GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009
GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS
HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 1 of 13
APPENDIX 15 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 & MIV-2) FOR BIOLOGICS
TABLE OF CONTENTS
PART A: INTRODUCTION.............................................................................................. 2
PART B: DOSSIER REQUIREMENTS FOR BIOLOGICS MIV-1 ................................... 2
B1 Change of Manufacturing Site............................................................................4 B2 Change of Testing Laboratory............................................................................4 B3 Change of Manufacturing Process .....................................................................4 B4 Change of Test Procedure .................................................................................5 B5 Change of Specifications....................................................................................5 B6 Change of Container Closure System................................................................5 B7 Change of Shelf Life and/or Storage Condition..................................................6 B8 Change of Excipient ...........................................................................................6 B9 Change of Product Label....................................................................................6 B10 Seasonal Variation of Influenza Strains for Vaccine...........................................7
PART C: DOSSIER REQUIREMENTS FOR BIOLOGICS MIV-2 .................................... 8
C1 Change of Contact Person.................................................................................8 C2 Change of Product Name...................................................................................8 C3 Change of Product Owner..................................................................................9 C4 Change of Batch Numbering System.................................................................9 C5 Renaming of Manufacturing Site........................................................................9 C6 Change of Batch Release Site ...........................................................................9 C7 Addition or Replacement of Secondary Packaging Site...................................10 C8 Withdrawal of Manufacturer or Manufacturing Site ..........................................10 C9 Deletion of Pack Size for Drug Product............................................................10 C10 Change of Secondary Packaging.....................................................................10 C11 Change of Impirints, Bossing, or Other Markings (except Score/Break Line on Tablet or Printing on Capsule Including Addition or Change or Inks Used for Product Marking................................................................................................10 C12 Change of Dimensions of Tablet, Capsule, Suppository or Pessary Without Change in Qualitative and Quantitative Composition and Mean Mass .............11 C13 Change in Colouring or Flavouring System of Product Including Addition, Deletion or Replacement of Colourant(s) or Flavourant(s)................................12 C14 Quantitative Change in Coating Weight of Tablet or Weight of Capusle Shell.12 C15 Change of Product Labelling due to Safety Updates........................................12 C16 Change of Product Labelling............................................................................13 C17 Change of Product Labelling of Language(s) Other Than English...................13 GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 2 of 13
PART A: INTRODUCTION
This document describes the requirements of a Minor Variation Application (MIV) submitted for an existing registered biologic drug product in Singapore. Applicants should be familiar with the contents of this document, the Guidance on Medicinal Product Registration in Singapore and the governing legislation prior to submitting an MIV to HSA.
Minor Variation Applications are divided into two sub-categories: MIV-1: A minor variation which requires regulatory approval MIV-2: A minor variation or an administrative change which does not require regulatory approval; i.e., notification.
If an MIV contains multiple proposed variations that belong to both MIV categories, the MIV should be categorized as an MIV-1. If a proposed MIV-2 does not meet its specified conditions, then the MIV must be categorized as an MIV-1 with supporting documents. HSA reserves the right to re-categorise the MIV if deemed appropriate.
Registration Process
A minor variation application (MIV) is submitted via the Amendment to a Licence of Western Drug Product form in PRISM.
Applicants should fully disclose all proposed change(s) under Section 0.4 Amendment Summary in Section 0 Licence Summary, and in the Table of Amendment Details. The Table template can be downloaded via the link indicated in Section 0.5 Amendment Details. Any undisclosed variation(s) embedded in the submitted data, or any flow-on changes not specifically requested by HSA, will not be considered for evaluation.
