Advanced Therapy Medicinal Products : Advanced Therapy Medicinal Products : recent experience with recent experience with - classification, classification, - - scientific advice scientific advice - - certification certification - Jean-Hugues Trouvin BWP chairman CAT Member
Disclaimer Disclaimer Although being a member of EMA committees and working parties, my presentation might not be the view of the CHMP and the EMA, nor that of the French Medicines Agency (Afssaps). This presentation reflects only personal views and binds in no way the organisations mentioned above. 2 SME workshop – – London London – – May 2011 May 2011 SME workshop
ATMPs ATMPs Regulation 1394/2007 • Definition of Advanced Therapy medicinal products • The Committee for Advanced Therapy Medicinal product (CAT) Focus on • Classification • Contribution to the Scientific Advice • Certification 3 SME workshop – – London London – – May 2011 May 2011 SME workshop
Advanced Therapy Medicinal Products (ATMP) Advanced Therapy Medicinal Products (ATMP) Regulation 1394/2007 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:324:0121:0137:en:PDF 4 SME workshop – – London London – – May 2011 May 2011 SME workshop
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Regulation 1394/2007 Regulation 1394/2007 Classifying tissue-based or cell-based products as medicinal products pharmaceutical legislation applies in all aspects of the product life cycle: • Development and Clinical trials • GMP for the production/quality control • Pharmacovigilance • With additional requirements (long term follow up –art.14) EMA responsible for the regulatory framework One centralised Marketing Authorisation One scientific Committee to deal with the submission : CAT 6 SME workshop – – London London – – May 2011 May 2011 SME workshop
Consequence of the regulation - -1 1- - Consequence of the regulation For products within the scope: • No marketing without prior authorisation • Assessment of the Quality, Safety & Efficacy • Post-authorisation vigilance; specific obligation for safety and for efficacy Authorisation via the centralised procedure mandatory Same dossier as for a medicinal product (CTD) with technical adaptations) Combined products: • Assessment for both the MD and MP • If NB assessment exist=> obligation to submit it • If not=>EMEA seeks opinion, unless CAT decides it is not required. 7 Ref. : Articles 27-28 of the proposal SME workshop – – London London – – May 2011 May 2011 SME workshop
Consequence of the regulation - -2 2- - Consequence of the regulation Centralised procedure mandatory New Committee within the EMEA: CAT • pooling of Community expertise • multidisciplinary nature: biotechnology medical devices risk management ethics … • representation of Civil Society and Research Community 8 SME workshop – – London London – – May 2011 May 2011 SME workshop
CAT COMPOSITION CAT COMPOSITION Interaction with other working parties Interaction with other working parties BWP GTWP SAWP CPWP PhVWP 5 co- -opted members opted members 5 co PgWP Committee Committee CHMP CHMP for Advanced Therapies for Advanced Therapies Chair: Dr. E. Abadie (CAT) (CAT) VWP EWP 5 „ „double members double members“ “ 5 QWP BPWP SWP BMWP Reg. 1394/2007, Art. 8 9 SME workshop – – London London – – May 2011 May 2011 SME workshop
Consequence of the regulation - -3 3- - Consequence of the regulation Competitiveness Aspects Competitiveness Aspects SMEs: Certification of quality and non-clinical data Additional Fee reduction if applicant is SME or hospital and can prove there is a particular public health interest in the Community • 50% fee reduction on MA fee • 50% post-authorisation activities during one year • Applies only during transitional period 10 SME workshop – – London London – – May 2011 May 2011 SME workshop
Tasks of the Committee for Advanced Therapies (art. 23) Tasks of the Committee for Advanced Therapies (art. 23) to formulate a draft opinion on the quality, safety and efficacy of an advanced therapy medicinal product for final approval by the CHMP dossier evaluation to provide advice, on whether a product falls within the definition of an advanced therapy medicinal product classification to advise on any medicinal product which may require, for the evaluation of its quality, safety or efficacy, expertise in one of the scientific areas Scientific advice to assist scientifically in the elaboration of any documents related to the fulfilment of the objectives of this Regulation criteria and guidelines 11 SME workshop – – London London – – May 2011 May 2011 SME workshop
Tasks of the Committee for Advanced Therapies (art. 23) Tasks of the Committee for Advanced Therapies (art. 23) to formulate a draft opinion on the quality, safety and efficacy of an advanced therapy medicinal product for final approval by the CHMP dossier evaluation to provide advice, on whether a product falls within the definition of an advanced therapy medicinal product classification to advise on any medicinal product which may require, for the evaluation of its quality, safety or efficacy, expertise in one of the scientific areas Scientific advice to assist scientifically in the elaboration of any documents related to the fulfilment of the objectives of this Regulation criteria and guidelines 12 SME workshop – – London London – – May 2011 May 2011 SME workshop
Scientific recommendation on advanced Scientific recommendation on advanced therapy classification (art. 17) therapy classification (art. 17) The CAT will answer the following questions for a given product submitted for classification: • Is it a biological ? • Is it a medicinal product • Is it an ATMP • What ATMP ? Within 60 calendar days following receipt of a valid request for scientific recommendation classification, the EMEA with involvement of the CAT, shall deliver its recommendation after consultation with the European Commission (EC). 13 SME workshop – – London London – – May 2011 May 2011 SME workshop
14 SME workshop – – London London – – May 2011 May 2011 SME workshop
Classification procedure Classification procedure The following scientific information are deemed as minimal, in order for the CAT to classify a product: • Active substance: description of active substance including starting materials, any additional substances such as scaffolds, matrices, biomaterials, biomolecules medical device or active implantable medical device). • Finished Product: qualitative & quantitative composition, pharmaceutical form mode of administration,. • Mechanism of Action / Proposed use: claimed mechanism of action, properties (including pharmacological, immunological or metabolic, indication (including therapeutic, prophylactic, diagnostic). • Summary of the status of the development key elements of manufacturing, level of manipulations on cells and tissues Outline of Non-Clinical development and Clinical development relevant for the ATMP classifification. 15 SME workshop – – London London – – May 2011 May 2011 SME workshop
Classification procedure Classification procedure The CAT express itself on whether a product is an ATMP • Fulfilment of one of the definitions of gene therapy medicinal product, somatic cell medicinal product, tissue engineering or combined ATMP; • The CAT is not a classification body; hence, it cannot express opinions on whether a product is or is not a medicinal product. • The ATMP classification is a non-mandatory procedure that can be used by developers to clarify the applicable regulatory framework The ATMP classification helps • to position the product in the ATMP category, • To clarity on the development path and scientific-regulatory guidance to be followed • to clarify questions of borderline with other areas, • to open the door to other incentives designed for Advanced Therapies ATMP classification, in many cases has facilitated further dialogue with the Agency and the provision of guidance early in the development process and throughout the lifecycle of the product 16 SME workshop – – London London – – May 2011 May 2011 SME workshop
Classification results Classification results http: / / www.ema.europa.eu/ ema/ index.jsp?curl= pages/ regulatio n/ general/ general_content_000301.jsp&murl= menus/ regulation 17 SME workshop – – London London – – May 2011 May 2011 SME workshop
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