FDA´s Emerging Technology Applications Program - Draft Guidance

On December 23, 2015, the FDA published a draft guidance for industry "Advancement of Emerging Technology Applications to Modernize the Pharmaceutical Manufacturing Base". Comments and suggestions regarding this draft document should be submitted within 60 days of publication.

The draft guidance provides recommendations to pharmaceutical companies interested in participating in a program involving the submission of CMC (chemistry, manufacturing, and controls) information containing emerging manufacturing (including testing, packaging and labeling operations, and quality control) technology to FDA. 

The program is open for new drug applications (INDs), original or supplemental new drug application (NDA), abbreviated new drug application (ANDA), or biologic license application (BLA). It only affects the quality section of a submission (CMC and facility-related information).

The development of emerging manufacturing technology, like, for example, aseptic manufacturing facilities with highly automated systems and isolators, may lead to improved manufacturing, and therefore improved product quality and availability throughout a product´s lifecycle. 

Pharmaceutical companies can submit questions and proposals about the use of these technologies to a group within CDER (Emerging Technology Team - ETT).

The draft guidance is a follow-on to the FDA guidance for industry "PAT - A Framework for Innovative Pharmaceutical Development, Manufacturing, and Quality Assurance" which describes the concept that quality cannot be tested into products. It should be built-in or should be present by design. Through the ETT, FDA intends to encourage the adoption of innovative approaches by leveraging existing resources of FDA to facilitate regulatory reviews of submissions.

Examples of emerging technology elements include an innovative or novel:

• Product manufacturing technology, such as the dosage form;
• Manufacturing process (e.g., design, scale-up, and/or commercial scale);
• Testing technology.

Interested parties should submit a written meeting request to participate in the ETT program at least three months prior to the planned application (IND, ANDA, BLA, NDA) submission date. In addition to the items outlined in the FDA guidance "Formal Meetings Between the FDA and Sponsors or Applicants" the request should also include the following items:

• A brief description of the proposed testing, process, and/or proposed technology;
• A brief explanation why the proposed testing, process, and/or technology are substantially novel and unique;
• A description of how the proposed testing and/or technology could modernize pharmaceutical manufacturing and thus improve product safety, identity, strength, quality, or purity;
• A summary of the development plan and any perceived roadblocks to technical or regulatory implementation;
• A timeline for submission.

The request should generally not exceed five pages and FDA expects to notify companies of its decision regarding acceptance into the program within 60 days of receipt of the request. Once accepted into the program, the participant can engage with ETT and CMC in accordance with existing meeting procedures and guidances (e.g. above mentioned FDA guidance on Formal Meetings).

For further information, please find all the details in the draft guidance "Advancement of Emerging Technology Applications to Modernize the Pharmaceutical Manufacturing Base".