NOTE: Applicants are encouraged to fax or email the MIV Filing and Submission Inquiry Form in Appendix 13 for any issues regarding MIV filing. GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 3 of 13
Documentary Requirements
The following documents must be submitted with each MIV submission, as given in Table A below:
Hard Copy E-Copy PRISM application form Yes N/A Table of Contents Yes Optional* Checklist for MIV applications Yes Optional* Table of Amendment Details Yes PRISM MIV-specific Supporting documents - Administrative (Module 1/Part 1) - Other supporting documents
Yes Optional
PRISM PRISM/CD Relevant CTD section(s) of the currently registered version with the proposed change(s) clearly annotated Optional PRISM/CD Current and proposed product labelling (annotated and pristine copies), where applicable Yes PRISM * E-copies may be submitted via PRISM or CD-ROM.
Table A. MIV Application Hard Copy and Electronic Copy Requirements
The Checklist for Minor Variation Applications for Biologic Drugs is located in Appendix 15A and 15B of this guidance document. This Checklist serves as a guide for submitting the required documents relevant to each proposed MIV. When submitting the Checklist, the following should be included: A copy of the relevant checklist(s) to each proposed MIV(s) the boxes should be checked to ensure that the required documents are included in the submission; and, The Declaration for the MIV with the submission date and the local applicants name and signature.
The Table of Amendment Details concisely describes the proposed MIV(s). The following information must be stated in the Table: Section of the original dossier affected by the change(s); Current and proposed condition(s); Reason for the change(s); and, Registration status and date of the proposed change(s) in other countries.
The required documents for each proposed MIV-1 or MIV-2 variation are specified in Part B or Part C of this document respectively. For an MIV application with multiple related or unrelated variations, all of the supporting documents for each individual variation should be submitted. If the required documents have not been submitted, justification must be provided.
This document reflects the current thinking of HSA on the minimum data necessary for assessment. Applicants are responsible for ensuring that all necessary validations were conducted to demonstrate that the change does not adversely affect the quality, safety or efficacy of the product concerned. HSA reserves the right to request additional information if deemed appropriate.
GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 4 of 13
PART B: DOSSIER REQUIREMENTS FOR BIOLOGICS MIV-1
B1 Change of Manufacturing Site
For any change, including addition to or replacement, of currently registered manufacturing site(s) of drug substance, drug product, process intermediates, and/or primary packager. If there are any changes in the manufacturing process, include documents listed under B3.
Supporting Documents 1) Official letter authorising the proposed site to perform the related activity; 2) GMP certificate; 3) Validation study reports and/or summaries of the manufacturing process at the proposed manufacturing site; 4) Release and/or shelf life specifications; 5) Batch analysis data (in a comparative tabular format) of at least three batches manufactured at the currently registered and proposed site; 6) Results of appropriate stability studies of at least three batches produced at the proposed manufacturing site in accordance with the relevant stability guidelines; 7) Batch numbering system.
B2 Change of Testing Laboratory
For any addition or replacement of the current registered laboratories for stability tests or any quality control (QC) tests.
Supporting Documents 1) Official letter authorising the proposed site to perform the related activity; 2) Analytical assays at the proposed site; 3) Validation study reports and/or summaries at the proposed site; 4) Release specification; 5) Batch analysis data (in a comparative tabular format) of at least two batches tested at the currently registered and proposed site
B3 Change of Manufacturing Process
For any change in the procedure and/or scale of the current registered manufacturing process at any stage during manufacture of drug substance and/or drug product.
Supporting Documents 1) Validation study reports and summaries of the proposed manufacturing process; 2) Release and/or shelf life specifications; 3) Batch analysis data (in a comparative tabular format) of at least two batches manufactured according to the currently registered and proposed process; GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 5 of 13
4) Results of appropriate stability studies of at least three batches produced with the proposed manufacturing process in accordance with the relevant stability guidelines; 5) A declaration from the applicant that no new impurities have been introduced at or above the accepted threshold for qualification of impurities or that there is no increase in the level of impurities, which require further safety studies.
B4 Change of Test Procedure
For any change of test procedure of drug substance, drug product, in-process tests, excipients, product release tests, and/or stability tests.
Supporting Documents 1) Validation study reports and summaries of the proposed test procedure.
