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Policy considerations for originator and similar biotherapeutic products 原研药和类似生物治疗制剂的政策考虑
Pub Date : 1900-01-01 DOI: 10.3233/PPL-160438
G. Grampp, R. Kozak, Thomas Schreitmueller
Biotherapeutic products (BTPs), also known as biotherapeutic medicines, contain structurally complex active substances produced by living organisms. Due to their complexity and method of manufacture BTPs require distinct regulatory approval standards relative to chemically-synthesized small molecule medicines. This is also relevant for licensing copied versions of a BTP, or similar biotherapeutic products (SBPs) made by a different manufacturer where regulatory concepts developed for generics should not have been applied. In all these licensing scenarios regulators need to evaluate the results of comparability exercises, including sensitive head-to-head analytical, pre-clinical and clinical comparisons with the original product as a basis for approval. SBPs do not contain chemically identical active substances, and may have slightly different benefit-risk profiles, therefore it is necessary to monitor post-approval safety on a product-specific basis. Policymakers may therefore emphasize the need for product-specific identification in patient records and safety reports using either a unique trade name or a distinguishable non-proprietary naming system. The unique nature of BTPs also informs the nature and degree of interchangeability between the originator and SBPs versions. Many policymakers also emphasize that switching between SBPs should only occur with the involvement of the prescriber. It is recommended that pharmacy substitution would only be appropriate when there is a robust framework for a competent authority to assess product-specific evidence of interchangeability. Another challenge is posed by the historical existence in some jurisdictions of copy BTPs that were not assessed according to current regulatory standards. To address this situation the World Health Organization has proposed a regulatory assessment framework wherein the status of such products can be normalized via the orderly submission and review of supplementary data.
生物治疗产品(BTPs),也称为生物治疗药物,含有由生物体产生的结构复杂的活性物质。由于其复杂性和制造方法,相对于化学合成的小分子药物,btp需要不同的监管批准标准。这也适用于由不同制造商生产的仿制BTP或类似生物治疗产品(sbp)的许可,这些仿制药不应适用为仿制药制定的监管概念。在所有这些许可情况下,监管机构需要评估可比性练习的结果,包括敏感的头对头分析,与原始产品的临床前和临床比较,作为批准的基础。SBPs不包含化学上相同的活性物质,并且可能具有略微不同的利益-风险概况,因此有必要在特定产品的基础上监测批准后的安全性。因此,政策制定者可能会强调在患者记录和安全报告中使用唯一的商品名称或可区分的非专有命名系统进行产品特定标识的必要性。btp的独特性质也决定了原始版本和sbp版本之间可互换的性质和程度。许多政策制定者还强调,只有在开处方者参与的情况下,才能在SBPs之间进行转换。建议只有当主管当局有一个健全的框架来评估产品特定的可互换性证据时,药房替代才是合适的。另一个挑战是,在一些司法管辖区存在未按现行监管标准评估的复制btp。为了解决这一问题,世界卫生组织提出了一个监管评估框架,其中可以通过有序提交和审查补充数据使此类产品的状况正常化。
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引用次数: 4
Designation, plausibility, protocol assistance, clinical benefit, similarity, reassessment: Rules and experiences 名称,合理性,方案援助,临床效益,相似性,重新评估:规则和经验
Pub Date : 1900-01-01 DOI: 10.3233/PPL-2010-0269
Chris Walker
Orphan legislation provides incentives to industry to investigate rare conditions that otherwise would be unlikely to be investigated. These incentives include, free access to scientific advice during the development of their clinical programs (‘protocol assistance’); reduction in fees payable to EMA for review of the marketing authorisation and subsequent licence maintenance fees; sustained market protection in the form of market exclusivity in addition to a range of national incentives. To qualify for these incentives companies must apply for orphan designation confirming the seriousness of the condition which has inadequate alternative therapeutic options (for the diagnosis, prevention or treatment) and that the condition qualifies in terms of low prevalence in the European community. The company must also provide evidence of medical plausibility including likely significant medical benefit for patients to be treated with the product for the proposed orphan indication. If an application for orphan designation is not accepted then a company is able to appeal providing detailed grounds for reassessment and will receive a second opinion from the PDCO. The period of market exclusivity awarded by orphan designation will require that future applications received by the EMA for the same condition have to undergo an assessment of similarity to ensure that no variations or new applications for ‘similar’ medicinal products are granted licences during this ten year period. Products gaining orphan designation provide regular/annual reports regarding their development status, status of global regulatory submissions and any change likely financial returns predicted for the indication.
