Regulatory and Timeline Advantages for Early Clinical Research in The Netherlands
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Transcript of Regulatory and Timeline Advantages for Early Clinical Research in The Netherlands
Izaak den Daas PhDPrincipal Scientist QPS Netherlands BV
Regulatory and Timeline Advantages for Early Clinical Research in
The Netherlands
16 October 2013 Confidential 1
Location of Clinical Studies: Global
Source: www.ClinicalTrials.gov
10/16/2013 Confidential 2
Location of Clinical Studies: Europe
Source: www.ClinicalTrials.gov10/16/2013 Confidential 3
Facts of The Netherlands
Population: 16,805,037
Ethnicity:
Dutch 80.7%,
EU 5%,
Indonesian 2.4%,
Surinamese 2%,
Caribbean 0.8%,
Turkish 2.2%,
Moroccan 2%,
other 4.8%
Gross Domestic Product:
$718.6 billion (ranking 24 in the world)
per capita: $42,900
Ecellent health system
Excellent academic and technology system
10/16/2013 Confidential 4
Source: www.CIA.gov
Phase 1 CPUs in Western Europe
10/16/2013
QPS Netherlands BV
Biotech Center
Phase I clinic (34 beds)
Screening & Recruitment
Isotope lab
The Villa & Cascade building
Offices
Central Pharmacy
Bioanalytical Laboratories
University Medical Center Groningen
Centre of Innovations :
Phase I clinic (24 beds)
Trial Submission in The Netherlands
16 October 2013 Confidential 7
Obtaining EC and HA approval in NL
10/16/2013 Confidential 8
Parallel submission to Health Authority (CCMO) and local Ethics Committee (EC) resulting in Clinical Trial Approval within 14 days!
Substantial amendments: 48h turnaround time
CTA will be prepared and submitted by QPS
Two EC meetings per month (every 1st and 3rd Tuesday); Submission 11 days before meeting
1 day before the meeting our PI receives a memo with the questions from the pre-advisors of the EC; these questions can be answered by the PI during the EC meeting
The PI will join the meeting for answering questions, but will off course not attend the voting process
CCMO will perform a so called marginal test (check of Eudravigilence and completeness of CTA); no questions will be raised; approval within 14 days as well
From past experience 3 (proof of principal studies: CSF sampling; dry blood spot and continuous CSF) out of 105 studies were not approved in the 1st review round.
Independent foundation BEBO Assen
2 committees meeting every 2 weeks
Main task is to judge the acceptable exposure of healthy subject or patient
Review time 10 days resulting in pre-advise before EC meeting
Advise before start study possible
Interim reporting between dosing evaluated by the chairman
Also for radio-active studies
Independent EC
The EC is also the only IRB of the study submission
10/16/2013 Confidential 9
Project Time-Lines
Start-up (incl. CSP writing)
CTA submission
ApprovalClinicalphase
DB lock
(after LPLV)
Tables, graphs and
listings
First draft CSR
4 weeks 2 weeks varies 1 week 3 weeks 3 weeks
Documentation needed
10/16/2013 Confidential 11
Submission documents as part of the Clinical Trial Application are:
Clinical Trial Protocol (CTP)
Investigator’s Brochure (IB)
Investigational Medical Product Dossier (IMPD)
Informed Consent Form (ICF)
IMPD + IB = IND
GMP in EU – Clinical Trials
16 October 2013 Confidential 12
Pharmacy
GMP-compliant Pharmacy
Clinical Trial PharmacistPharmacy TechniciansManufacturer’s License for Investigational Medical ProductsAseptic production facilities
10/16/2013 Confidential 13
Guidelines
Applicable guideline:
EudraLex Volume 4 Good Manufacturing Practice (GMP) guidelines:
Annex 13: typical chaptersProduct Specification FileProduction
Manufacturing operations
Principles applicable to comparator product
Blinding
Randomisation
Packaging (Packed in individual way for each subject)
Labelling (in Dutch)
Release of batches
Labelling
Name, address and telephone number of the sponsor, CRO or PIPharmaceutical dosage form, route of administration, quantity of dosage unitsBatchnumberTrial reference codeTrial subject identification numberDirections for use“For clinical trial use only” or similar wordingStorage conditionsPeriod of use (use-by date, expiry date)“Keep out of reach of children”
Release of batches
Release of investigational medicinal products by QualifiedPerson (QP)Duties of Qualified Person affected by different circumstances
Product manufactured within EU but not subject to an EU marketing authorisation
Product sourced from the open market within EU and subject to an EU marketing authorisation
Product imported directly from a 3rd country (including US(!))
