Regulatory Affairs: Interview Questions and Answers

What is Regulatory Affairs?

Regulatory Affairs in the Pharmaceutical industry is a profession that acts as the interface between the pharmaceutical industry and Drug Regulatory authorities across the world. It is mainly involved in the registration of drug products in respective countries prior to their marketing.

What are the goals of Regulatory Affairs Professionals?

• Protection of human health
• Ensuring the safety, efficacy, and quality of drugs
• Ensuring appropriateness and accuracy of product information

What are the Roles of Regulatory Affairs professionals?

• Act as a liaison with regulatory agencies
• Preparation of organized and scientifically valid NDA, ANDA, INDA, MAA, DMF submissions
• Ensure adherence and compliance with all the applicable cGMP, ICH, GCP, and GLP guidelines, regulations, and laws
• Providing expertise and regulatory intelligence in translating regulatory requirements into practical workable plans
• Advising the companies on regulatory aspects and climate that would affect their proposed activities
• Apart from the above main roles, there are various other roles that Regulatory Affairs professionals play.

What is an Investigational New Drug (IND) application?

It is an application that is filed with FDA to get approval for legally testing an experimental drug on human subjects in the USA

What is a New Drug Application?

The NDA is the vehicle through which drug sponsors formally propose that the FDA approve a new pharmaceutical for sale and marketing in the U.S. The data gathered during the animal studies and human clinical trials of an Investigational new drug become part of the NDA. In simple words, “It is an application which is filed with FDA to market a new Pharmaceutical for sale in USA”

What is an Abbreviated New Drug Application (ANDA)?

It is an application filed with FDA, for a U.S. generic drug approval for an existing licensed medication or approved drug. In simple words, “It is an application for the approval of Generic Drugs “

What is a Generic Drug Product?

A generic drug product is one that is comparable to an innovator drug product in dosage form, strength, route of administration, quality, performance characteristics and intended use.

What is a DMF?

A Drug Master File (DMF) is a submission to the Food and Drug Administration (FDA) that may be used to provide confidential detailed information about facilities, processes, or articles used in the manufacturing, processing, packaging, and storing of one or more human drugs.

Important facts regarding DMFs

• It is submitted to FDA to provide confidential information
• Its submission is not required by law or regulations
• It is neither approved nor disapproved
• It is filed with FDA to support NDA, IND, ANDA another DMF or amendments and supplements to any of these
• It is provided for in the 21 CFR (Code of Federal Regulations) 314. 420
•  It is not required when the applicant references it's own information

What are the types of DMF’s?

• Type I: Manufacturing Site, Facilities, Operating Procedures, and Personnel (No longer accepted by FDA)
• Type II: Drug Substance, Drug Substance Intermediate, and Material Used in Their Preparation, or Drug Product
• Type III: Packaging Material
• Type IV: Excipient, Colorant, Flavor, Essence, or Material Used in Their Preparation
• Type V: FDA Accepted Reference Information (FDA discourages its use)

What is a 505 (b)(2) application?

505 (b)(2) application is a type of NDA for which one or more investigations relied on by the applicant for approval were not conducted by/for the applicant and for which the applicant has not obtained a right of reference.

What kind of application can be submitted as a 505(b)(2) application?

• New chemical entity (NCE)/new molecular entity (NME)
• Changes to previously approved drugs

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What are the examples of changes to approved drug products for which 505(b)(2) applications should be submitted?

• Change in a dosage form.
• Change in strength
• Change in route of administration
• Substitution of an active ingredient in a formulation product
• Change in formulation
• Change in dosing regimen
• Change in active ingredient
• New combination Product
• New Indication
• Change from prescription indication to OTC indication
• Naturally derived or recombinant active ingredient 
• Bioequivalence

What are the chemical classification codes for NDA?

Number	Meaning
1	New molecular entity (NME)
2	New ester, new salt, or other noncovalent derivatives
3	New formulation
4	New combination
5	New manufacturer
6	New Indication
7	Drugs already marketed but without an approved NDA
8	OTC (over-the-counter) switch

What are the differences between NDA and 505 (b)(2) application?

