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Management of Product Licence Applications for Natural Health Products -Attestations-

Learn about the process of submitting a Product Licence Application (PLA) for natural health products, including the importance of attesting to NNHPD monographs. Understand when monograph conditions are not required and how to navigate post-licensing audits.

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Management of Product Licence Applications for Natural Health Products -Attestations-

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  1. Management of Product Licence Applications for Natural Health Products -Attestations- Natural and Non-prescription Health Products Directorate (NNHPD) Winter 2017

  2. Table of Contents Slides 3 - 5: Before Submitting a Product Licence Application (PLA) Slides 6 - 12: Attestation to NNHPD Monographs Slides 13 - 15: When Are Monograph Conditions Not Required? Slides 16 - 17: Post Licensing Audit Slide 18: References

  3. Before Submitting a Product Licence Application (PLA)

  4. All medicinal and non-medicinal ingredients must be present and compliant with the Natural HealthProductsIngredientsDatabase • Applicants are encouraged to: • Use the latest Electronic Product Licence Application (ePLA) • Use the NHP Online eSubmissionBuilder (eSB) to create electronic submission packages • Enrol as a Trading Partner to use NNHPD’s chosen secure communication service: epostConnectTM • New applications must be sent to the “new applications” conversation • All applications must have a unique ePLA tracking number Before Submitting a PLA

  5. For all PLAs and amendments, the cover letter must indicate whether the application is Class I, II or III; applicants will be notified for any applications they identified as Class II that are shifted to Class III Before Submitting a PLA • Applicants must notify the NNHPD prior to submitting a large volume of applications at one time in order for the NNHPD to work with the applicant to develop a plan for processing and assessing applications within the service standards

  6. Attestation to NNHPD Monographs

  7. All Class I, II and III PLAs and amendments containing one or more ingredient(s) supported by NNHPD monograph(s) for safety, efficacy and/or quality are required to submit a Monograph Attestation The Monograph Attestation is embedded in the ePLA for certain application types or as a standalone form online The attestation is confirmation from the applicant that their product complies with the identified monograph parameters Attestation to NNHPD Monographs

  8. Overview of attestation conditions, whereby applicants attest: That the monograph parameters [proper name, common name, source material, route of administration, dosage form, use or purpose, dose, duration of use, risk information, etc.] are met; That the non-medicinal ingredients fully comply with the Natural Health Product Ingredients Database (NHPID); That the label text is acceptable as per sections 86-94 of the Natural Health Products Regulations; That the brand name is not false or misleading; and The selling of the product is within the conditions of the attestation and terms of market authorisation (product licence). Attestation to NNHPD Monographs

  9. For products supported by a combination of both monographs and evidence provided in the application package: Check the second box on the attestation form (seen below) Complete the table on page two to indicate which medicinal ingredients meet an NNHPD monograph in support of safety, efficacy and/or quality Ensure evidence is provided for all non-attested components Attestation to NNHPD Monographs • For products fully supported by one or more NNHPD monographs: • Check the first box on the attestation form (seen below) • Do not complete the table on page two Sample of the Monograph Attestation Form for products supported by a combination of both monographs and evidence. See Slide 18 for form website address.

  10. To attest to safety: all monograph parameters except minimum daily dose and recommended use/purpose (i.e. claim) must be met To attest to efficacy: monograph parameters of source, minimum daily dose and recommended use/purpose (i.e. claim) must be met; claim must be written in full on standalone attestation form To attest to quality: monograph specifications and Quality for NHPs Guide must be met Attestation to NNHPD Monographs

  11. The following table demonstrates the applicable attestation (safety, efficacy and/or quality) for several different scenarios: Attestation to NNHPD Monographs

  12. If not attesting to a full monograph, clearly indicate the reasoning in cover letter and ensure evidence or rationale has been provided E.g. if omitting required conditions of use, do not attest to safety; instead indicate the reason for not attesting in the cover letter and provide evidence or rationale to support the omission as part of the application package E.g. if attesting to safety but not efficacy because the claim is not supported by the monograph, ensure evidence is provided to support the efficacy of the non-monographed claim Attestation to NNHPD Monographs

  13. When Are Monograph Conditions Not Required?

  14. In the following cases, monograph conditions of use are not required for an ingredient to be supported by an NNHPD monograph: Sub-population-specific risk information is not required if the product is not indicated for that sub-population E.g. the risk statement “if pregnant or breastfeeding, consult a health care practitioner” is not required for a product indicated for an “adult male” sub-population Risk information is not required from one monograph if it is considered less stringent and overlaps the risk information of another ingredient in the product E.g. “if pregnant or breastfeeding, consult a health care practitioner prior to use” is not required if the product contains the risk statement “if pregnant or breastfeeding, do not use” When are Monograph Conditions Not Required

  15. A duration of use relating to efficacy is not required if it is shorter than the duration of use relating to efficacy required by another ingredient in the product (i.e. use the longest duration when related to efficacy) E.g. “use for a minimum of 3 months to see beneficial effects” is not required if the product’s duration of use will be “use for a minimum of 6 months to see beneficial effects” A duration of use relating to safety is not required if it is longer than the duration of use relating to safety required by another ingredient in the product (i.e. use the shortest duration when related to safety) E.g. “consult a health care practitioner for use beyond 1 month” is not required if the product’s duration of use will be “consult a health care practitioner for use beyond 1 week” When are Monograph Conditions Not Required

  16. Post-licensing Audit

  17. The NNHPD conducts post-licensing audits (both random and risk-based) of monograph-based applications (Class I, II and III) to ensure there are no errors in the attestation (e.g. deviations from the monograph) Objective: to ensure that the parameters against which applicants have attested are met Applicants are notified of issues identified during the post-licensing audit via a Notice of Audit Failure; should issues not be addressed immediately within the specified time limit, compliance action may be taken Post-licensing Audit

  18. References Management of product licence applications for natural health products: http://www.hc-sc.gc.ca/dhp-mps/prodnatur/legislation/pol/pla-dlmm_manage-gestion-eng.php Approach to NHPs: http://www.hc-sc.gc.ca/dhp-mps/prodnatur/nhp-new-nouvelle-psn-eng.php Natural Health Products Ingredients Database: http://webprod.hc-sc.gc.ca/nhpid-bdipsn/search-rechercheReq.do?lang=eng Electronic product licence application form (ePLA): http://www.hc-sc.gc.ca/dhp-mps/prodnatur/applications/online-enligne/pla-dlmm-view-eng.php Monograph Attestation form: http://www.hc-sc.gc.ca/dhp-mps/prodnatur/applications/licen-prod/form/attestation-eng.php NHP Online eSubmission builder (eSB): http://www.hc-sc.gc.ca/dhp-mps/prodnatur/applications/online-enligne/esb-gde-intro-eng.php Guidance document on how to interact with the Natural Health Products Directorate electronically: http://www.hc-sc.gc.ca/dhp-mps/pubs/natur/trading_part_commerce-eng.php

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