Diagnostics new product development: overview, WHO’s scientific and regulatory role, regulatory pathways and demand creation Irena Prat Technical Officer, PQDx 1| Dx new product development | 23 September 2013 Global Dx regulatory landscape Dx regulation is relatively new for many jurisdictions and the degree of harmonization is suboptimal, although improving In the rapidly evolving world of technology, the rate of change in Dx design and development is high, and this provides a major challenge in maintaining a balance between timely availability of the latest technology the need to ensure safety and performance Another issue is the number of products available, with the large number of variations within a product range 2| Dx new product development | 23 September 2013 Harmonization history 1993: senior regulatory officials and industry representatives from the EU, USA, Canada, Japan and Australia established a global consultative partnership aimed at harmonizing medical device regulatory practices: GHTF The GHTF was a voluntary group of representatives from national medical device regulatory authorities and the regulated industry The purpose of the GHTF was to encourage convergence in regulatory practices related to ensuring the safety, effectiveness/performance and quality of MD, promoting technological innovation and facilitating international trade. The primary way in which this was accomplished was via the publication and dissemination of harmonized guidance documents on basic regulatory practices. Guidance principles can be adopted/implemented by NRAs. 3| Dx new product development | 23 September 2013 The GHTF 5 GHTF Study Groups – – – – – Study Group 1 - Premarket Evaluation Study Group 2 - Post-Market Surveillance/Vigilance Study Group 3 - Quality Systems Study Group 4 - Auditing Study Group 5 - Clinical Safety/Performance The GHTF regulatory model – the core and basic elements – Supported by GHTF guidance documents 4| Dx new product development | 23 September 2013 Dx life cycle development is a continuous process from the initial concept of the device to the various phases of product realization to placing the device on the market to marketing of the product through distribution, promotion, advertising, servicing to obsolescence or renewal as a modified product The entire cycle is subject to the regulatory processes of a (QMS), RM, and regulatory auditing 5| Dx new product development | 23 September 2013 GHTF regulatory model: key subsystems Riskbased PM control PMS system QMS and RM process encompassing life cycle Regulatory process to periodically assess conformity These elements are interrelated and mutually interdependent. 6| Dx new product development | 23 September 2013 Current harmonization GHTF 2011 IMDRF IMDRF: – a regulator-led harmonization and collaboration group that would allow for more detailed discussion between members on the optimum ways to achieve harmonization at an operational level – Australia, Brazil, Canada, Europe, Japan, USA, China and Russia; WHO is an official observer – Working Groups are established by the Management Committee and operate under targeted mandates on specific activities Other harmonization groups: AHWP 7| Dx new product development | 23 September 2013 WHO PQDx process Manufacturer submits application Rejected Application is screened Manufacturer signs letter of agreement, pays fee and submits product dossier Accepted Rejected Dossier is reviewed Accepted Does not meet WHO requirements Manufacturing Site Inspection Meets WHO requirements Meets WHO requirements Product is prequalified Post-market surveillance Figure 1: Overview of the prequalification of diagnostics process 8| Dx new product development | 23 September 2013 Does not meet WHO requirements PQ criteria Product Laboratory Evaluation WHO PQDX regulatory framework ISO and EN standards 9| GHTF / IMDRF guidance documents Dx new product development | 23 September 2013 CLSI guidance documents PQ requirements PQDx advisory visits Why? How? Who? 10 | To exchange information with R&D teams and Mx in the early stages of development of a Dx, with a view to facilitating entry into the PQDx and meeting int. regulatory requirements Focuses on review of the current status of the company, and then in that context, the advisory team explains the specific requirements for PQDx in relation to the dossier submission, site inspection and performance evaluations. Experts in QMS, R&D, production and technology of the Dx involved Dx new product development | 23 September 2013 PQDx advisory visits What? Analytespecific issues PQDx requirements The QMS, regulation and certification 11 | Dx new product development | 23 September 2013 Research and development Documents under development Information for manufacturers of innovative diagnostics Advisory visits newsletter Further guidance on product dossier submission 12 | Dx new product development | 23 September 2013 Regulatory pathways for Mx PQDx is aligned with SRAs regulatory requirements – Specific PQ aspects (stability, IFU, customer-related issues etc.) are addressed from a different prospective Regulatory pathways required by SRAs also lead to compliance with PQDx; – Mx following SRAs requirements are on the good way to meet PQ requirements To meet the demand for innovative Dx market access: – Advisory visits to Mx 13 | Dx new product development | 23 September 2013 Capacity building in countries PQDX pilot project on pre- and post-market regulation capacity building Focuses on 5 countries with several other MS involved Building a regulatory framework in line with best international practice Ensuring understanding of regulatory practice and avoiding duplication of work 14 | Dx new product development | 23 September 2013 Thank you for your attention Questions? 15 | Dx new product development | 23 September 2013
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