Focus on Post Approval

Changes and Change

Control Evaluation
Regulatory Best Practices
 CONTENTS
1. PREFACE

2. INTRODUCTION AND BACKGROUND

3. SCOPE

4. DEFINITIONS

ANNEXURE1: CHECKLIST FOR POST APPROVAL CHANGES & CHANGE

CONTROL EVALUATION

IPA Sub-Group 4: Focus on Post Approval Changes and Change Control Evaluation
 PREFACE
The IPA launched its Quality Forum (QF) in April 2015 to help Indian pharmaceutical manufacturers achieve parity with global
benchmarks in quality. The QF made a commitment to a multi-year journey to address key issues facing the industry and develop
best practices.

The QF focused on several priority areas in the last four years, viz., Data Reliability, Best Practices & Metrics, Culture & Capability,
Investigations, etc. It took upon itself the challenge of developing a comprehensive set of guidelines for several of these topics. In
this document, we focus on the best regulatory practices specifically focused on the Post approval changes (i.e., regulatory
reporting category evaluation and regulatory documents requirement for specific changes) & change control evaluation. This
document also highlights the key major sections of a sANDA application that, if appropriately and scientifically addressed at the
time of the original sANDA submission, leads to decrease in the number of deficiency points in the complete response letter (CRL)
and provides ways to avoid ‘Major’ category CRLs. In addition, this document identifies certain key areas of an sANDA application
which needs to be continuously monitored and communicated via suitable regulatory strategies, in order to obtain timely approval
of and sANDA application.

This document is the outcome of a concerted effort over the last few months by senior managers engaged in the regulatory
functions of six IPA member-companies. Mr. Vipul Doshi, Mr. Srinivas Gurram (Srini), Ms. Ranju Nijhawan, Mr. Bhaumik Modi and
Mr. Darshan Doshi (all in Cadila Healthcare); Mr. Pramod Dahibhate and Mr. Girish Chavan (Lupin); Mr. Dilkesh Shah (Torrent
Pharmaceuticals); Mr. G. Srinivas Rao and Mr. S Sri Rama Murthy (Dr Reddy’s Laboratories); Mr. P J Deepak (Sun Pharma); and
Mr. Ramakant Shukla and Ms. Praveena Manglorkar (Cipla). They shared current practices, benchmarked these with the existing
regulatory guidance from the USFDA and developed a robust draft document and got it vetted by leading subject matter experts.
The IPA acknowledges their hard work and commitment to the project.

The IPA also wishes to acknowledge the CEOs of six member-companies who have committed their personal time, human
resources and provided funding for this initiative.

IPA Sub-Group 4: Focus on Post Approval Changes and Change Control Evaluation 01
 This document, to be released at the IPA’s 6th India Pharmaceutical Forum 2021, will be hosted on the IPA website -
www.ipaindia.org – in order to make it accessible to all manufacturers in India and abroad.

Mumbai
February 2021

This document represents the current thinking of the Indian Pharmaceutical

Alliance (IPA) on this topic. It does not establish any rights for any person or
persons and is not binding on IPA or the public. An alternative approach may
be used as long as it satisfies the requirements of the applicable statutes and
regulations.

IPA Sub-Group 4: Focus on Post Approval Changes and Change Control Evaluation 02
 2 Introduction and Background

❖ The document covers recommended reporting categories for post approval changes for drugs other
than specified biotechnology and specified synthetic biological products.

❖ The key objectives of this regulatory best practice document are listed below:

❖ This document acts as a Ready Reckoner to determine the post approval submission category
as per US FDA’s various guidelines;

❖ Identification of post approval change submission requirements and intelligence at one place;

❖ Precise and easy change control assessment process;

❖ For the smooth life cycle management of the post approval changes.

❖ Various post approval changes have been broadly classified in to following categories. Detailed
regulatory requirements for each change is provided below in Annexure 1 of this document.

❖ Pharmacopeia Compliance;

❖ Type II DMF Notifications;

❖ Risk Mitigation Strategies;

❖ Increase Productivity or Trouble Shooting;

❖ Packaging Material Changes;

❖ Cost Improvement.

3 Scope

❖ This document provides recommendations to holders of Abbreviated New Drug Applications (ANDAs)
who intend to make post approval changes in accordance with section 506A of the Federal Food, Drug,
and Cosmetic Act (the Act) and § 314.70 (21 CFR 314.70).

IPA Sub-Group 4: Focus on Post Approval Changes and Change Control Evaluation 03
 4 Definitions

❖ Prior Approval Supplement (PAS):

❖ A major change is a change that has a substantial potential to have an adverse effect on the identity,
strength, quality, purity, or potency of a drug product as these factors may relate to the safety or
effectiveness of the drug product. A major change requires the submission of a supplement and
approval by the FDA prior to distribution of the drug product made using the change. This type of
supplement is called, and should be clearly labeled, a Prior Approval Supplement (§ 314.70(b)).

❖ Changes Being Effected in 30 Days (CBE-30) and Changes Being Effected (CBE) Supplement:

❖ A moderate change is a change that has a moderate potential to have an adverse effect on the identity,
strength, quality, purity, or potency of the drug product as these factors may relate to the safety or
effectiveness of the drug product. There are two types of moderate change. One type requires the
submission of a supplement to the FDA at least 30 days before the distribution of the drug product is
made using the change. This type of supplement is called, and should be clearly labeled, a Supplement
- Changes Being Effected in 30 Days (§ 314.70(c)(3)). In the second type, the FDA may identify
certain moderate changes for which distribution can occur when the FDA receives the supplement (§
314.70(c)(6)). This type of supplement is called, and should be clearly labeled, a Supplement -
Changes Being Effected.

❖ Annual Report:

❖ A minor change is a change that has minimal potential to have an adverse effect on the identity,
strength, quality, purity, or potency of the drug product as these factors may relate to the safety or
effectiveness of the drug product. The applicant must describe minor changes in its next Annual
Report (§ 314.70(d)).

IPA Sub-Group 4: Focus on Post Approval Changes and Change Control Evaluation 04
 Annexure 1
Checklist for post
approval changes &
change control
evaluation

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Published by:
Indian Pharmaceutical Alliance
A-205 Sangam 14B S V Road, Santacruz (W)
Mumbai 400 054, India
E-mail: sudarshan.jain@ipa-india.org

February 2021