孤儿立法为行业提供了调查罕见疾病的激励,否则这些疾病不太可能被调查。这些激励措施包括:在制定临床方案期间免费获得科学建议(“方案援助”);减少支付给EMA的上市许可审查费用和随后的许可证维持费;除了一系列国家激励措施外,还以市场独占的形式提供持续的市场保护。为了获得这些奖励,公司必须申请孤儿指定,确认疾病的严重性,没有足够的替代治疗方案(用于诊断、预防或治疗),并且该疾病在欧洲共同体的患病率较低。公司还必须提供医学合理性的证据,包括可能对孤儿症患者的重大医疗益处。如果孤儿药指定申请未被接受,则公司可以提出上诉,提供重新评估的详细理由,并将收到PDCO的第二份意见。孤儿药指定授予的市场独占期将要求EMA收到的针对相同病症的未来申请必须进行相似性评估,以确保在这10年期间没有“类似”药品的变体或新申请被授予许可。获得孤儿药认定的产品提供定期/年度报告,内容包括其开发状态、全球监管提交状态以及该适应症预测的任何可能的财务回报变化。
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引用次数: 0
Drugs labelling, leaflets and packing in European pharmaceutical law with special reference to the Spanish and Italian cases 药品标签,传单和包装在欧洲药法,特别参考西班牙和意大利的情况
Pub Date : 1900-01-01 DOI: 10.3233/PPL-2010-0298
Francisco Bombillar
The drug, as a technical product, has been created in order to control and dominate nature. Thus, the pharmaceutical industry acts against infections and diseases in nature, as well as other attacks on our health that can weaken it or bring it to a complete end. Unfortunately, these technologies are not innocuous; they eliminate “threats” but create “risks”, even for the health-related object of protection (suffice to say the side effects of drugs like Vioxx or Thalidomide). Not surprisingly, from its earliest origins the word “drug” has referred to a substance that can be harmful, as well as ultimately, healing. These products are not safe. Therefore, the Legislator has created an assumption of risk: it is supposed
药物作为一种技术产品,被创造出来是为了控制和支配自然。因此,制药业的行动是为了对抗自然界的感染和疾病,以及其他可能削弱或彻底终结我们健康的攻击。不幸的是,这些技术并非无害;它们消除了“威胁”,但也产生了“风险”,甚至对于与健康有关的保护对象(足以说明万克或沙利度胺等药物的副作用)。毫不奇怪,“毒品”一词最早的起源指的是一种有害的物质,最终也可以治愈。这些产品不安全。因此,立法者创造了一个风险假设:这是假定的
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引用次数: 2
Economic tools for ensuring access to medicines in Latin American countries 确保拉丁美洲国家获得药品的经济工具
Pub Date : 1900-01-01 DOI: 10.3233/PPL-140385
F. Tobar, Evangelina Martich
Summary: The greatest challenges for pharmaceutical policies in Latin American countries are related to the objective of promoting access for their populations. Around two thirds of the spending on medicine in the region is financed by household incomes, with a strong regressive effect on their financing. For these reasons, the economic regulation tools for controlling spending and prices of medicines take on singular importance. The present article examines a set of measures implemented by the countries in the region for the economic regulation of medicines centred on ensuring access to them, emphasizing those intended to control the prices of the pharmaceutical products and those oriented to moderating the spending on medicines in the health systems.
