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eCTD. An overview of the full day presentation by Dr Olaf Schoepke at the SAAPI conference in July 2008. Overview. History Why go electronic? Types of electronic submissions What eCTD consists of Preparing eCTD Eye openers and bombshells Conclusion. eSubmissions history.
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eCTD An overview of the full day presentation by Dr Olaf Schoepke at the SAAPI conference in July 2008 SAPRAA 5 Sept 2008
Overview • History • Why go electronic? • Types of electronic submissions • What eCTD consists of • Preparing eCTD • Eye openers and bombshells • Conclusion SAPRAA 5 Sept 2008
eSubmissions history • Began in late 80’s but insufficient IT capabilities • 1995 FDA used PDF files with hyperlinks • 1997 CTD topic of ICH4 • 2001 first eCTD guideline • 2003 CTD mandatory in EU and first eCTDs submitted • 2006 lifecycle management a challenge SAPRAA 5 Sept 2008
The future in EMEA • July 2008 – only electronic submissions accepted (either eCTD or non-eCTD) • July 2009 – strongly recommend only eCTD format electronic submissions to be accepted. Paper and other electronic formats to be exception. SAPRAA 5 Sept 2008
Why go electronic? • Quality • Better quality • Entire life cycle of product covered • Easy and rapid call up of information • Costs • Paper and transportation costs reduced • Storage and archive requirements reduced • Faster, more efficient review, quicker registration • Environmentally responsible SAPRAA 5 Sept 2008
Save a tree!! • NCE is approx 240,000 pages Paper for this would be 672 kg Equivalent to ONE average tree AN ENTIRE TREE IS REQUIRED TO SUBMIT A SINGLE COPY OF THE APPLICATION FORM ONE APPLICANT TO ONE HEALTH AUTHORITY SAPRAA 5 Sept 2008
Types of electronic submissions • NeeS format (Non eCTD electronic submission) • Scanned version of paper submission without backbone etc. • eCTD • Documents in ‘intelligent’ PDF, JPG or GIF format, with folder or tree structures and XML backbone SAPRAA 5 Sept 2008
What does eCTD consist of? • Folder or tree structure • XML backbone file is Table of Contents • Additional ‘util’ information (Document type definition – rule book for tags and attributes) • Regional information and files SAPRAA 5 Sept 2008
Folder Structure Sections with specific information in folder names SAPRAA 5 Sept 2008
Preparing documents Templates should be used where possible Documents to be: • technically correct • have the right granularity • conform to external regulations/guidelines • consistent with internal standards and styles – naming conventions, etc. • ‘intelligent’ PDF files SAPRAA 5 Sept 2008
SAPRAA 5 Sept 2008 From eCTD Fundamentals Dr O Schoepke
Granularity • Defines how the completed document is broken down, tagged and stored for reuse • Determines smallest piece of information that is reusable • Changing granularity during lifecycle is difficult, therefore must be planned at the beginning. • FDA Guidance • Each document should be provided as a separate file SAPRAA 5 Sept 2008
‘intelligent’ PDF files • A file converted to special PDF format enabling links and bookmarks to be applied, and hence is searchable. SAPRAA 5 Sept 2008
Cross referencing documents • Intradocument links – bookmarks • Most intradocument links can be automatically set using templates • To set each link manually would take MANY hours • Interdocument links • Cross reference documents in context of other documents. SAPRAA 5 Sept 2008
Cross referencing submissions • Inter submission links • Cross references of submissions in context of other submissions, e.g. variations. SAPRAA 5 Sept 2008
Time frames • Once all documents are written, checked and formatted setting bookmarks and links take from 2 to 12 weeks. SAPRAA 5 Sept 2008
Eye openers • Global application • Life cycle history easily accessible • Ease of compilation and review once system is up and running • Intersubmission checks made possible by both applicant and reviewer • Authenticity of documentation easy to verify. SAPRAA 5 Sept 2008
Bombshells • Extensive software programme needed to support the system • Software programme used in EU costs €20,000 per USER (over R200,000 per user) • Extensive IT support needed by applicant and regulator SAPRAA 5 Sept 2008
Conclusion • Great idea but need intermediate steps to get there • CTD format to be adopted immediately • NeeS in interim • Essential to join electronic bandwagon SAPRAA 5 Sept 2008