Quality Measures in the Gulf Regulatory Practices

, Mohammed Al-Rubaie2, Stuart Walker3 and Sam Salek4



(1)
Regulatory Affairs Consultant Executive Directive, Kuwait Advancement for Conference and Exhibition Management, Kuwait, Kuwait

(2)
Ministry of Health, Directorate General of Pharmaceutical Affairs and Drug Control, Muscat, Oman

(3)
Founder of Centre for Innovation in Regulatory Science, London, UK

(4)
Department of Pharmacy School Life & Medical Sciences, University of Hertfordshire, Hatfield, UK

 




Introduction


Drug regulatory authorities are constantly challenged to develop and improve their capacity to regulate pharmaceutical products. Therefore, it is critical to develop regulations based on two broad objectives, namely, to provide technical assistance in establishing and implementing effective strategies for monitoring quality and correcting deficiencies and to refine existing methods to ensure optimal regulatory services through an applied quality management programme. The regulations must be broad enough to address all the essential issues, but flexible enough to be applied to specific problems.

In the world of medicines regulations, the term ‘quality’ is associated with data on the pharmaceutical characteristics of the medicinal product and the processes for chemical and manufacturing control (CMC). Increasingly, however, the term ‘quality’ is also being used in discussions of the drug regulatory process itself. It is not enough to measure regulatory performance in terms of timelines and the speed of the review process alone. The quality of the process, from the construction of the dossier to the ultimate regulatory decision, must also be monitored and added to the equation (Cone and McAuslane 2006).

Past attempts to compare review processes of different regulatory authorities have been hampered by insufficient public information, together with the complexity of the processes themselves. Even though, for some authorities, a review performance is becoming more transparent, the lack of uniformity between countries puts considerable limitations on the interpretation of different review times (CMR R&D Briefing 11 1997). Pressures on regulatory authorities from the general public for rapid access to new medicines have led health authorities worldwide to seek new measures for improving their own review processes. However, regulatory authorities are faced with the responsibility of reducing review timelines as well as maintaining the quality of the review procedures. To achieve this aim, the regulatory authorities should have a legal basis for all its functions, sufficient human and financial resources and access to appropriate scientific expertise and to a quality control laboratory. However, different regulators have different definitions of ‘quality’, but they all agree that the term is defined in the light of the provider’s standards and patients’ expectations. The quality of the review process stems from the quality of care provided to the public, and the degree of quality is the extent to which the care provided is expected to achieve the most favourable balance of benefits and harms (Donabedian 2005; Brown et al. 1998).

In order to assess the quality of the review process conducted in the GCC authorities, a clear understanding of the current situation, an identification of the practices and standards, the level of expertise and technical support as well as the accessibility to procedures and information within the authorities are essential. Therefore, the regulatory functions involved in the review procedures were examined, and a comparative view of the quality measures were established to produce a valuable insight into aspects of the good review practices (GRPs) in the GCC authorities.

The six GCC regulatory authorities (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and United Arab Emirates (UAE)) provided detailed information on the quality measures employed within their agency, and these were validated in face-to-face meetings. The GCC countries have the unique advantage of having a similar economic background and culture, the same language and similar historical background and political characteristics. These advantages are the main factors that play a prominent role in the success of the GCC Central Drug Registration (GCC-DR) system. Therefore, the GCC regulatory authorities, being in their developing stage, were chosen for comparison and to achieve standardisation on the basis of these similarities, unlike the systems of the mature agencies such as the United States Food and Drug Administration (US FDA), the European Medicines Agency (EMA), Health Canada and Australia’s Therapeutic Goods Administration (TGA) which are advanced and complex and differ significantly from one country to another.


General Measures Used to Achieve Quality


This information allowed a comparison of quality measures used officially across the six GCC authorities. The regulatory authorities are continuously developing and implementing a variety of measures to improve quality standards and to meet the expectations of the industry and the general public. Therefore, it was critical to assess the quality measures currently in place within each GCC regulatory authority and, where none, their plans to introduce such measures in the foreseeable future. A list of the assessed quality measures with their definitions are provided in Table 4.1.


