characteristics: manufacturer, brand name, medicinal ingredient(s), strength of medicinal ingredient(s), pharmaceutical form, route of administration.

 

What is an Application for a DIN – DINA?


When a product is not subject to Division 8 of the Food and Drug Regulations, the application is called a DIN submission.

Note: Under the provisions of section C.01.014 of the Food and Drug Regulations, no manufacturer shall sell a drug in dosage form unless a drug identification number (DIN) has been assigned for that drug and the assignment of the number has not been cancelled pursuant to section C.01.014.6. In the case of a new drug, a new drug submission filed pursuant to Division 8 of the Food and Drug Regulations is regarded as an application for a DIN.

  • A DINB is an Application for a DIN specific to a Biologic Product.
  • A DIND is an Application for a DIN specific to a Disinfectant Product.
  • A DINF is an Application for a DIN specific to a Category IV Product.

 

What is the Food and Drug Act – FDA?


An Act respecting food, drugs, cosmetics and therapeutic devices.

 

What is are Food and Drug Regulations – FDR?


The legislation that oversees and sets out requirements for the manufacture, packaging, labelling, storage, importation, distribution and sale of foods, and prescription and non-prescription drugs in Canada. Requirements for drug clinical trials are also set out in the regulations. Health Canada develops and enforces regulations under Government of Canada legislation. The Department consults with the Canadian public, industry and other interested parties in the development of laws that protect health and safety. They also prepare guidelines and policies in order to help interpret and clarify the legislation surrounding drugs and health products. The purpose of the legislation is to protect the health and safety of Canadians with respect to the sales of food and drug products.

 

What is Good Clinical Practice – GCP?


Generally accepted clinical practices that are designed to ensure the protection of the rights, safety and well-being of clinical trial subjects and other persons, and the good clinical practices referred to in section C.05.010 of the Regulations.

 

What is Good Manufacturing Practices – GMP?


The part of quality assurance ensuring that drugs are consistently produced and controlled in such a way to meet the quality standards appropriate to their intended use, as required by the marketing authorization. Part of the Health Products and Food Branch Inspectorate (Inspectorate) program is to conduct inspections of establishments that are involved in activities covered by the Establishment Licensing framework.

 

What is Health Canada – HC?


Health Canada is the Federal department responsible for helping Canadians maintain and improve their health, while respecting individual choices and circumstances.

 

What is a Health Product – HP?


Health Products in Canada are products regulated under the Food and Drugs Regulations (drugs) and the Natural Health Products Regulations (natural health products). Drugs include both prescription and non-prescription pharmaceuticals; biotechnology products and biologically-derived products such as vaccines, serums, and blood derived products; disinfectants; and radiopharmaceuticals.  

 

What is the Health Product and Food Branch – HPFB?


The health product and food branch is a Health Canada Branch mandated to manage the health-related risks and benefits of health products and food by: 1) minimizing health risk factors to Canadians while maximizing the safety provided by the regulatory system for health products and food; 2) providing information to Canadians so they can make healthy, informed decisions about their health. The HPFB activities are carried out under various Directorates and Offices, including the Therapeutic Product Directorate, the Biologic and Genetic Therapies Directorate and the Marketed Health product Directorate.

 

What is the Health Product and Food Branch Inspectorate – HPFBI?


The health product and food branch inspectorate conducts inspections of establishments that are involved in activities covered by the Establishment Licensing framework. These inspections are conducted to verify the compliance with GMP (Part C, Division 2 of the Food and Drugs Regulations) which is a requirement for the issuance of an establishment licence.

 

What is Héma Québec – HQ?


Meets the needs of the Québec population for quality blood and other biological products of human origin.

 

What is Health Technology Assessment – HTA?


A health Technology assessment is the process followed to provide an evidenced based recommendation on whether a health technology merits being publicly funded.

 

What is an Investigator’s Brochure – IB?


An investigator’s brochure, in respect of a drug, is a document containing the nonclinical and clinical data on the drug that are described in section C.05.005(e) of the Regulations.

 

What is an Informed Consent Form – ICF?


An informed consent form is a document that describes: The risks and anticipated benefits to his or her health arising from participation in the clinical trial; and all other aspects of the clinical trial that are necessary for that person to make the decision to participate in the clinical trial.

 

What is the International Conference on Harmonization – ICH?


International initiative to harmonize efficacy, safety and quality (chemistry and manufacturing) requirements globally for the registration of drugs (pharmaceuticals, biologicals, genetic therapies, …) for human use. This initiative include standard information organization for new drug registration applications.

