Hey friends,
In today’s blog I
want to share my thoughts on what skill sets are required to excel in this
profession. I call it as - THE REGULATORY MANTRA. Well basically these
are few good practises which you should adopt, throughout your life, as RA
professionals. These skill sets are good differentiators and the one who excels
in these get recognized as a good RA professional. It will make you much more
effective in delivering RA roles and responsibilities.
Mantra 1: Your aim is to ensure the safety,
efficacy and quality of the drug for which you are seeking an approval or a marketing
license.
Now if this is
your mantra, obviously you must understand what safety, efficacy and quality of
drug means. Thankfully, there is an ICH (International Council for
Harmonisation of Technical Requirements. Follow link : https://www.ich.org/home.html
The International
Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human
Use (ICH) is unique in bringing together the regulatory authorities and the pharmaceutical
industry to discuss the scientific and technical aspects of drug registration.
They have issued
guidelines which is accepted worldwide and can be accessed on https://www.ich.org/products/guidelines.html
The ICH topics are
divided into four categories: Quality, Safety, Efficacy and Multidisciplinary
and it serves as a good starting point to understand all critical technical
aspects about drug.
Now let me add a
word of caution - trying to understand so many guidelines in first go
would be very intimidating. If you are accessing this site for the first time,
the big question would be - where do I begin? According to me, it will depend
on what you want to pursue. Are you going to be majorly involved in clinical
trial submissions, then safety and efficacy guidelines are good to begin with.
If you are intending to become a CMC (chemistry, manufacturing, control)
specialist then quality guidelines is a right start for you to understand the
requirements in greater depth and detail.
Apart from ICH,
there are WHO (World Health Organization) guidelines which can be also be
referred to. It is important to note that apart for these guidelines, every
country issues their own technical guidelines that are adopted from
ICH/WHO.
Mantra 2: Respect the law of the land and comply to it.
What does this
mean? It simply means that whenever your firm decides on a target market for
selling a pharmaceutical product, you have to ensure that you have read the
rules, regulation and guidelines of that specific country, understand it
thoroughly and interpret it in the right manner. The next step would be to
share with your firms’ internal key stakeholders, an exact list of
requirements. As already specified, every country has their own set of specific
requirements even if they are adopting ICH or WHO guidelines. So, it is prudent
for the RA person to understand these differences and highlight the needs
upfront so that the development, manufacturing, and marketing strategy is
designed appropriately and data generated is accepted in these markets without
many queries leading to faster approvals and faster entry to market.
Mantra 3:
Maintain your knowledge base by upgrading it from time to time.
Keep abreast with
all latest news on technology and keep track of changing laws, rules and
regulations worldwide. This can be done easily by just signing up for email
updates. As an example I have shared a link of CDER, FDA guidance documents.
If you click on
this link and go down the page there is a provision given for signing up for
guidance email updates. Similarly, you can sign up for updates from EU or any
other health authorities.
Mantra 4:
Network, Network and Network.
Networking is
extremely essential for the flow of information and sharing of experience. So associating
with regulatory groups on LinkedIn or attending seminars and conferences is a
good way to connect with industry colleagues. Creating or joining Regulatory professionals’
group on WhatsApp is another good platform to share knowledge and experience.
Mantra 5: Work on principle of providing just enough information or data –
not less and not more.
I have realized
through my years of experience that in this function ‘more is not merrier’. We
are dealing with health regulators who receive applications from all over the
world and they work on deadlines just like us. Completing the review and
granting us approval on time is their mission. If our content is not well
researched, well written, crisp and clear it will take them longer to
understand and they may have to come back to us with lot of queries for
additional clarifications. That’s precisely the reason why they have provided
so many guidelines upfront. Through these guidelines the regulators are sharing
their expectations upfront. Please learn the art of providing crisp information
and provide only that specific information without beating around the bush. It
is highly encouraged and appreciated by health authorities.
Mantra 6: Work
on principle of RFT (right first time).