摘要:拉丁美洲国家药品政策面临的最大挑战与促进其人口获得药品的目标有关。该地区约三分之二的医药支出由家庭收入提供资金,这对家庭的资金来源产生了强烈的递减效应。由于这些原因,控制药品支出和价格的经济调控工具具有独特的重要性。本文审查了该区域各国为确保获得药品而对药品进行经济管制所执行的一套措施,强调了那些旨在控制药品价格的措施和那些旨在减少保健系统药品支出的措施。
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引用次数: 1
How is Italian pharmacy changing and what is the new direction: A modern health post or a drug-store? 意大利的药房正在发生怎样的变化?新的发展方向是什么?是现代保健站还是药店?
Pub Date : 1900-01-01 DOI: 10.3233/PPL-2010-0306
P. Cicconetti
List of the new health (professional) and social (administrative) services provided by pharmacy according to new Italian law and National Health Service Authority; weak and strength points, examination of all the aspects. New health services are important to give effort to the pharmacist role, on the other hand the social ones need time and human resources to run. Some pharmacy provides a wide range of services for free already and small pharmacies cannot compete due to problems dealing with the surface of the shop or with the number of employees. New strategies oriented to help and protect small pharmacies are vital, but the most important thing is to create a network of pharmacies that will offer new services; everyone must join it, we do not want pharmacies lack in knowledge in the future and not professional.
根据新的意大利法律和国家卫生服务管理局,药房提供的新的卫生(专业)和社会(行政)服务清单;分弱项和长处,考查各方面。新型卫生服务必须发挥药师的作用,而社会卫生服务的运行则需要时间和人力资源。一些药店已经免费提供广泛的服务,而小药店由于处理商店表面或员工数量的问题而无法竞争。以帮助和保护小型药店为导向的新策略至关重要,但最重要的是建立一个提供新服务的药店网络;每个人都必须加入其中,我们不希望药剂师在未来缺乏知识和不专业。
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引用次数: 0
Pharmacoeconomic evidence and policies to promote use of generic medicines in Jordan 促进约旦仿制药使用的药物经济学证据和政策
Pub Date : 1900-01-01 DOI: 10.3233/PPL-170448
F. El‑Dahiyat
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引用次数: 3
Activity of Ethics Committees in Europe on issues related to clinical trials in paediatrics: Results of a survey 欧洲伦理委员会在儿科临床试验相关问题上的活动:一项调查结果
Pub Date : 1900-01-01 DOI: 10.3233/PPL-2009-0208
A. Altavilla, C. Giaquinto, D. Giocanti, C. Manfredi, J. Aboulker, F. Bartoloni, E. Cattani, M. L. Giudice, M. J. M. Peña, R. Nagler, C. Peterson, O. Vajnerová, F. Bonifazi, A. Ceci
The rights and well-being of children involved in clinical research in Europe should be assured by the respect of ethical considerations and legal rules. Specific provisions are included in the Directive 2001/20/EC (CT-Dir) aimed at providing a homogeneous ethical and legal context to perform clinical trials in Europe. The TEDDY Network of Excellence carried out a “Survey on the ethical and legal frameworks existing in Europe for paediatric clinical trials” to examine the measures enforced by Member States to implement the CT-Dir and other relevant ethical norms. The results showed that many differences exist in the protection of children enrolled in clinical trials. Such differences are especially due to a non-coordinated implementation of the Directive’s Article 4 and a lack of public awareness on ethical issues in this field. The recently approved ‘Ethical considerations for clinical trials on medicinal products conducted with the paediatric population’ should speed up the implementation of an ‘ad hoc set of ethical rules’ and increase the level of minors’ protection. Nevertheless, in lack of ‘binding rules’, a coordination at European level is still needed. Public initiatives aiming at promoting in-depth debates have to be supported in order to encourage this process of coordination.