 

What is Institut national d’excellence en santé et en services sociaux – INESSS?


Quebec’s review process to evaluate therapeutic value and cost-effectiveness of oncology and non-oncology drugs. INESSS issues a recommendation to Quebec’s Minister of Health and Social Services as to whether or not a drug should be publicly funded for patients who need access

 

What is an Investigational Testing Application – ITA?


The equivalent of a CTA but for a Medical Device.

 

What is a Marketing Authorization Holder – MAH?


A marketing authorization holder is the entity that holds the Notice of Compliance, the Drug Identification Number (DIN), the Natural Product Number (NPN), the Homeopathic Medicine Number (DIN-HM), or the product license.

 

What is a Medical device License Application – MDLA?


A medical device license application is equivalent to a CTA but for Investigating the efficacy and safety of a Medical Device.

 

What is a Master File – MF


A master file, formerly known as Drug Master File is a reference that provides information about specific processes or components used in the manufacturing, processing, or packaging of a drug. The MF is a useful vehicle for providing information to Health Canada, where that information is of a proprietary nature [i.e., confidential business information] and is not available to the manufacturer of the dosage form or to the sponsors of a drug submission or clinical trial application (also referred to as the applicants).

 

What is a New Active Substance – NAS?


A new active substance is a chemical or biological substance not previously authorized for sale in Canada as a drug;

  • Isomer, derivative or salt of a chemical substance previously authorized for sale as a drug in Canada, but differing in properties with regard to safety and efficacy;
  • Biological substance previously authorized for sale in Canada as a drug, but differing in molecular structure, nature of the source material or manufacturing process.

 

What is a Notifiable Change – NC?


Notifiable changes are Level II Changes and are classified either as:

Moderate Quality Changes (chemistry and manufacturing) which have a moderate potential to have an adverse effect on the identity, strength, quality, purity, or potency of the drug product as these factors may relate to the safety or effectiveness of the drug product. This level of change does not apply to Human Pharmaceuticals.

Risk Management Change (clinical) defined as a change to the label that has the potential to improve the management of risk to the population currently indicated for use of, or in any other way exposed to the drug. These changes are classified as either 90-day review changes (more urgent changes) or 120-day review changes.

 

What is a New Drug Submission – NDS?


A new drug submission is a regulatory dossier that needs to be submitted and approved by Health Canada for a manufacturer to be granted authorizations to sell a new drug (i.e. pharmaceutical, biologic, vaccine, biotechnology product). This dossier typically requires complete Pre-clinical, Clinical and Chemistry and Manufacturing (Quality) package. Specific requirements may differ depending on the drug type, the pathology treated, the aimed patient population, amongst other elements.

 

What is a Natural Health Product – NHP?


A substance set out in Schedule 1 of the Natural Health Products Regulations or a combination of substances in which all the medicinal ingredients are substances set out in Schedule 1 of the Natural Health Products Regulations, a homeopathic medicine or a traditional medicine.

 

What is a Notice of Compliance – NOC?


A notice of compliance is a notification issued by Health Canada indicating that a manufacturer has complied with the requirements of the Food and Drug Regulations at the end of the review of an NDS, ANDS, S/NDS or S/ANDS.

 

What is a Notice of Compliance with Conditions Qualifying Notice -NOC/c-QN?


A notice of compliance with conditions qualifying notice is a notification issued by the Director of the responsible reviewing Bureau/Centre upon completion of a review, should a submission be determined to qualify for further consideration under the NOC/c policy. The NOC/c – QN will indicate that the submission qualifies for a NOC, under the NOC/c policy, as well as outline the additional clinical evidence to be provided in confirmatory studies, post-market surveillance responsibilities and any requirements related to advertising, labeling, or distribution. Submission review will cease upon issuance of the Qualifying Notice.

This applies to products that has promising evidence of clinical effectiveness with acceptable safety profile intended for the treatment, prevention or diagnosis of a serious, life-threatening or severely debilitating disease or condition for which there is no existing therapy available in Canada which possesses  a similar therapeutic profile or for which the new drug submission demonstrates a significant improvement in the benefit/risk profile over the available alternative product.

 

What is a Notice of Deficiency – NOD?


A notice of deficiency is a notice issued if deficiencies and/or significant omissions that preclude continuing the review are identified during the review of a submission.

 

What is a No Objection Letter – NOL?


A no objection letter is a letter emitted by Health Canada after the review of a Clinical Trial Application or a Notifiable Change, if the application is deemed acceptable to them. It confirms that a sponsor can proceed with its Clinical Trial in Canada or can implement the changes presented in the Notifiable Change.