Table 4.1
The general measures used to achieve a quality review process




























Quality measure

Definition

Quality policy

Overall intentions and direction of an organisation related to quality as formally expressed by top management

Good review practice (GRP)

A code about the process and the documentation of review procedures that aims to standardise and improve the overall documentation and ensure timeliness, predictability, consistency and high quality of reviews and review reports

Standard operating procedures (SOPs)

Written documents that describe in detail the routine procedures to be followed for a specific operation

Assessment templates

Set out the content and format of written reports on scientific reviews

Peer review

An additional evaluation of an original assessment that is carried out by an independent person or committee. Peer review can occur either during assessment of a dossier or at the time of sign-off

Shared and joint review

A shared review is one where each participating authority takes responsibility for reviewing a separate part of the dossier. A joint review is one where the whole dossier is reviewed by each authority, and the outcome is discussed before a decision is taken such as the GCC system


Quality Management Tools


Quality management tools can be considered to have two main components: quality assurance and quality improvement. Quality management is focused not only on product/service quality, but also the means to achieve it. It uses quality assurance and control of processes as well as products/services to achieve more consistent quality. In the context of this study, the means for assuring and improving quality in the review process were assessed, namely, the quality audit and feedback, the scientific committee review and the existence of the quality assurance (QA) infrastructure.


Communication as an Element of Quality


This section assessed practices used to ensure quality in the review process using the element of effective communication between the authority and the applicant in order to exchange critical information and official guidelines to assist the industry in the registration of medicines. Furthermore, the level of interaction with the applicants during the assessment of the registration dossier was examined to understand its impact on the efficiency and effectiveness of the decision-making in each authority.


Training and Continuing Professional Development (CPD) as an Element of Quality


This section was related to the training and continuing education of assessors working within the authority, including those employed on a full-time basis and those contracted for specific assessments where necessary. Furthermore, it assessed whether the training was followed by an examination once it was completed. The level of cooperation and collaboration between the GCC authorities and other authorities in the training and/or CPD programmes for reviewers was evaluated and whether external speakers were invited to provide informative lectures to the reviewers within the authorities.


Transparency of the Review Procedure


This section examined ‘transparency’ in terms of the ability and willingness of the authorities to assign time and resources to providing information on its activities to both the public (which includes health professionals) and the industry. Transparency was measured in terms of the level of information made available and how important the authorities believe that increased transparency is to determine the quality of the review processes.


Drivers and Barriers


The purpose of this section was to identify the most common reasons for introducing quality measures as viewed by each participating authority as well as to understand the unique positive qualities and the major impediments they are facing in carrying out the review of new medicines to making them available to meet patients’ needs. Each authority was asked to provide three factors that make a major contribution to the effectiveness and efficiency of its review procedures and decision-making processes and three factors that act as barriers to making new medicines available in a timely manner through their regulatory process.

The outcomes obtained from the six authorities represent their experiences during the year of this study (2010). However, variations can occur in practice due to continuous changes in the regulatory systems in the GCC region.


General Measures Used to Achieve Quality


Six quality measures were considered critical in the evaluation of the regulatory review process in the Gulf states, namely, joint and shared review (JR/SR), peer review (external and internal), assessment templates, standard operating procedures (SOPs), good review practice (GRP) and a quality policy (QP). The GCC authorities completed all the questions, and where questions were not applicable, no response was provided. However, the answers received were sufficient to provide the required information for the study. Furthermore, the respondents had the opportunity to express their comments and viewpoints in more detail for each question.

The measures currently used by each GCC regulatory authority to achieve quality in the review process are shown in Table 4.2. The results indicated that a joint review is the only quality measure shared by all six GCC authorities. It is a practice that is performed by all the authorities for the GCC Central Drug Registration (GCC-DR) system, where a dossier is reviewed by each authority and the outcome is discussed in a conference meeting after which the decision is made by consensus. The other quality measures are practised in some authorities, whilst other authorities have plans to implement them in the future.


Table 4.2
Measures used to achieve quality in the GCC review processes












































































Quality measure

Bahrain

Kuwait

Oman

Qatar

Saudi Arabia

UAE

Quality policy







Good review practice (GRP)







Standard operating procedures (SOPs)







Assessment templates







Internal peer reviews







External peer reviews







Shared/joint reviews








Quality Policy


This is the overall intentions and direction of an organisation related to quality as formally expressed by top management. It aims at improving the performance of the reviewers, and the activities involved focus entirely on the term ‘quality’ of the review process. To establish whether the review process is acceptable and the registration procedure fulfils the desired quality standard, a quality policy must be decided by the top management for the achievement of satisfactory results. Three out of six authorities stated that they have quality policies (Bahrain, Kuwait and UAE), whereas the other three authorities are planning to introduce them in the foreseeable future.