在欧洲,参与临床研究的儿童的权利和福祉应通过尊重伦理考虑和法律规则得到保证。指令2001/20/EC (CT-Dir)中包含了具体规定,旨在为在欧洲进行临床试验提供统一的伦理和法律环境。TEDDY卓越网络开展了一项“关于欧洲现有儿科临床试验伦理和法律框架的调查”,以审查成员国为实施CT-Dir和其他相关伦理规范而采取的措施。结果表明,在保护参加临床试验的儿童方面存在许多差异。这种差异主要是由于指令第4条的执行不协调以及公众对该领域道德问题缺乏认识。最近批准的《针对儿科人群进行药品临床试验的伦理考虑》应当加快“一套特别伦理规则”的实施,并提高对未成年人的保护水平。然而,由于缺乏“约束性规则”,欧洲层面的协调仍然是必要的。必须支持旨在促进深入辩论的公共倡议,以鼓励这一协调进程。
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引用次数: 9
A public health perspective on the effectiveness of European pharmaceutical regulation 从公共卫生角度看欧洲药品管制的有效性
Pub Date : 1900-01-01 DOI: 10.3233/PPL-2011-0316
Rafael Bauschke
After more then four decades, the regulation of pharmaceuticals still is an evolving and much discussed topic within Europe from a political and economic perspective. Even though the benefits of regulatory harmonization remain uncontested, the constant review and evaluation of the sector may raise public concerns regarding regulatory performance. If regulatory 0experts still see the need for improving existing regulatory provisions, there is reason to believe that the current system does not live up to its expectations. An assessment of regulatory effectiveness, depicting the degree of goal attainment, provides a systematic answer to such questions. Drawing on the regulatory framework, the governance and the outcomes of the regulatory process the development of regulatory effectiveness since the beginnings of European regulation in the sector is discussed. While a continuous improvement from the perspective of effectiveness is traceable throughout time, some issues impeding the performance of the regulatory regime remain. Even though the pharmaceutical package may help to mitigate some of the identified problems, additional efforts will be necessary to finally strengthen the effectiveness of European pharmaceutical regulation and public health.
四十多年后,从政治和经济的角度来看,药品监管仍然是欧洲一个不断发展和讨论的话题。尽管监管协调的好处仍然是无可争议的,但对该部门的不断审查和评估可能会引起公众对监管绩效的关注。如果监管专家仍然认为有必要改善现有的监管规定,那么有理由相信,当前的体系没有达到他们的预期。对监管有效性的评估,描述了目标实现的程度,为这些问题提供了一个系统的答案。利用监管框架、治理和监管过程的结果,讨论了自欧洲监管开始以来监管有效性的发展。虽然从有效性的角度来看,持续的改进是可以追溯的,但一些阻碍监管制度发挥作用的问题仍然存在。尽管药品一揽子计划可能有助于减轻某些已查明的问题,但仍需要作出更多努力,最终加强欧洲药品管制和公共卫生的效力。
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引用次数: 1
Scientific advice in EU for products for treatment of rare diseases 欧盟对治疗罕见疾病产品的科学建议
Pub Date : 1900-01-01 DOI: 10.3233/PPL-2010-0270
Katrin Rupalla
The national scientific advice procedure can vary from country to country, with some national regulatory agencies not giving advice at all. Usually it is a face-toface meeting, for which there are no pre-specified dates. It can be requested at any time during the development process, also while concerned studies are in progress. The national procedure timelines are flexible and depend upon a local procedure, and can last from two to four months. The procedure is coordinated by a group of national staff, which often includes CHMP and SAWP members of the Agency, but can involve external experts as well. Essentially, the national scientific advice is a national opinion around issues concerning pre-clinical development, clinical development (trial design, statistical methods, RMP, etc), and quality aspects. Any deviation from the advice has to be justified. The advantages of asking a national scientific advice revolve around the flexibility of the procedure, with the possibility of having face-to-face meetings and ask general questions, as well as addressing specific national issues. On the other hand, timelines for the procedures are very variable, in particular when external experts are required. In addition, the national agency may ask the sponsor to go to CHMP for scientific advice. Finally it is important to consider that the national advice is the opinion from a single country and may diverge from the EU-wide position. In fact, the national advice is perceived as non-binding by some EU regulators.