 

What is a Notice of Non Compliance – NON?


A notice of non compliance is a notice issued after the comprehensive review of a submission is complete, if the submission is deficient or incomplete in complying with the requirements outlined in the Food and Drugs Act and Regulations.

 

Not Satisfactory Notice –

NSN


A notice issued by the Director of the responsible reviewing Bureau/Centre if deficiencies are identified during the review of a Clinical Trial Application, Clinical Trial Application-Amendment or Notifiable Change. The deficiencies will be specified and review of the submission will stop on the date of the Not Satisfactory Notice.

 

Pharmaceutical Advertising Advisory Board –

PAAB


An independent and not-for-profit organization funded on a fee-for-service basis. It is the only regulator whose preclearance service is recognized by Health Canada for advertising directed to healthcare professionals. PAAB works to protect Canadians by ensuring that healthcare product advertising meets the regulatory, scientific, therapeutic, and ethical standards outlined in the Code of Advertising Acceptance. All PAAB approved materials bear the PAAB logo.

 

Periodic Benefit Risk Evaluation Report –

PBRER


A pharmacovigilance document intended to provide a comprehensive, concise, and critical analysis of new or emerging information on the risks of the health product, and on its benefit in approved indications, to enable an appraisal of the product’s overall benefit-risk profile. The current ICH guidance ensures that PSURs for marketed drugs have the role of being periodic benefit-risk evaluation reports by covering: Safety evaluation, evaluation of all relevant available information accessible to sponsors/MAHs and benefit-risk evaluation.

 

pan-Canadian Pharmaceutical Alliance –

pCPA


National mechanism designed to achieve greater value for government drug plans. pCPA negotiates with a drug company to determine both the cost and criteria under which governments will pay for a medication, concluding with a Letter of Intent to fund the drug.

 

Patented Medicine Price Review Board –

PMPRB


A board that protects and informs Canadian consumers by ensuring that the prices of patented medicines sold in Canada are not excessive, and by reporting on pharmaceutical trends.

 

Priority Review –

PR


A status granted by Health Canada to an NDS or an SNDS for a serious, life-threatening or severely debilitating disease of condition for which there is substantial evidence of clinical effectiveness that the drug provides: 1) effective treatment, prevention or diagnosis of a disease or condition for which no drug is presently marketed in Canada; or 2) a significant increase in efficacy and/or a significant decrease in risk such that the overall benefit/risk profile is improved over existing therapies, preventatives or diagnostic agents for a disease or condition that is not adequately managed by a drug marketed in Canada.

 

Protocol Safety and Efficacy Assessment Template – Clinical Trial Application –

PSEAT-CTA 


A protocol summary to be prepared and submitted within the CTA. The summary is expected to contain: protocol identification, background and rationale, trial objectives, study design and duration, total number of sites (including number of Canadian sites), investigators, sample size, patient population, inclusion & exclusion criteria, drug formulation, dosage regimen, washout period, screening & baseline evaluation, treatment & assessment visits, concomitant & rescue medication, risk management, withdrawal/discontinuation criteria, efficacy & safety variables and analysis, statistical analysis.

PSUR – Periodic Safety Update Report
Mechanism for summarizing interval safety data, and for conducting an overall safety evaluation. It is a tool for sponsors to conduct systematic analyses of safety data on a regular basis. In addition to covering ongoing safety issues, the PSUR should also include updates on emerging and/or urgent safety issues, and major signal detection and evaluation that are addressed in other documents.

 

Qualified Health Care Professional – QHCP


A person who is a member in good standing of a professional medical, nursing, pharmacists’ or other health care practitioner association and entitled to provide health care under the laws of the jurisdiction in which the person is located, and other individuals retained by the Marketing Authorization Holder who have the appropriate health care education and therapeutic expertise.

 

Qualified Investigator


The person responsible to the sponsor for the conduct of the clinical trial at the clinical trial site, who is entitled to provide health care under the laws of the province where that clinical trial site is located.

 

Qualified Investigator Undertaking


The undertaking that must be completed by the qualified investigator responsible for the conduct of the clinical trial at the clinical site and retained by the clinical trial sponsor for a period of 25 years. This undertaking should not be submitted to Health Canada unless requested.

 

Quality Overall Summary – QOS


Summary template that follows the scope and the outline of the Quality Body of Data (of CTD Module 3.2). Specific QOS templates exists for Clinical Trial Applications Phases I, II & III; for Bioavailability studies and for DIN applications. The QOS for new chemical entities is presented below.