At QPS the QP is the clinical trial pharmacist. He is there to help the sponsor with all local procedures needed for a successfull clinicaldrug study
Production process flow
Receipt
Quarantaine
Releasedbulk
product
CoABatch ReleaseIMPDCCMO/METc
IMP Receiptform
Bulk product IMP
• Storage in temperature
controlled / monitored area
• Release based on
documentation and product
• QP or CTP involvement
• Release criteria for bulk
product depends on origin
and market authorization y/n
• Identification forms
• Invoice
• Approved supplier
• IB/IMPD
• Approval METc / CCMO
• CoA
• Release certificate
• GMP conformanceProduction
Production process flow
Draft label specification
Final label specification
Labels
Labels forproduction
ProductionLabel reconciliation
• Labelspecification issued on
basis of clinical protocol
• QA involvement
• Sponsor representative
involvement if desired
Production process flow
Draft production
protocol
FinalProduction
protocol
Production Protocol
Production
• Production protocol issued
on basis of clinical protocol /
study operation manual /
TQA / other
• QA involvement
• Sponsor representative
involvement if desired
Protocol forproduction
Production process flow
Release of product
• Release on basis of
• Product
• Labels
• Production protocol
• Analysis of product
(optional)
• Release by QP or
Pharmacist
Protocol forproduction
Label reconciliation
Product
Analysis of product
CoA and release certificate of product
ReleasedProduct
Administration
Radioactive Studies in
The Netherlands
16 October 2013 Confidential 21
Human Mass Balance Studies with radiolabelled IMP
Objectives
To determine the rate and extent of excretion of total radioactivity
To evaluate the extent of absorption of radioactivity after dosing
To examine the blood and plasma concentration profiles of total radioactivity
Metabolite identification and profiling
GCP
Samples – urine, feces, blood, plasma, expired air
Timelines:
Clinical Protocol Approval – 2 weeks
Total Radioactivity Recovery Results – 3 to 4 weeks
Metabolite Identification and Profiling Results – 3 to 4 months
Human Mass Balance Study
Dosing low doses of radiolabeled test article to healthy subjects or patients
Objectives
To assess absolute bioavailability
To study pharmacokinetic profile in sub therapeutic level
To examine the blood and plasma concentration profiles of total radioactivity
Metabolite identification and profiling
GCP
Samples – urine, feces, blood, plasma, expired air
Timelines:
Clinical Protocol Approval – 2 weeks
Accelerated mass spectrometry (AMS) Results – 6 to 8 weeks
Micro Dose Studies
Functions Involved – Roles & Responsibilities
Functions Physical location/affiliation Roles & Responsibilities
Radio Synthesis Selcia Ltd., Ongar Essex UK GMP Preparation of 14 labeled API
Radio Pharmacy Radio pharmacy of the UMCG (contract between QPS and UMCG)
Receipt and Release of 14C-labeled APIIndividual Drug Preparation of 14C-labeled IMPReturn and/or Destruction of 14C-labeled IMP
Clinical Trial Pharmacy Clinical Trial Pharmacy of QPS Transport of 14C-labeled IMPPreparation of Individual Drug Preparation FormPreparation of Label Specifications according to GMP Annex 13
Clinical Pharmacology Unit Clinical Pharmacology Unit of QPS
Drug Administration of 14C-labeled IMPSample Collection and Processing of Radioactive Human Excreta (blood, urine, feces and expired air)
AMS Laboratory TNO, Zeist The Netherlands Measurement of the 14C-Radioactivity using accelerated mass spectrometry
Biometrics Biometrics Department of QPS Determination of the total 14C-Radioactivity Recovery Rate
Ethics Committee & Competent Authority Submission
The application process for a radioactive phase I trial in the Netherlands is essentially the same as for any other non-radioactive phase I trial
Written EC and CA approval is routinely obtained within 14 days after submission of the Clinical Trial Application (CTA).
Submission documents as part of the Clinical Trial Application are:
o Clinical Trial Protocol (CTP)
o Investigator’s Brochure (IB)
o Investigational Medical Product Dossier (IMPD)
o Informed Consent Form (ICF)
o Human Dosimetry Calculation, Not required for Micro Dose
QPS has a standard set of calculations, which are based on MIRD and ICRP recommendations to determine human radiation dosimetry estimates
Drug Administration of 14C-labeled IMP
Compounding from API to IMP at QPS Pharmacy
Drug administration of the 14C-labeled study medication is always done in the presence of an authorized user (PI or a designated Research Physician).
Circumstances are again essentially the same as for any other non-radioactive phase I trial.
Additional hygienic measures are used to prevent radioactive contamination of the CPU.
Collection, Sample Processing and Transport of Radioactive Human Excreta
All necessary steps to ensure sample integrity (experience gained from preclinical studies) will be taken from sample collection, sample processing, storage, and shipping.
Collection of blood, urine, feces and expired air takes place in the CPU.
Sample processing of collected blood, urine and expired air samples takes place in the CPU as well.
For non Micro-dose StudiesSample processing (i.e. homogenization and aliquoting) of collected feces samples takes place in the radionuclide laboratory.
The volunteers are discharged from the clinic after at least 85 % (or more if the study protocol requires to do so) of the total dose of radioactivity has been recovered in the excreta from the volunteer.
Measurement of the 14C-Radioactivity in Human Excreta
Not for micro-dose studies
All necessary sample pretreatments after the samples have been processed and aliquoted until the measurement of 14C-radioactivity, are done by laboratory technicians from the radionuclide laboratory who are trained by in GLP and the particular Assays Instruction(s) as required by the Bioanalytical Protocol of the concerned study.
The measurement of 14C-radioactivity in human study samples is performed on a beta-counter (Tricarb 2500) in the radionuclide laboratory. Feces combusted in Oxidizer.
Publication of Clinical Studies
EMA regulations for clinical studies endorse the publications of results
Particularly if there are side effects found which are important for public health
Scientific relevant results published in agreement with sponsor
Sponsor has influence on timelines but can not withhold
QPS will only publish in full collaboration with sponsor
16-10-2013 29
Thank you for your
attention!