B5 Change of Specifications
For any change of release and/or shelf life specifications of drug substance, drug product, in-process tests, product release tests, and/or stability tests.
Supporting Documents 1) Scientific and/or historical data used to support the change; 2) Currently registered version of the release and/or shelf life specifications with the proposed change(s) clearly highlighted, underscored, or otherwise indicated.
B6 Change of Container Closure System
For any change of the container closure system that is in immediate contact with the drug substance, drug product, process intermediates, and/or diluent used for reconstitution.
Supporting Documents 1) Information on construction materials and design features of the proposed container closure system; 2) Study reports and/or summaries on compatibility, leaching materials, leak tests, etc. for demonstrating the suitability of using the proposed container closure system; 3) Release and shelf life specifications; 4) Results of appropriate stability studies of at least three batches produced with the proposed container closure system in accordance with the relevant stability guidelines.
GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 6 of 13
B7 Change of Shelf Life and/or Storage Condition
For any change of shelf life and/or storage condition of drug substance, drug product, and/or process intermediates after initial opening or after reconstitution.
Supporting Documents 1) Release and shelf life specifications; 2) Results of appropriate stability studies of at least three batches covering the duration of the proposed shelf life under the proposed storage conditions in accordance with the relevant stability guidelines.
B8 Change of Excipient
For any change of the qualitative or quantitative formulation of excipients of drug substance and/or drug product.
Supporting Documents 1) Release and shelf life specifications; 2) Batch analysis data (in a comparative tabular format) of at least two batches manufactured according to the currently registered and proposed formulation; 3) Results of appropriate stability studies of at least three batches with the proposed formulation in accordance with the relevant stability guidelines.
B9 Change of Product Label
For any change of product labelling of the package insert (PI), patient information leaflet (PIL), unit carton label, inner label, and/or blister strips which cannot be classified as an MAV or an MIV-2.
Supporting Documents 1) J ustification for the proposed change(s) and supporting clinical documents, where applicable; 2) Currently registered product label with the proposed change(s) clearly highlighted, underscored, or otherwise indicated; 3) Proposed product label with all change(s) incorporated;
B10 Seasonal Variation of Influenza Strains for Vaccine
Change of only influenza strains for the formulation of an influenza vaccine according to WHO Recommendations for Influenza Vaccine Composition may be expedited. Additional changes other than strain changes will require additional supporting documents, and may delay the evaluation timeline.
Document Required In Addition to MIV-1 Compulsory Documents: 1) CTD Module 2 - Section 2.3 Quality Overall Summary; GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 7 of 13
2) CTD Module 3 - Section 3.2.P.8 Stability (Summary & Conclusion) of at least 6 months of the vaccine from the preceding year or season; 3) Currently registered product label with the proposed change(s) clearly highlighted, underscored, or otherwise indicated; 4) Proposed product label with all change(s) incorporated; 5) A commitment from the applicant to perform stability studies up to the proposed shelf-life of the product.
GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 8 of 13
PART C: DOSSIER REQUIREMENTS FOR BIOLOGICS MIV-2
An MIV-2 application is a variation for which only a notification is required to be submitted to HSA. Each MIV-2 notification shall be submitted at least 2 months in advance of the commencement date.
If a proposed MIV-2 does not meet its specified conditions, then the MIV must be submitted as an MIV-1 with supporting documents. HSA reserves the right to re- categorise the MIV if deemed appropriate.
C1 Change of Contact Person
Condition - The product licence holder remains the same.
Supporting Documents 1) Particulars of the contact person updated in the on-line PRISM application form.
C2 Change of Product Name
Conditions - There is no change to the product (formulation, specifications, manufacturing source and process) except the product name; - No perceived conflict, confusion, or similarity to name(s) of existing medicinal products; - New name does not imply (a) greater safety or efficacy than supported by clinical data, (b) superiority over a similar product in Singapore, (c) imply a therapeutic use for the product, or (d) the presence of substance(s) not present in the product.