 

Quality Overall Summary – Chemical Entities (CTA) – QOS-CE


Summary template that follows the scope and the outline of the Quality Body of Data (of CTD Module 3.2). This template can be used by sponsors to summarize the Quality information for New Drug Submissions (NDSs) and Abbreviated New Drug Submissions (ANDSs) containing drug substances and their corresponding products of synthetic or semi-synthetic origin that are filed with Health Canada pursuant to Part C, Division 8 of the Food and Drug Regulations.

This would exclude submissions for Biotechnological/Biological (Schedule D) and Radiopharmaceutical (Schedule C) drugs. Nonetheless in reality, the referenced QOS-CE is used to summarize the Quality information for Schedule D New Drug Submissions (NDSs); sections of the template are then bonified with the requirements of the Schedule D NDS guidance. A Quality Information Summary (QIS) is available for radiopharmaceuticals, upon request from Health Canada.

 

Research Ethics Board – REB


A body that is not affiliated with the sponsor, mandated to approve the initiation of, and conduct periodic reviews of, biomedical research involving human subjects in order to ensure the protection of their rights, safety and well-being. The body needs at least five members, that are in majority Canadian citizens or permanent residents under the Immigration Act, and composed of both men and women. Additional criteria apply.

 

Risk Minimization Activity


Risk minimization activities are interventions intended to prevent or reduce the occurrence of adverse reactions associated with the exposure to a medicine, or to reduce their severity or impact on the patient should adverse reactions occur. These measures may include warnings in the label or minimization activities beyond routine, such as health care provider educational material.

 

Risk Management Plan


A document that describes a set of pharmacovigilance activities and interventions designed to identify, characterize, prevent or minimize risks related to drug products, and the assessment of the effectiveness of those interventions (adopted from the European Medicines Agency definition of a Risk Management System).

 

Supplemental Abbreviated New Drug Submission – S/ANDS


Same as for a S/NDS presented below but for generic products.

 

Supplemental New Drug Application – S/NDS


Submission required for Level I Quality or Safety & Efficacy (Clinical) Changes that have a substantial potential to have an adverse effect on the identity, strength, quality, purity, or potency of a drug product as these factors may relate to the safety or effectiveness of the drug product or a change to the label of a drug that has the potential to increase the exposure levels of the drug, either by expanding the population that is exposed, or by increasing individual exposure.

 

Special Access Program


Program that allows access to nonmarketed drugs for practitioners treating patients with serious or life-threatening conditions when conventional therapies have failed, are unsuitable, or unavailable. The SAP authorizes a manufacturer to sell a drug that cannot otherwise be sold or distributed in Canada. Drugs considered for release by the SAP include pharmaceutical, biologic, and radio-pharmaceutical products not approved for sale in Canada.

 

Serious Adverse Drug Reaction – SADR


An adverse drug reaction that requires in-patient hospitalization or prolongation of existing hospitalization, that causes congenital malformation, that results in persistent or significant disability or incapacity, that is life threatening or that results in death.

 

Serious Adverse Reaction


A noxious and unintended response to a natural health product that occurs at any dose and that requires in-patient hospitalization or a prolongation of existing hospitalization, that causes congenital malformation, that results in persistent or significant disability or incapacity, that is life threatening or that results in death.

 

Senior Executive Officer


The most senior person with policy and operational decision making authority within the sponsor, or is an official who has this delegated authority in respect of a clinical trial.  The SEO is responsible for providing an attestation with respect to the Clinical Trial Application/Amendment at the time of filing the CTA to Health Canada.

 

Serious Unexpected Adverse Drug Reaction – SUADR


A serious adverse drug reaction that is not identified in nature, severity or frequency in the risk information set out in the investigator’s brochure or on the label of the drug.

 

Therapeutic Products Directorate

Canada’s regulator of prescription drugs and medical devices for human use. Before giving permission to sell a product, the directorate must see scientific evidence of the product’s safety, effectiveness, and quality, as required by the Food and Drugs Act and Regulations.

 

Yearly Biologic Product Report – YBPR


A report that must be submitted annually by manufacturers of all Schedule D (Biologic) drugs in accordance with Guidance for Sponsors: Lot Release Program for Schedule D (Biologics) Drugs. The report contains production information on both drug substance and drug product lots, including test methods and results, reasons for any recalls and corrective action taken, as well as other pertinent post-market information.

Celebrating 25 year anniversary in Regulatory Affairs

Press release celebrating 25 year anniversary in Regulatory Affairs. SPharm – Canada’s Drug Regulatory Experts.

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