Thursday, June 25, 2015

From XEVPRM to IDMP.......................................a lot to comply


On 15 December 2010, the European Parliament issued Regulation No 1235/2010 amending earlier regulations 726/2004 and 1394/2007. Although this regulation focused on pharmacovigilance, it also directed to set up and maintain a list of all medicinal products for human use authorized in the EU and to comply with this regulation in 2012. The regulation itself did not include any mandate about the format which needed to be used and the EMA decided to use the Article 57 format or eXtended EudraVigilance Product Report Message (XEVPRM) format to store date in Extended EudraVigilance Medicinal Product Dictionary (XEVMPD).  

On June 19, 2012 Regulation (EU) No 520/2012 was issued, specifically stating reference to the ISO norms 11615, 11616, 11238, 11239 and 11240 as the terminology to be used for communication of pharmacovigilance and medicinal product information. The implementation stated from July 1, 2016.  This is how; ISO Identification of Medicinal Product (IDMP) put forward as regulatory framework.

In light of the above developments, the current Art57/XEVPRM format will be replaced with the formats, terminologies and standards as defined by the ISO IDMP standards.

ISO IDMP Standard was developed in response to a worldwide demand for internationally harmonized specifications for Medicinal Products.

IDMP is a key regulatory framework that developed under the umbrella of the ISO organization. European region is the only one mandating compliance with IDMP at this point of time but once the IDMP standards get adopted across different regions, it will enable consistent data entry, thereby providing regulators the means to compare data across regions for consistency, particularly in the case of global companies.

These standards include a variety of regulatory activities related to development, registration and life cycle management of medicinal products, as well as pharmacovigilance and risk management.

So how XEVPRM works?

XEVPRM is based on XML files.  Basically your software will gather together all your product licence information and any related data about organisations etc, put it into XML format, and create a ZIP file from it, along with any documents that are also required. You will then send this file to the EMA. EMA will process this file per their rules and review and update their database with your valid information and generate EV codes for the new records. Then it will create an acknowledgement file that will say which data it found to be valid and which is invalid. Finally it sends the file back to you. Your software will then read this file and use it to update your database with the EV Codes that it has allocated to your data.

IDMP will also require software implementation but it is far more comprehensive than XEVPRM. Comparative analysis of IDMP requirements Vs. XEVMPD given below shows IDMP is a far more broad set of standards vs. XEVMPD.

 XEVMPD
IDMP
IDMP data Source
Medicinal product
Medicinal product
Regulatory Knowledge, RIM System
Regulated document
Regulated document
Version
Regulatory Knowledge, RIM, ERP Systems
Medicinal Product name
 
Medicinal Product name
Country/language
Regulatory Knowledge, RIM System
Medicinal product classification
Medicinal product classification
Manufacturer/Establishment
Marketing authorization holder
Manufacturing operation
Medicine regulatory agency
Regulatory Knowledge, RIM System
Marketing authorization
Marketing authorization procedure
Marketing authorization application
Marketing authorization
Marketing authorization procedure
Marketing authorization application
Marketing status
PSUR
Regulatory Knowledge, RIM System
Packaged medicinal product
Device
 
Packaged medicinal product
Device
Device batch identification
Batch identifier
Shelf life/storage
Device nomenclature
Package Container
Package component
Manufactured item
Other characteristic
Physical characteristics
Device batch identification
Labeling/ERP Systems
Pharmaceutical product
Route of administration
Pharmaceutical product
Route of administration
Pharmaceutical product characteristics
PHPID set
Regulatory Knowledge, RIM System
Specified substance
Reference strength
Ingredients
Strength
Substance
Specified substance
Reference strength
Ingredients
Strength
Substance
CTD Module 3, Quality Systems
Clinical particulars
Therapeutic indication
Clinical particulars
Therapeutic indication
Undesirable effects
Contraindication
Interaction
Interactant
Population specifics
Other therapy Specifics
Regulatory Knowledge, Labeling, Pharmacovigilance, Clinical
New requirement
Scope expanded
Same

Reference to above table, data will exist in multiple places; some of it will be in the supply chain system, and some of it will have to be gathered from clinical documentation and the regulatory submission information. All that data will have to be extracted and made ready for IDMP. To comply with the IDMP standards; companies will need to do data assessment, Preparation to meet the gaps, software selection and implementation of the system.

The EMA expects to have draft guidance in June 2015.