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eCTD Submissions

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eCTD Submissions

  1. 1. eCTD SUBMISSIONS 1Gautam G. Halder– Regulatory Affairs 6/12/2018
  2. 2. 2Gautam G. Halder– Regulatory Affairs 6/12/2018 WHAT IS eCTD? The Electronic Common Technical Document (eCTD) is the standard format for submitting applications, amendments, supplements, and reports to FDA’s Center for Biologics Evaluation and Research (CBER) and Center for Drug Evaluation and Research (CDER). STANDARD FORMAT FOR SUBMISSIONS
  3. 3. 3Gautam G. Halder– Regulatory Affairs 6/12/2018 WHAT IS eCTD?......CONTINUED An eCTD submission has five modules: region-specific information, summary documents, quality-related information, nonclinical study reports, and clinical study reports.
  4. 4. 4Gautam G. Halder– Regulatory Affairs 6/12/2018 FRAMEWORK FOR REQUIRED ELECTRONIC SUBMISSION FDASIA: Food and Drug Administration Safety and Innovation Act (FDASIA)
  5. 5. 5Gautam G. Halder– Regulatory Affairs 6/12/2018 How will eSubmissions be Implemented? FRAMEWORK FOR REQUIRED ELECTRONIC SUBMISSION
  6. 6. 6Gautam G. Halder– Regulatory Affairs 6/12/2018 FRAMEWORK FOR REQUIRED ELECTRONIC SUBMISSION When will eCTD Format be Required? 36 months for Commercial INDs
  7. 7. 7Gautam G. Halder– Regulatory Affairs 6/12/2018 UPDATES When will eCTD Format be Required? Starting May 5, 2018 Ø New MFs and any submissions to existing MFs (e.g., amendments, annual reports, letters of authorization (LOAs)) must be submitted using eCTD. Ø All submissions must be submitted electronically, even if the remainder of the MF is on paper. Ø MF submissions that are not submitted in eCTD format, will not be filed or received. Ø The current requirements and supported versions can be found in the FDA Data Standards Catalog at www.fda.gov/eStudyResources.
  8. 8. 8Gautam G. Halder– Regulatory Affairs 6/12/2018 What Submission Types are Applicable? FRAMEWORK FOR REQUIRED ELECTRONIC SUBMISSION *Commercial IND applications (for products that are intended to be distributed commercially)
  9. 9. 9Gautam G. Halder– Regulatory Affairs 6/12/2018 Electronic submission standards will be optional but encouraged for the following categories: Ø Noncommercial INDs, such as investigator-sponsored INDs and expanded-access INDs Ø Submissions for blood and blood components, including source plasma Ø Submissions for promotional materials for human prescription drug What Submission Types are Applicable? EXEMPTION
  10. 10. 10Gautam G. Halder– Regulatory Affairs 6/12/2018 FRAMEWORK FOR REQUIRED ELECTRONIC SUBMISSION What are the eCTD Specifications?
  11. 11. 11Gautam G. Halder– Regulatory Affairs 6/12/2018 What are the eCTD Specifications? CURRENT VERSIONS AND UPDATES Ø Submit electronic submissions using the version of eCTD currently supported by FDA. Ø For a listing of Specifications, Supportive Files, M1 versions 1.3 and 2.3 documents related to eCTD, please refer to eCTD Submission Standards (XLS - 57KB) or eCTD Submission Standards (PDF - 91KB).
  12. 12. 12Gautam G. Halder– Regulatory Affairs 6/12/2018 FRAMEWORK FOR REQUIRED ELECTRONIC SUBMISSION What eCTD Formats will be Required?