This can be
achieved only if you are able to apply scientific & regulatory principles
from the stage when a drug is being shortlisted for development and by
proactive planning and execution. Preparing a detailed checklist and sharing
with each function is a good way of ensuring that the requirements have been
communicated right at the outset without missing any critical elements.
Conducting training sessions regularly also ensures that your knowledge about
any guidelines is transferred across the firm.
While evaluating
any data received with respect to a product from any function like R&D,
Manufacturing, Clinical, etc the top three questions that should come into your
mind are :
1. Whether all the data generated has been on the basis of scientific
principles(wherever applicable),
2. Have all the requirements mentioned in the
guidelines been met and
3. Are all final data authentic and well supported by
raw data. If not, is there a sound scientific justification to it which can be
explained to the regulators.
Anticipating the
questions from regulators and providing data upfront to avoid queries while
review of any application is something a RA personnel develops over the years
based on the experience gained during interactions with health authorities.
According to me,
this can also be acquired by going through case studies or queries received on
other products that have been evaluated by these authorities. Authorities like
FDA and EMEA post the summary of drug approval on their websites. Going through
these data packages helps to understand the review process and queries raised
on earlier submissions. Many health authorities, if not all, often conduct
seminars, conferences and training sessions primarily to share the updates,
concerns and expectations from the industry. Attend these or look for the
presentations and recorded sessions which are posted on their websites within
few days of these conferences being held. It’s the best learning platform for
all RA professionals. As an example, I am sharing the link from FDA site which
provides information on training sessions conducted by FDA from time to time.
Its called CDER SBIA Learn : Webinars, Conferences, Trainings & Upcoming
Events. Follow link : https://www.fda.gov/drugs/cder-small-business-industry-assistance-sbia/cder-sbia-learn-webinars-conferences-trainings-upcoming-events
Mantra 7: Always keep a tab of regulatory commitments and post
approval changes.
Most dossiers
would provide commitments to submit data during the lifecycle management of the
product post approval. In this era of continuous improvement there will be
changes affected due to adopting better and newer technology. There is also a
continuous need to keep costs under control, which will involve changes such as
shifting to an alternate source of material used in the product. All these
changes will lead to changes in the registered information/data set. RA
professional should be at the centre of managing all post approval changes and
updating health authorities by choosing the correct regulatory pathway, as and
when the changes need to be implemented. So it is prudent to keep track, as
missing to inform can have consequences. One of the ways this can be
effectively managed is by maintaining a product history file which is a live
document and captures the critical information, commitments and changes with
respect to a product.
Mantra 8: Always be audit ready.
Pharmaceutical
firms regularly come under the scrutiny and are audited by health authorities.
Regulatory professional participate in such quality audits of the manufacturing
facility and hence should securely maintain archives and repository of all data
provided to health authorities. A good document management system can be used
to track, manage and store documents.
Mantra 9: Possess good IT skills.
In today’s digital
era, good IT skills are must for almost all functions in any industry and more
so in regulatory affairs as many health authorities around the globe have
adopted paperless submission strategy and have their own set of requirements
for providing e-submissions (electronic submissions) through their secured
gateway or portal. Expertise in doing e-submissions can be achieved by way of
on job training. But basic knowledge about word, excel and powerpoint is a must
for entry into this function.
Mantra 10:
Develop good stakeholder management and negotiation skills.
RA professional
compiles data coming from R&D, Manufacturing, Packaging, Supply chain,
Quality Assurance, Quality Control, Validation, Project management, Business
Development, Labelling, Clinical/Bioequivalence teams. A good RA person needs
to balance the objective of regulatory as well as of different functions and
still manage to get data on time and in compliance. Good RA professionals
understands the position of stakeholders while sharing their priorities and
ensures a win-win situation for both. That’s perfect negotiation skill!!
In my future blog
I will share, through a case study, how systematic planning and proactive
approach will help us in achieving timely submissions. See you soon!!