Good Review Practice (GRP)


The six authorities were asked whether they implement a GRP system. GRP was defined as a code about the process and documentation of review procedures that aim to standardise and improve the overall documentation and ensure timeliness predictability, consistency and high-quality reviews and review reports (Table 4.1). Unfortunately, only Bahrain stated that they implement the GRP system. Kuwait explained that the Ministerial Decree 302/80 is being used as a good guidance for both assessors and the industry through the scientific assessment process. However, Kuwait, as well as the other GCC states, has begun to implement the full GRP system by adopting the Common Technical Document (CTD) format which has been playing an effective role in improving the quality of the review process and standardising the assessment practices in the Gulf region. GRP has been introduced in all well-established authorities; for example, Canada initiated it in 2004, whilst it has been conducted for more than a decade by the US FDA (Health Canada 2008; Garrett 2009).


Standard Operating Procedures (SOPs)


This measure is defined as the formal documents that clearly and accurately describe how an individual or organisation should be performing a certain task. A standard operating procedure (SOP) is a compulsory document which describes the regularly recurring operations relevant to the quality of the investigation. The purpose of SOPs is to carry out the procedures correctly and always in the same manner and should be available at the place where the work is done. In the GCC states, four out of six countries use SOPs for the guidance of scientific reviewers (Bahrain, Oman, Qatar and UAE), whereas the other two expressed their intentions to implement this quality measure in the near future.


Assessment Templates


Four out of six authorities in the GCC region use assessment templates for reports on the scientific review of a New Active Substance (NAS) and an Existing Active Substance (EAS) (Bahrain, Kuwait, Saudi Arabia and UAE). These templates are an important quality measure that set out the content and the format of the written scientific assessment reports. Oman and Qatar indicated that they intend to introduce assessment templates in the near future.


Peer Review


Peer review is an additional evaluation of an original assessment that is carried out by an independent person or committee. Peer review can occur either during the assessment of a dossier or at the time of sign-off. It can occur internally at different levels within an authority, which can help to build quality into the review process. Four out of six authorities stated that they perform internal peer reviews through their established scientific committee that evaluates the reviewer’s assessment reports, whilst only two authorities stated that they also carry out external peer reviews to ensure that the registration dossier is of the desired quality. Kuwait and Qatar do not perform peer reviews, and the review is totally dependent on the qualification and experience of the reviewer. However, Qatar has a registration committee that makes the final approval decision should the assessment report show positive outcomes. In Kuwait, the drug registration and release superintendent (DRRS) reviews the scientific report made by the assessor and makes the final decision.


Shared/Joint Reviews


All the GCC authorities stated that they conduct joint reviews as part of the GCC Central Drug Registration (GCC-DR) system. A joint review was described as a procedure where the whole dossier is reviewed by each authority, and the outcome is discussed before the decision is taken by the agreement between the six states (and Yemen). The GCC states took these initiatives from the European centralised procedure where joint reviews of the registration dossier is carried out by the EU member states. In a shared review, however, each authority takes responsibility for reviewing a separate part of the dossier. This is not applicable in the GCC regulatory system. A shared review is conducted internally within different divisions of the State Food and Drug Administration in China (Deng and Kaitin 2004). Shared reviews are rarely carried out in well-established authorities. However, memorandums of understanding have been signed between the TGA, Swissmedic, Health Canada and Health Science Authority (HSA) in Singapore in order to facilitate the opportunity for these four agencies to carry out shared and joint reviews (HSA 2010).


Quality Audits and Feedback


When the GCC authorities were asked about activities they were undertaking to achieve continuous improvement in the assessment and registration process, two responses were provided by the GCC authorities, namely, reviewing the assessor’s feedback (Bahrain, Kuwait, Qatar, Saudi Arabia and UAE) and the stakeholder’s feedback (Bahrain, Kuwait, Oman, Qatar and Saudi Arabia) to take the necessary action accordingly (Table 4.3).