  13. 13. 13Gautam G. Halder– Regulatory Affairs 6/12/2018 What eCTD Formats will be Required? Ø Electronic submissions must use the version of eCTD currently supported by FDA, which is specified in the FDA Data Standards Catalog on the Study Data Standards Resources page. Ø Updates to the standard will be announced on the FDA website and published in the Federal Register. Ø The notices will include the date on which the new versions will go into effect. For notices, please see eCTD Important Notices. CURRENT VERSIONS AND UPDATES
  14. 14. 14Gautam G. Halder– Regulatory Affairs 6/12/2018 FRAMEWORK FOR REQUIRED ELECTRONIC SUBMISSION How to Submit eCTD Submissions?
  15. 15. 15Gautam G. Halder– Regulatory Affairs 6/12/2018 How to Submit eCTD Submissions? CURRENT VERSIONS AND UPDATES Please refer to eCTD Submission Standards (XLS - 57KB) or eCTD Submission Standards (PDF - 91KB).
  16. 16. 16Gautam G. Halder– Regulatory Affairs 6/12/2018 Ø Before making the first electronic submission to an application, you must obtain a pre-assigned application number by contacting the appropriate Center. Ø All electronic submissions must have an application number Ø Information regarding how to obtain a pre-assigned application number may be found on FDA’s eCTD web page at https://www.fda.gov/Drugs/DevelopmentApprovalProcess/FormsSubmissionRequire ments/ElectronicSubmissions/ucm114027.htm PRE-SUBMISSION CONSIDERATIONS Pre-assigned application number Requesting a Pre-Assigned Application number 1. Apply for a secure email with the FDA by contacting secureemail@fda.hhs.gov. If using a US Agent to request the number, please be sure that the agent has established a secure e-mail. 2. Send one email per application number request to cderappnumrequest@fda.hhs.gov. Please note that at this time the Electronic Submission Gateway (ESG) cannot accept requests for pre-assigned numbers. 3. A pre-assigned number will be issued within 3 business days.
  17. 17. 17Gautam G. Halder– Regulatory Affairs 6/12/2018 Resubmission of Material Ø There is NO requirement to resubmit anything that has already been submitted in paper Ø If you choose to resubmit your entire DMF upon conversion to eCTD, that is acceptable but it is NOT required. SUBMISSIONS
  18. 18. 18Gautam G. Halder– Regulatory Affairs 6/12/2018 Conversion of Paper DMFs to Electronic Ø If the existing number is 4-digits, e.g. 1234, the DMF holder should pad left with zeroes to convert to a 6-digit format, e.g. 001234. Ø Each section should be complete and contain up-to-date information. Ø DMFs in non-CTD paper format must be converted to CTD format before submission in eCTD. Ø Any changes in the technical content of the DMF as a result of the conversion to CTD format, e.g. addition of new information, should be specified in the cover letter of the submission. Ø The numbering of the submissions should start with 0001. SUBMISSIONS Ø When converting from paper to electronic, the holder may submit an amendment containing all sections specified in the CTD format that are applicable to the material covered by the DMF. Ø An existing DMF number may be used when converting a paper DMF to electronic format.
  19. 19. 19Gautam G. Halder– Regulatory Affairs 6/12/2018 Paper to eCTD Examples (v2.01 DTD) When transitioning from paper to eCTD and holder is utilizing us-regional.xml v2.01 DTD, the most common scenarios are below: 1. First eCTD submission is an amendment to the DMF • In this case, use a submission type of original-application Subsequent amendments, including letters of authorization, submitted in eCTD should use a submission type of amendment 2. First eCTD submission is an annual report • In this case, use a submission type of annual-report SUBMISSIONS DTD: Document type definition TIP! FDA prefers eCTD submissions start with sequence 0001
  20. 20. 20Gautam G. Halder– Regulatory Affairs 6/12/2018 Paper to eCTD Examples (v3.3 DTD) When transitioning from paper to eCTD and holder is utilizing us-regional.xml v3.3 DTD, the most common scenarios are below: 1. First eCTD submission is an amendment to the DMF • In this case, use a submission type of original-application and submission subtype of application. • Use eCTD sequence number = 0001 and Submission ID = 0001 Subsequent amendments, including letters of authorization, submitted in eCTD should use a submission type of original application and submission subtype of amendment. Use next available eCTD sequence number and Submission ID = 0001 (Submission ID for the first eCTD submission to the Original application) 2. First eCTD submission is an annual report • In this case, use a submission type of annual-report and submission subtype of report. Use eCTD sequence number = 0001 and Submission ID = 0001. SUBMISSIONS DTD: Document type definition TIP! FDA prefers eCTD submissions start with sequence 0001
  21. 21. 21Gautam G. Halder– Regulatory Affairs 6/12/2018 Electronic Submissions Gateway (ESG) TRANSMITTING ELECTRONIC SUBMISSIONS What is Electronic Submissions Gateway (ESG)? Ø The FDA Electronic Submissions Gateway (ESG) is the central transmission point for sending information electronically to FDA. Ø The ESG does not open or review submissions. Ø It receives submissions, acknowledges receipt, routes them to the proper FDA center or office, and notifies that center or office of delivery.
