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WHO Drug Information Vol. 25, No. 2, 2011

WHO Drug Information Vol. 25, No. 2, 2011

WHO Drug Information Vol. 25, No. 2, 2011

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<strong>WHO</strong> <strong>Drug</strong> <strong>Information</strong> <strong>Vol</strong>. <strong>25</strong>, <strong>No</strong>. 2, <strong>2011</strong>Quality Assurance IssuesScheme (PIC/S) and International Conferenceon Harmonisation (ICH) (USA,Japan, and EU) provide evidence of GMPstatus.Q23 What is the difference betweenapproval of the quality data in the submissionand evidence of GMP?A23 Approval of the quality information ina submission is a determination of howthe applicant proposes to manufactureand control the quality of the product atthe time of manufacture and throughoutthe life of the product.Evidence of GMP compliance confirmsthat the applicant company has been ableto demonstrate that the manufacturingfacilities and operations conform to goodmanufacturing practices (GMP) asrecommended by <strong>WHO</strong>.Q24 When would a CPP be required?A24 When the CPP replaces either a fullor partial quality, safety and efficacy(QSE) review. The CPP would be acondition of approval but it would not berequired at the time of submission.If local legislation stipulates provision of aCPP at the time of submission, theauthority review should comprise averification procedure with published,communicated timelines that should beshort and avoid delaying patient access.Q<strong>25</strong> Are there any alternatives to a CPPas evidence of approval by an MRA?A<strong>25</strong> In addition to the <strong>WHO</strong> CertificationScheme other forms of evidence include:• Product approval letters (or copies oflicences) from well-established MRAs,e.g., Australia, Canada, China, Denmark,Finland, Germany, India, Japan,<strong>No</strong>rway, Republic of Korea, Spain,United Kingdom, United States ofAmerica.• Positive scientific opinion from theEuropean Medicines Agency (EMA).• Decisions of the European Commission.• Licensing/approval information onregulatory authority web sites.• Evidence of approval on the UnitedStates Food and <strong>Drug</strong> Administrationweb site.Q26 Is it necessary for a pharmaceuticalproduct to be exported from the samecountry as the certifying authority?A26 <strong>No</strong>. It is not necessary for theproduct to be exported from the certifyingcountry as long as a declaration of GMPassurance appears on the CPP.The Scheme was established on thebasis that the certifying country was alsothe country where finished productmanufacture took place and was, therefore,the exporting country. Subsequentrevisions to the Scheme allow scope forCPPs to be issued by other referenceauthorities. Most certifying authoritiescurrently provide CPPs when the finishedproduct is not manufactured in the certifyingcountry on the basis of GMP assurance.Many authorities assume that certifyingauthorities issue CPPs even whenfinished product manufacture does notoccur in the certifying country. Strictadherence to the above assumptionpotentially limits licensing and registrationoptions and can delay the introduction oraffect the continued supply of neededmedicines.Q27 Is it possible to obtain a CPP from acertifying authority that is not of thecountry where the manufacture of thefinished product takes place?A27 Yes. The GMP declaration on theCPP will refer to assurance of GMP for117

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