Supporting Documents 1) Official letter authorising change of product name; 2) A declaration from the applicant that there is no change to the product except name; 3) Official letter of commitment to inform users of the relevant changes, and that the current product stocks will be exhausted before the product labelled with the new name is marketed; 4) CPP.
NOTE: Applicants are encouraged to fax or email the MIV Filing and Submission Inquiry Form in Appendix 13 for any issues regarding MIV filing. GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 9 of 13
C3 Change of Product Owner
Condition - The product licence holder remains the same.
Supporting Documents 1) Official letter by the new product owner declaring the change, and authorising the local licence holder to be responsible for the product licence in Singapore; 2) If the new product owner is not the manufacturer of the drug product, an official letter by the new product owner authorising the manufacturer to produce the drug product on its behalf.
C4 Change of Batch Numbering System
Supporting Documents 1) Official letter stating the commencement date of the change; 2) Description of batch number system.
C5 Renaming (e.g. street name, postal code) of Manufacturing Site
Condition - The current manufacturing site(s) of drug substance, drug product, process intermediates, packaging, and/or batch release remains unchanged and at the same physical location.
Supporting Documents 1) Official letter authorising the site to perform the related activity (not required if the manufacturer is the product owner); 2) A declaration from the applicant that the manufacturing site remains the same, and that the renaming does not involve changes of the manufacturing process and/or quality of the product; 3) Official letter stating the commencement date of the change; 4) GMP certificate with new name or address.
C6 Change of Batch Release Site
Condition - Batch release procedure is equivalent between the current and new site.
Supporting Documents 1) Official letter authorising the site for batch release; 2) GMP certificate of the new site.
GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 10 of 13
C7 Addition or Replacement of Secondary Packaging Site
Supporting Documents 1) Official letter authorising the proposed manufacturer to perform secondary packaging; 2) Evidence (i.e. GMP certificate) demonstrating that the proposed site is appropriately authorised for the packaging activity concerned.
C8 Withdrawal of Manufacturer or Manufacturing Site
Supporting Documents 1) Official letter stating the withdrawal or deletion of the manufacturer or manufacturing site to perform the related activity.
C9 Deletion of Pack Size for Drug Product
Supporting Documents 1) No additional documents required.
C10 Change of Secondary Packaging
Conditions - Conformance to current drug product release and shelf life specifications; - The change is consistent with the dosage regimen and duration of use as approved in the PI.
Supporting Documents 1) Official letter stating that release and shelf life specifications, the container and closure system compositions have not been changed; 2) J ustification that the change is consistent with the dosage regimen and duration of use as approved in the PI.
C11 Change of Imprints, Bossing or Other Markings (except Score/Break Line) on Tablet or Printing on Capsule Including Addition or Change of Inks Used for Product Marking
Conditions - New markings do not cause confusion with other tablets or capsules; - The inks are acceptable for pharmaceutical use; - Conformance to current drug product release and shelf life specifications except for appearance.
GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 11 of 13
Supporting Documents 1) A declaration from the applicant that that the release and shelf life specifications (except appearance) of the drug product have not been changed; 2) Official letter of commitment to inform users of the relevant changes, and that the current product stocks will be exhausted before the new product is marketed; 3) Detailed drawings and/or written descriptions of the current AND new imprint/ bossing/ markings/ink/etc.; 4) Drug product release and shelf life specifications.
C12 Change of Dimensions of Tablet, Capsule, Suppository or Pessary Without Change in Qualitative and Quantitative Composition and Mean Mass C12.1 Conventional Dosage Form, Suppository and Pessary C12.2 Critical dosage form and scored tablet
Conditions - No change in dissolution profile; - Conformance to current drug product release and shelf life specifications except for dimensions.
Supporting Documents C12.1 Conventional dosage form, suppository and pessary 1) Detailed drawing or written description of the current and proposed appearance; 2) Release and shelf life specifications of the drug product; 3) Revised drafts of the package insert and labelling incorporating the proposed variation (where applicable).