Sr. No.	New Drug Application (NDA)	505 (b)(2) Application
1.	All investigations relied on by the applicant for approval were conducted by/for the applicant and for which the applicant has the right of reference	One or more investigations relied on by the applicant for approval were not conducted by/for the applicant and for which the applicant has not obtained a right of reference
2.	Generally, filed for newly invented pharmaceuticals.	Generally, filed for new dosage forms, new routes of administration, new indication, etc for all already approved pharmaceuticals.

Note: 505 (b)(2) application is a type of NDA.

What is a Marketing Authorization Application?

It is an application filed with the relevant authority in Europe (typically, the UK's MHRA or the EMA’s Committee for Medicinal Products for Human Use (CHMP)) to market a drug or medicine.

As per UK’s MHRA-

• Applications for new active substances are described as 'full applications'.
• Applications for medicines containing existing active substances are described as 'abbreviated’ or ‘abridged applications’.

What is an ASMF?

An active substance master file is a submission that is made to EMA, MHRA, or any other Drug Regulatory Authority in Europe to provide a confidential intellectual property or 'know-how' of the manufacturer of the active substance.

Simply put, “It is a submission made to European Drug regulatory agencies on the confidential information of Active Substance or Active Pharmaceutical Ingredient (API)”.

What are the types of active substances for which ASMFs are submitted?

• New active substances
• Existing active substances not included in the European Pharmacopoeia (Ph. Eur.) or the pharmacopeia of an EU Member State
• Pharmacopeial active substances contained in the Ph. Eur. or in the pharmacopeia of an EU Member State

What is the difference between DMF and ASMF (with respect to submission)? 

ASMF is submitted as Applicant’s Part (Open Part) and Restricted Part (Closed Part). 

There isn’t any differentiation of DMF’s into parts

What is ICH?

International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH): is a project that brings together the regulatory authorities of Europe, Japan and the United States and experts from the pharmaceutical industry in the three regions to discuss scientific and technical aspects of pharmaceutical product registration.

What is CTD?

• The Common Technical Document (CTD) is a set of specifications for the application dossier, for the registration of Medicines and is designed to be used across Europe, Japan and the United States. Quality, Safety, and Efficacy information is assembled in a standard format through CTD. The CTD is maintained by the International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH).
• CTD format for submitting drug registration applications/dossiers is widely accepted by regulatory authorities of other countries like Canada, Australia, etc.

What are the ICH guidelines to be referred to for the preparation of registration dossiers/applications of medicines (With respect to format and contents in each module)?

M4 Guideline M4Q Guideline M4S Guideline M4E Guideline

What are the modules in CTD?

The Common Technical Document is divided into five modules:

1. Module 1. Administrative information and prescribing information
2. Module 2. Common Technical Document summaries (Overview and summary of modules 3 to 5)
3. Module 3. Quality
4. Module 4. Non-clinical Study Reports (toxicology studies)
5. Module 5. Clinical Study Reports (clinical studies)

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What is Orange Book?

• It is the commonly used name for the book “Approved Drug Products with Therapeutic Equivalence Evaluations” published by USFDA.
• It contains the list of drug products, approved on the basis of safety and effectiveness by the Food and Drug Administration (FDA) under the Federal Food, Drug, and Cosmetic Act.

What is the Hatch-Waxman Act?

It is the popular name for Drug Price Competition and Patent Term Restoration Act, 1984. It is considered the landmark legislation which established the modern system of generic drugs in the USA. Hatch-Waxman amendment of the federal Food, drug, and cosmetics act established the process by which, would-be marketers of generic drugs can file Abbreviated New Drug Applications (ANDA) to seek FDA approval of generic medications. Paragraph IV of the act allows 180-day exclusivity to companies that are the "first-to-file" an ANDA against holders of patents for branded counterparts.

In simple words “Hatch-Waxman Act is the amendment to Federal, Food, Drug, and Cosmetics act which established the modern system of approval of generics ”

What are the patent certifications under the Hatch-Waxman act?

Ans-As per the Hatch and Waxman Act, generic drug and 505 (b) (2) applicants should include certifications in their applications for each patent listed in the “Orange Book” for the innovator drug. This certification must state one of the following:

1. that the required patent information relating to such patent has not been filed (Para I certification);
2. that such patent has expired (Para II certification);
3. that the patent will expire on a particular date (Para III certification); or
4. that such patent is invalid or will not be infringed by the drug, for which approval is being sought(Para IV certification).