国家科学咨询程序因国家而异,有些国家监管机构根本不提供咨询。通常是面对面的会议,没有预先指定的日期。可以在开发过程中的任何时候提出要求,也可以在进行有关研究时提出要求。国家程序时间表是灵活的,取决于当地程序,可能持续两到四个月。该程序由一组国家工作人员进行协调,其中通常包括机构的卫生防护中心和卫生计划成员,但也可以包括外部专家。从本质上讲,国家科学建议是围绕临床前开发、临床开发(试验设计、统计方法、RMP等)和质量方面的问题的国家意见。任何偏离建议的行为都必须是合理的。征求国家科学建议的好处在于程序的灵活性,有可能举行面对面的会议并提出一般性问题,也有可能解决具体的国家问题。另一方面,这些程序的时间表变化很大,特别是在需要外部专家的情况下。此外,国家机构可能会要求申办者去CHMP寻求科学建议。最后,重要的是要考虑到国家建议是来自单个国家的意见,可能与整个欧盟的立场不同。事实上,一些欧盟监管机构认为,各国的建议不具约束力。
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引用次数: 0
The concerns and problems facing Alpha-1 Antitrypsin Deficiency patients α -1抗胰蛋白酶缺乏症患者的担忧和问题
Pub Date : 1900-01-01 DOI: 10.3233/PPL-2009-0228
L. Warren
Alpha-1 Antitrypsin Deficiency (AATD) is probably the most common life threatening inherited disease in Europe. It is estimated that in excess of 100,000 individuals on the Continent suffer from it. It fatally affects the lungs (emphysema) and liver (cirrhosis). As the only therapy for liver AATD is transplantation and as lung disease is far more common, I shall confine my remarks to lung related AATD for which replacement (augmentation) therapy has been developed and is fairly widely used. This is a plasma derived product and is IV delivered. An inhaled product is currently being developed also. However, most patients do not know that they have the condition and most doctors do not know that some of their patients have the condition either. This is true even with symptomatic patients. They are usually diagnosed with Asthma or COPD. This in turn, means that they are being inappropriately treated with therapies that do little for their condition of Alpha-1 Antitrypsin Deficiency. It has been estimated in the USA that it takes an average of five doctors, over a seven year period, to diagnose the condition in a patient. Even after that long delay there is no guarantee that an Alpha-1 patient will be diagnosed. To date, only c. 5% have been diagnosed in the countries that are looking for them. AATD is a deficiency of a vital lung protecting protein. Therefore, it would seem that the obvious therapy is to replace or augment that which is lacking. This therapy has been developed and is now being widely used in the USA and in Europe. In Europe it is licensed and prescribed in the following countries:
α -1抗胰蛋白酶缺乏症(AATD)可能是欧洲最常见的威胁生命的遗传性疾病。据估计,非洲大陆有超过10万人患有此病。它会致命地影响肺(肺气肿)和肝(肝硬化)。由于肝脏AATD的唯一治疗方法是移植,而肺部疾病更为常见,因此我将只讨论与肺相关的AATD,其中替代(增强)疗法已经开发出来,并得到了相当广泛的应用。这是一种血浆衍生产品,静脉给药。一种吸入产品目前也正在开发中。然而,大多数患者并不知道他们有这种情况,大多数医生也不知道他们的一些患者有这种情况。即使是有症状的患者也是如此。他们通常被诊断为哮喘或慢性阻塞性肺病。反过来,这意味着他们正在接受不恰当的治疗,而这些治疗对他们的α -1抗胰蛋白酶缺乏症几乎没有作用。据估计,在美国,平均需要5位医生在7年的时间里诊断出一个病人的病情。即使经过这么长时间的拖延,也不能保证Alpha-1患者会被诊断出来。迄今为止,在正在寻找这些疾病的国家,只有5%的人被诊断出来。AATD是一种重要的肺保护蛋白的缺乏。因此,显而易见的治疗方法似乎是替换或增加所缺乏的东西。这种疗法已经被开发出来,现在在美国和欧洲被广泛使用。在欧洲,它在以下国家获得许可和规定:
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引用次数: 0
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Pharmaceuticals, policy and law
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