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IDMP Webinar 19 January 2017-01-19 Questions answered by Andrew Marr, Frits Stulp and Sergio Rotstein Q1 Is there a way to extract data from G-SRS (not only few fields but an extended list of fields)? - Note I used the export feature but I did not get all the fields I wanted... R1 Andrew: The version of G-SRS available at the moment does not have the full intended functionality. I’m not aware of the intended capability upon public release, either by FDA or EMA. Q2 Is eagle an in-house developed system? R2 Frits: EAGLE is based on off the shelf software tooling Q3 What is the requirement for Excipients for IDMP reporting - are these Specified Substances? What information will need to be reported for these? R3 Andrew: Excipients are Substances. The data for defining substances does not differentiate between actives and inactives. A substance is a substance. The grade of a substance would be defined as a Specified Substance Group 3. The manufacturer of a substance would be defined as a Specified Substance Group 2. In EU it is anticipated that the grade of actives and excipients will need to be defined for a Medicinal Product. The expected position is that the manufacturer of excipients will not need to be required but this is still to be confirmed. Q4 What is the requirement for Placebos used in clinical trials? R4 Andrew: The Medicinal Product standard (ISO11615) supports the definition of placebos and comparators but the requirements for implementation have not yet been defined. This may be on a regional basis Q5 Will the EMA's G-SRS system contain both UNII codes and xEVMPD codes for a particular substance, and will there be a new identifier generated as part of the R5 new G-SRS system? Andrew: The requirements are not yet defined but during the transition period when both XEVMPD and IDMP are operational, the XEVMPD code will be mapped to the new IDMP code. There is still need to agree whether the global IDMP code will be the UNII or a new, additional code. Q6 For investigational products, at what point would substances be required to be registered into G-SRS? Is this anticipated to be in line with Patent protection or R6 Q7 can G-SRS ensure confidentiality? Andrew: It is anticipated that new substances will need to be registered before First Time in Man, namely at (or before) the time of CTA/IND. Investigational substances will be confidential. It is expected that they would only be considered non-confidential if the structure and company code are put into the public domain within the same publication, or when a Medicinal Product containing the substance becomes authorised. Will Regulators or standards organisations be providing more information about how to link standards like IDMP and eCTD content? R7 Andrew: From a European perspective there is already a project on-going to look at how data for IDMP, eAF, CESSP (new common European portal) and eCTD v4 should be managed as a single data load. EMA will communicate on this at some point in the future, when plans are more mature Q8 How do you manage using the same system globally when Controlled Vocabularies are not standard globally? R8 Frits: Most of the global systems in Astellas have the required governance in place to ensure intra-system consistency. The introduction of the new Controlled Vocabulary Management system and process will now focus on inter-system consistency. Naturally, where critical processes are concerned now (e.g. between RA and PV) procedural arrangements are already in place. Q9 "Mapped where necessary" Can you tell more about this? R9 Andrew: The ideal is, in the long-term, to have global vocabularies where possible. However, some vocabularies may not be able to be adopted by all jurisdictions due to local legislation or current practices. For example, the vocabulary for Pharmaceutical Dosage Forms as defined by EDQM will be considered to be the ‘global CV’ but FDA, at the moment is constrained in having to use USP terms. These are being mapped to EDQM terms so that there is global interoperability. Q10 Why SRS? Regulators choice? R10 Andrew: Not sure I understand the question. G-SRS has been a collaboration between several regulators (US, EU, Canada, Switzerland). It has always been the intent that the system is to be used in support of IDMP. This does not mean that companies have to manage their data in a local instance G-SRS, but it is a possibility. Q11 Where can users gain access to the controlled vocabularies for IDMP? R11 Andrew: From a European perspective CVs will be made available via the Referential Management System (RMS) when this goes live (currently expected May 2017). Apart from being available internally in G-SRS it has not yet been decided how/when CVs for substances will be made available Q12 How many votes were included in the first poll? R12 approx. 80 Q13 How much of the substance data do you see as being exclusively found in "unstructured" sources, e.g. documents like SmPC. R13 I think the poll just answered my question! Q14 Was the CV Management tool at Astellas an off-the-shelf product or home grown? R14 That slide just answered my question - home grown. Frits: correct; an internal URS was developed and based on Oracle APEX technology a basic CVM system was developed, that is likely to be replaced in due course by off the shelf software, integrating with MDM processes. Q15 Structured authoring question: is Astellas creating new content in a structured way or are they using Word documents in i4i and essentially 'tagging' specific content R15 Q16 to enable extraction and/or consistency? Frits: At this time the focus is on tagging of relevant components in existing documents so these can be used for both IDMP submission purposes as well as other business process objectives (like consistency reporting). For new documents, we intend to introduce the concepts of structured authoring as much as we can, within the boundaries of the functionality of our EAGLE system. Linguamatics have good experience with pharma customers using text mining to extract IDMP data elements from e.g. SmPCs, eCTDs. How do the panel see this R16 approach working alongside structured content authoring? Andrew, Frits Frits: I have seen interesting examples of this, but overall the required quality control on the total outcome has never convinced me to fully rely on this so far. I do see great value in a balanced combination of text mining and structured authoring tools. Andrew: I’m yet to be convinced that the effort and cost in establishing text mining will be worthwhile, particularly from documents beyond the SmPC. IDMP increases the need for closer integration of procedures for managing document and related data content. For a document such as the SmPC which is data-rich then there can be a role of structured content authoring, if the size of the company and hence number of SmPCs merits it. The business case is different for developing documents for new products going forward versus retro-fitting already authorised products. Q17 I work in a CMC Product Development analytical lab where we do release and stability testing of drug substance and tablets used to establish shelf life and storage conditions for clinical studies. Can you comment on how IDMP will impact R17 Q18 my work and when the standards relevant to my work will be ratified? Andrew: I don’t think that they will affect your work. The formulation of product used in clinical trials will need to be submitted, and perhaps the shelf-life but no data. In the very long term, the adoption of Specified Substance Group 4, which covers the information regarding Drug Substance at the level of detail of the CTD would cover analytical methods and specifications. This is a long way off and, in my opinion, would only be worthwhile implementing for authorised and not investigational substances. Are software companies (LIMS, ELN, CDS, MES, etc.) embedding IDMP standards into their software? R18 Frits: So far, I have seen very little evidence of that at this time, although it would make so much sense. Right now the more obvious software suppliers (e.g. RIMS, XEVMPD tooling) are preparing IDMP readiness in their tools, and some ERP vendors is investigating combining these requirements with existing traceability functionalities. When timelines are more firm and the contributions from CMO organizations and internal supply chain departments become essential, I expect an acceleration in this development. This is my opinion. Q19 Would IDMP consider certifying commercial software applications as IDMPcompliant? Then we could buy software off the shelf instead of each of us R19 spending time and money to create custom solutions. Andrew, Frits Frits: I am not clear what is meant with “IDMP” here as this is not an organization. There have been discussions in seeking a certification from an independent body to describe coverage of the ISO IDMP requirements in software. Andrew: It would not be ISO that does any certification. And of course there will be flavours of IDMP. For example, the scope, processes, some vocabularies etc will vary between regulators implementing IDMP. Q20 Will a recording of the webinar be made available? R20 Yes, it will be uploaded tomorrow Q21 I would like to know if we could get the slides after the end of the meeting R21 They'll be posted on our website tomorrow. Q22 Is there way of representing mutant proteins that may be therapeutic. R22 Sergio: From a HELM perspective the answer is yes. Any kind of protein can be represented, including any that may have any kind of unnatural component (e.g. Unnatural amino acids, chemical attachments, etc)