  22. 22. 22Gautam G. Halder– Regulatory Affairs 6/12/2018 Electronic Submissions Gateway (ESG) TRANSMITTING ELECTRONIC SUBMISSIONS Submission types Ø The FDA ESG supports the receipt of guidance-compliant electronic regulatory submissions to the Center for Biologics Evaluation and Research (CBER) and the Center for Drug Evaluation and Research (CDER). Ø The FDA ESG also supports the receipt of reports and attachments for many other FDA offices and centers. FDA is continually expanding the list of electronic regulatory submissions that can be received by the ESG. Submission requirements Ø As of May 5, 2017, many submissions to CBER and CDER are required to use the Electronic Common Technical Document (eCTD) format. (For commercial Investigational New Drugs [INDs] and Master Files, the requirement takes effect on May 5, 2018.) Ø Submissions that fall under the eCTD requirement and are 10 GB or less in size must be submitted via the FDA ESG as of the applicable date. For more information on these requirements, see www.fda.gov/ectd.
  23. 23. 23Gautam G. Halder– Regulatory Affairs 6/12/2018 Electronic Submissions Gateway (ESG) TRANSMITTING ELECTRONIC SUBMISSIONS Submission options There are two methods for submitting to the ESG 1. AS2 Gateway-to-Gateway Connection Ø Generally used by sponsors that have a high volume of submissions Ø Allows automated submissions Ø Requires AS2-compliant software and technical expertise 2. WebTrader Ø A regular desktop computer can be used for submissions Ø User can send only one submission at a time Ø Requires installation of a Java applet but minimal technical expertise
  24. 24. 24Gautam G. Halder– Regulatory Affairs 6/12/2018 Electronic Submissions Gateway (ESG) TRANSMITTING ELECTRONIC SUBMISSIONS Registration process Ø Registering to use the FDA ESG involves a sequence of steps that are to be conducted for all submitters and types of submissions. Ø It is best to start well in advance of the time when you plan to make a submission. Ø The process includes a testing phase designed to ensure that the FDA ESG can successfully receive your electronic submission and that the electronic submission is prepared according to published guidelines. Ø The testing phase is done through the FDA ESG test system. Once the submitter’s test submission has passed the testing phase, an account will be set up allowing submissions to be sent through the FDA ESG production system.
  25. 25. 25Gautam G. Halder– Regulatory Affairs 6/12/2018 Electronic Submissions Gateway (ESG) TRANSMITTING ELECTRONIC SUBMISSIONS Getting started Ø The first step to submitting electronically through ESG is to request a test account. Refer to the FDA ESG User Guide, available at www.fda.gov/esg, for information on how to submit the registration request. Ø Setting up an ESG account is a multi-step process and should be started well before you intend to make your first electronic submission.