A certification under paragraph I or II permits the ANDA to be approved immediately if it is otherwise eligible. A certification under paragraph III indicates that the ANDA may be approved when the patent expires.

What is meant by 180-day exclusivity?

• The Hatch-Waxman Amendments provide an incentive of 180 days of market exclusivity to the “first” generic applicant who challenges a listed patent by filing a paragraph IV certification and thereby runs the risk of having to defend a patent infringement suit.
• 180 Day Exclusivity could be granted to more than one applicant. The recent example is- the 180-day exclusivity was granted to Ranbaxy and Watson Laboratories for marketing a generic version of Lipitor ( Atorvastatin calcium).

What are the procedures for the Approval of Drugs in the EU?

• Centralized Procedure (CP) 
• Decentralized Procedure (DCP)
• Mutual Recognition Procedure (MRP) 
• National Procedure (NP)

What is the Full form of the abbreviation, CEP?

Certificate of Suitability to the monographs of the European Pharmacopoeia (or) Certificate of suitability of monographs of the European Pharmacopoeia (or) Certification of suitability of European Pharmacopoeia monographs

It is also informally referred to as a Certificate of Suitability (COS)

What is a CEP?

It is the certificate issued by the Certification of Substances Division of the European Directorate for the Quality of Medicines (EDQM), when the manufacturer of a substance provides proof that the quality of the substance is suitably controlled by the relevant monographs of the European Pharmacopoeia.

Full forms of some of the Abbreviations related to Regulatory Affairs:

Sr. No.	Abbreviation	Full Form
1	NDA	New Drug Application
2	ANDA	Abbreviated New Drug application
3	IND	Investigational New Drug Application
4	DMF	Drug Master file
5	ASMF	Active Substance Master File
6	MAA	Marketing Authorisation Application
7	CEP	Certificate of Suitability to the monographs of the European Pharmacopoeia
8	ICH	The International Conference on Harmonisation of technical requirements for Registration of Pharmaceuticals for human use.
9	CTD	Common technical document for the registration of pharmaceuticals for human use.
10	AP	Applicant’s Part
11	RP	Restricted Part
12	OP	Open Part
13	CP	Closed Part
14	NME	New Molecular Entity
15	NCE	New Chemical Entity
16	SmPC	Summary of Product Characteristics
17	PL	Packaging Leaflet
18	RMS	Reference Member State
19	CMS	Concerned Member State
20	CHMP	The Committee for Medicinal Products for Human Use
21	CPMP	Committee for Proprietary Medicinal Products
22	CVMP	Committee For Medicinal Products For Veterinary Use
23	SUPAC	Scale-up and post-approval changes
24	BACPAC	Bulk Active Chemicals Post-approval Changes
25	cGMP	Current Good Manufacturing Practice
26	GCP	Good Clinical Practice
27	GLP	Good Laboratory Practice

Well known Drug Regulatory Agencies across the world

Sr. No.	Country /Region	Regulatory Agency
1	United States of America	United States Food and Drug Administration (USFDA)
2	United Kingdom	Medicines and Healthcare Products Regulatory Agency (MHRA)
3	European Union	European Medicines Agency (EMA)
4	European Union	European Directorate for the Quality of Medicines (EDQM)
5	Australia	Therapeutic Goods Administration (TGA)
6	Canada	Therapeutic Products Directorate (TPD) in Health Product and food branch (HPFB) of Health Canada (HC)
7	Japan	Pharmaceutical and Medical Devices Agency (PMDA)
8	France	Agence Francaise de Securite Sanitaire des Produits de Sante (AFSSAPS) Translated into English as- French Agency for the Safety of Health Products
9	Germany	Bundesinstitut für Arzneimittel und Medizinprodukte, (BfArM) Tanslated into English as- Federal Institute for Drugs and Medical Devices
10	Brazil	Agência Nacional de Vigilância Sanitária (ANVISA) Translated into English as- The National Health Surveillance Agency
11	India	Drugs Controller General of India (DCGI) who heads Central Drugs Standard Control Organisation (CDSCO)
12	Switzerland	Swiss Agency for Therapeutic Products (SWISSMEDIC)
14	Singapore	Health Sciences Authority (HSA)
15	New Zealand	New Zealand Medicines and Medical Devices Safety Authority (MEDSAFE)

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