Table 4.3
Quality audit and feedback activities carried out to improve the quality of the assessment and registration process in the GCC states




































































Activities that bring improvement in the review process

Bahrain

Kuwait

Oman

Qatar

Saudi Arabia

UAE

Reviewing assessors’ feedback and taking necessary action







Reviewing stakeholders feedback and taking necessary action







Using an internal tracking system to monitor (e.g. consistency, timeliness, efficiency and accuracy)







Carrying out internal audits and using findings to improve the system







Having external quality audits by an accredited certification body to improve the system







Having a ‘post-approval’ discussion with the sponsor to provide feedback on the quality of the dossier and obtain the company’s comments







Four authorities have an internal tracking system to monitor the quality of the review process (Bahrain, Kuwait, Oman and Saudi Arabia). However, in general, the GCC authorities lack the appropriate electronic tracking system to monitor the impact of each of the review milestones and the activities performed within these milestones on the overall approval time. Furthermore, the study showed that four authorities carry out internal audits (Bahrain, Oman, Qatar and Saudi Arabia). However, the logistics behind conducting such audits are questionable. Some regulators view an internal audit as reassessing the review by a senior assessor to ensure that it is of the required quality standard, whilst others view it as an independent activity performed by a separate section/unit on different departments or processes (Table 4.3).

External audits can be carried out by accredited certification bodies such as the International Organization for Standardization (ISO), the European Foundation for Quality Management (EFQM) or by WHO audits. Oman was the only authority that indicated its engagement in external auditing by an accredited certification body to improve the quality of its registration process. External audits are essential to provide an objective opinion on the quality of the review process, discover errors that may be overlooked by the internal reviewers and educate regulators on the importance of the current regulatory issues that need to be considered in the process of improving the quality of the assessment and decision-making process.

Post-approval feedback is another important practice to provide the sponsor with an opportunity to improve the quality of the submitted data after issuing the registration approval of a medicinal product. On the other hand, the authority will also benefit from the objective pre-approval discussion about issues that could impact the consistency, accuracy, transparency and timeliness of the approval process. This exchange of constructive feedback between the two stakeholders can have a significant impact on the quality of the review and decision-making outcomes.


Quality Assurance Infrastructure


Finally, only Kuwait has a dedicated department or unit for the quality assurance of the assessment and registration process. Whilst Kuwait has a small unit consisting of two pharmacists, the unit does not yet officially exist in the current organisational structure of the authority, and its functions are not fully regulated or enforced. UAE stated that the quality assurance department does not exist for the assessment and registration process, but it does have an independent department reporting to the CEO of the Medical Practices and Licensing, to which the Registration and Drug Control Department reports. Nevertheless, their work has not yet been fully implemented.


Scientific Committee Procedure


The study also examined the existence of committees and their associated procedures involved in the review process. Committees are a necessary aspect of organisations of any significant size (i.e. more than 15 or 20 people), and they are a way to formally draw together people of relevant expertise from different parts of an organisation who otherwise would not have an appropriate way to share information and coordinate actions. They may have the advantage of sharing viewpoints and responsibilities. They can also be supported with experts to recommend actions in matters that require specialised knowledge or technical judgment. After assessing the committee’s procedures as an element to improve the quality of the registration of medicines in each authority, it was found that Kuwait and Qatar did not have scientific committees that are integrated into their assessment procedure, and therefore they were not included in this part of the assessment (Table 4.4).


Table 4.4
Description of the scientific committees in four GCC authorities
































































Description

Bahrain

Oman

Saudi Arabia

UAE

Committee

RCa

TCR&Pa

SACa

SCa + HRCa

Meeting frequency

Once a month

Every 2 weeks

Once a week

Every 2 months

Number of members

8

8

19

Average 5

Committee reviews all applications (NASs/EASs)





Committee reviews selected applications (NASs/EASs)





Committee reviews complete dossier





Committee reviews assessment reports from reviewers





Committee makes the final approval decision






a RC registration committee, TCR&P technical committee for registration of pharmaceutical companies and their products and pricing, SAC scientific advisory committee, SC scientific committee, HRC higher registration committee, TCR technical committee for registration

However, Qatar does have a registration committee that makes the final approval decision, and Kuwait has recently begun adopting this approach as well. In three authorities (Saudi Arabia, Oman and Bahrain), the committees are responsible for assessing the applications and making the final approval decision. However, in UAE, separate scientific committees exist for each area, e.g. stability, quality control, GMP, bioequivalence studies, minor variations and internal peer reviews and external screening committee. All reports of the scientific committees are then discussed in the higher registration committee after the scientific committees have given their opinions, and the higher registration committee then makes the final approval decision.

Only gold members can continue reading. Log In or Register to continue

Stay updated, free articles. Join our Telegram channel

Sep 18, 2016 | Posted by in PHARMACY | Comments Off on Quality Measures in the Gulf Regulatory Practices

Full access? Get Clinical Tree

Get Clinical Tree app for offline access