C12.2 Critical dosage form and scored tablet 4) In addition to C12.1 Documents 1 to 3; 5) Comparative dissolution data on at least one pilot/production batch of the current and proposed dimensions in accordance with HSAs drug registration guidelines; 6) J ustification for not submitting a new bioequivalence study according to the current Bioavailability and Bioequivalence guidelines; 7) Where applicable, data on the test for uniformity of content of the subdivided parts of tablets at release should be submitted and commitment to conduct the test at the end of shelf life, data should be provided only if outside the release and shelf life specifications (with proposed action).
C13 Change in Colouring or Flavouring System of Product Including Addition, Deletion or Replacement of Colourant(s) or Flavourant(s)
Conditions - Same functional characteristics, no change in dissolution profile for solid dosage forms; - The colouring system must not have been rejected for pharmaceutical use; - Conformance to current drug product release and shelf life specifications except for colour/flavour. GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 12 of 13
Supporting Documents 1) A declaration from the applicant that that the release and shelf life specifications (except colour and/or flavour) of the drug product have not been changed; 2) Official letter of commitment to inform users of the relevant changes, and that the current product stocks will be exhausted before the new product is marketed; 3) Official letter of commitment to conduct the appropriate stability studies of at least three batches produced with the revised formulation in accordance with the relevant stability guidelines; 4) Detailed information of the colouring or flavouring agent; 5) Revised product formulation; 6) Drug product release and shelf life specifications.
C14 Quantitative Change in Coating Weight of Tablet or Weight of Capsule Shell
Conditions - No change in dissolution profile; - Conformance to current drug product release and shelf life specifications except for weight.
Supporting Documents 1) A declaration from the applicant that that the release and shelf life specifications (except weight) of the drug product have not been changed; 2) Comparative dissolution data of at least one pilot or production batch of the current version versus the proposed version in accordance with HSAs drug registration guidelines; for modified release products, also provide correlative data comparing in vitro and in vivo data; 3) J ustification for waiving requirements for a new bioequivalence study according to the relevant guidelines; 4) Drug product release specification.
C15 Change of Product Labelling due to Safety Updates:
Note: Changes to safety information on product labels and package insert may be allowed without prior approval from HSA provided the changes fulfil the conditions stipulated below. Companies that need to disseminate safety information urgently can continue to do so through Dear Healthcare Professionals Letters, in consultation with HSA. Thereafter, product labelling should be updated in accordance with the labelling safety-related update notification system.
Conditions - Addition of warnings, precautions, contraindications or adverse events/effects to the current product labelling, or - Tightening of the target-patient population.
Supporting Documents 1) A declaration from the applicant that no other changes have been made to the GUIDANCE ON MEDICINAL PRODUCT REGISTRATION IN SINGAPORE JANUARY 2009 GUIDELINE ON MINOR VARIATION APPLICATIONS (MIV-1 &MIV-2) FOR BIOLOGICS HEALTH SCIENCES AUTHORITY HEALTH PRODUCTS REGULATION GROUP Appendix 15 - Page 13 of 13
labelling and that the change is supported by data.
C16 Change of Product Labelling Relating to: Addition/Deletion of Bar Code Replacement of Distributor Details Layout without Altering Text or Meaning Deletion of Indication (Note: Re-inclusion of the deleted indication in the future should be submitted as MAV-1 according to the prevailing requirement.) Addition/Deletion/Replacement of Pictures or Diagrams that do not Imply an Unapproved Indication
Conditions - No change to the text or meaning of the wordings; - No unapproved indications, usages, dosage regimens or promotional information.
Supporting Documents 1) A declaration from the applicant that no other changes have been made to the labelling.
C17 Change of Product Labelling of Language(s) Other Than English
Conditions - No change to the text or meaning of the English wordings; - No unapproved indications, usages, dosage regimens or promotional information.
Supporting Documents 1) A declaration from the applicant that the information in other language(s) provides complete, accurate and unbiased information on the product and is consistent with the English version.