  26. 26. 26Gautam G. Halder– Regulatory Affairs 6/12/2018 MUST DO See the Guidance for a *complete* list of the “musts” Ø Must submit electronic submissions using the eCTD version currently supported by FDA. § The version of eCTD currently supported is specified in the Data Standards Catalog Ø Must obtain a pre-assigned application number by contacting the appropriate Center. § How? Go to www.fda.gov/ectd Ø Must follow the FDA eCTD technical specification Table of Contents Headings and Hierarchy. § Find it in the eCTD Submissions Standards catalog
  27. 27. 27Gautam G. Halder– Regulatory Affairs 6/12/2018 Find these specifications and more in the eCTD Submissions Standards catalog Ø Must adhere to the formats and versions specified in the FDA Specifications for File Format Types Using eCTD Specifications. Ø Must adhere to the FDA Portable Document Format (PDF) Specifications. Ø Must use the eCTD replace operation rather than submitting the file as new if a document replaces a document previously submitted… MUST DO
  28. 28. 28Gautam G. Halder– Regulatory Affairs 6/12/2018 Ø Must include only FDA fillable forms (e.g., User Fee Form 3794) and electronic signatures to enable automated processing of the submission…Scanned images of FDA forms will not be accepted. Ø Must not submit paper copies of the application, including review & desk copies when submitting in eCTD format. Ø Must use the FDA Electronic Submission Gateway for submissions 10 GB or smaller. MUST DO
  29. 29. 29Gautam G. Halder– Regulatory Affairs 6/12/2018 Must use the FDA Electronic Submission Gateway for submissions 10 GB or smaller. See Transmission Specification (www.fda.gov/ectd) for details Ø If you are not currently an ESG submitter, set up an account now; process can take several weeks Ø Most submitters use the “WebTrader Hosted Solution” Ø There is no cost for an ESG account, but you must obtain a Digital Certificate for each person in your organization who will be sending files through the ESG Ø See the ESG website for complete instructions, http://www.fda.gov/esg MUST DO
  30. 30. 30Gautam G. Halder– Regulatory Affairs 6/12/2018 PDF Table of Contents and Bookmarks Ø Should be the same Ø For documents 5 pages or longer Ø Up to 4 levels deep in hierarchy TIPS FOR DMF SUBMISSION SUCCESS
  31. 31. 31Gautam G. Halder– Regulatory Affairs 6/12/2018 BAD – Bookmarks and TOC do not match. TOC does not contain hyperlinks TIPS FOR DMF SUBMISSION SUCCESS
  32. 32. 32Gautam G. Halder– Regulatory Affairs 6/12/2018 GOOD! TIPS FOR DMF SUBMISSION SUCCESS
  33. 33. 33Gautam G. Halder– Regulatory Affairs 6/12/2018 Orientation TIPS FOR DMF SUBMISSION SUCCESS
  34. 34. 34Gautam G. Halder– Regulatory Affairs 6/12/2018 Orientation Any documents provided in the submission should be in the correct orientation TIPS FOR DMF SUBMISSION SUCCESS
  35. 35. 36Gautam G. Halder– Regulatory Affairs 6/12/2018 ESG Tips (Electronic Submissions Gateway) Ø Submissions of 10 GB or less must use the Electronic Submission Gateway (ESG). Ø Get an account early • Account activation process contains many steps including submission of a CDER compliant test submission and passing validation. This may take multiple attempts and can take weeks. • Instructions are located at: www.fda.gov/esg • There is no cost for an ESG account, but you must obtain a digital certificate for each person in your organization who will be sending files through the ESG. Ø When transmitting to CDER, choose “CDER” as the center and “eCTD” as the submission type Ø When transmitting to CBER, choose “CBER” as the center and “DMF” as the submission type Ø Questions related to the Gateway should be directed to: ESGHELPDESK@fda.hhs.gov TIPS FOR DMF SUBMISSION SUCCESS
  36. 36. 37Gautam G. Halder– Regulatory Affairs 6/12/2018 QUOTE OF THE DAY
  37. 37. 38Gautam G. Halder– Regulatory Affairs 6/12/2018

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