Marketed Substance - creation
The creation of a new Marketed Substance begins with a "basis for creation" regular/enriched email message/notification with the topic "New Marketed Substance":
- enriched email notification after the creation of the first distributing Organization of the new Substance
- enriched email notification after the creation of another distributing Organization of the Substance
- regular/enriched email message with an attachment "Decision to introduce a new Marketed Substance" for the already introduced Substance and its distributing Organization but with the different composition
- regular/enriched email message with an attachment "Decision to introduce a new Marketed Substance - Production Chain" for the already introduced Marketed Substance and its distributing Organization
Other "basis for creation" documents that may be necessary for structural and narrative definition of the Marketed Substance are:
- Certificate of Suitability - CEP
Gathering of the documentation/data
Gathering of documentation and necessary data for the structural and narrative definition of a new Marketed Substance can be done in advance, before the beginning of structural definition and subsequently when the Marketed Substance has become a topic in the enriched email correspondence.
Before the beginning of the structural definition
Gathering of documentation related to the creation of a new Marketed Substance is a process that can begin before the receipt of the "basis for creation" enriched email and subsequent beginning of the structural definition. During that period database record for the new Marketed Substance and directory tree of replacement narrative files does not exists in the eCTD Integral Information System and the only topic that can be used in the correspondence is "New Marketed Substance". Attached documents are classified and uploaded to the Corporate Documentation Cloud but they are not linked with the Marketed Substance that is being created. Nevertheless, linking of all correspondence to the newly created Marketed Substance is essential and it can be done when the structural definition is started.
After the beginning of the structural definition
The cmc entity person begins the process of Marketed Substance structural definition right after receiving the "basis for creation" enriched email. When selecting a "basis for creation" enriched email on the "correspondence" sub-application form, all related correspondence previously received relating to the Marketed Substance being created should also be selected.
During the insertion of the record into the eCTD Integral Information System a core sequence and a directory tree of replacement narrative files are generated and the newly defined Marketed Substance automatically becomes the topic of the "basis for creation" enriched email and all selected previously received enriched emails.
That can be seen when inserting additional data on the "correspondence" sub-application form.
Previously received attachments/documents have to be manually assigned to the corresponding replacement files using the application form "Corporate Entity creation / Marketed Substance / Narrative data". The process is explained in the narrative definition section.
All correspondence from then on should be conducted using enriched email messages and the newly-created Marketed Substance as the topic.
During the subsequent correspondence and classification of the attachment(s), attached document(s) are automatically uploaded to the Corporate Documentation Cloud and assigned to the appropriate replacement files.
Structural definition
In order to create and structurally define a new Marketed Substance following business processes must be performed in the following order:
- Generation/receipt of a "basis for creation" regular/enriched email
- Selection of one "basis for creation" enriched email message and related correspondence on the sub-application form "Correspondence" of the application form "Corporate Entity creation / Marketed Substance / Structural Data"
- Definition of Marketed Substance general structural data
- Definition of Marketed Substance Specification and Quality Control Analysis
- Definition of Marketed Substance-Production Chain
- Completion of the structural definition
- Complete structural definition during the first session
- Complete structural definition in several sessions
1. Generation/receipt of a "basis for creation" regular/enriched email
The enriched email notification automatically sent to the high-level cmc entity person:
- after the creation of the first distributing Organization of the new Substance
- after the creation of another distributing Organization of the Substance
The regular/enriched email message with the attachment "Decision to introduce an additional Marketed Substance" sent by a corporate person with the appropriate authority to the high-level cmc entity person. This option is limited to the case when one or more Marketed Substances for a given Substance already exist in the system and when the need for an additional one with a different specification has arisen.
The regular email message must be registered by the recipient.
If necessary, additional correspondence using the same topic and subtopic can be made in order to clarify certain details. When all details are clarified, the structural definition process can be started by choosing the menu item "Corporate Entity creation / Marketed Substance / Structural Data" on the "Corporate Entities" application module.
2. Selection of one "basis for creation" enriched email message and related correspondence
To create a new Marketed Substance, first, using the "Correspondence" sub-application form, a received "basis for creation" enriched email relevant to the new Marketed Substance being created must be selected from the non-processed correspondence documents. In addition, all enriched email messages classified as "related correspondence" pertaining to the same new Marketed Substance should also be selected in order to properly establish entity creation correspondence environment.
3. Definition of Marketed Substance general structural data
A minimal set of structural data is specified with the (*) and they are a prerequisite for the insertion of the record in the eCTD Integral Information System Database. Using the data from the "basis for creation" emails and the entity creation chain of correspondence all the data previously defined during the definition of the relevant Substance are transferred to the application form and new data are defined such as:
- Purity
- Marketed Substance name
- Standard
- Monograph number
Using at least the minimal set of required data, the Marketed Substance is introduced into the eCTD Integral Information System and a core sequence, directory tree of replacement narrative files, and an enriched email notification to the designated cmc entity person are generated.
During subsequent correspondence and classification of attachment(s), the attached document(s) are automatically uploaded to the Corporate Documentation Cloud and assigned to the appropriate replacement narrative files.
Depending on the role of the Substance, five types of Marketed Substance directory trees with replacement narrative files are defined:
- active substance directory tree with replacement narrative files
- novel excipient directory tree with replacement narrative files
- non novel - non compendial excipient directory tree with replacement narrative files
- compendial excipient directory tree with replacement narrative files
- directory tree with replacement narrative files and with an additional specification test(s)
These documents/files are placed in the "common area" of the Corporate Documentation Cloud and are automatically used to generate initial submissions whenever the Marketed Substance is present in the manufacturing process of a Medicinal Product.
The five types of directory tree with replacement narrative files are presented below:
Marketed substance directory tree with replacement narrative files and with an additional specification test(s)
In addition to the basic eCTD files associated with the Marketed Substance, the following business rules are used to create the narrative files required for a complete narrative definition:
- if the quality standard is defined by the EU Pharmacopeia replacement narrative file for the CEP is created (annex-10)
- if the quality standard is defined by ASMF related replacement narrative files are not created at this instance. They are created at the time of Corporate Project launch when the regulatory agency to which the letter of accession (Annex-10) and the letter of confirmation for notification of changes (Annex-11) are to be sent.
For compendial chemicals these files are used to generate submissions and fill-in electronic application form to the Certification of Substances Department (DCEP) of the EDQM to obtain a Certificate of Suitability to the monographs of the European Pharmacopoeia (CEP).
4. Definition of Marketed Substance specification and Quality Control Analysis
The specification for the Marketed Substance is defined using the dedicated sub-application form "Specification" on the "Corporate Entity creation / Marketed Substance / Structural Data" application form.
Separate blocks are provided for Composition and Physicochemical properties. An analytical method is defined for each property and at the insert of the record an analytical Quality Control Analysis is defined. The Analysis is later used to initiate quality control of the Marketed Substance during the purchasing receiving procedure.
Analytical Quality Control is supported by a separate "Analytica Quality Control" application module that can be added on request.
5. Definition of Marketed Substance-Production Chain
One or more distributing Organizations can be defined for each Marketed Substance. Distributor is selected from the List of Values of GDP distributing Organizations of the Substance in question.
For each distributor, an initial rudimentary Marketed Substance - Production Chain is defined, consisting only of the distributing Organization. A further, more elaborate, definition of the Marketed Substance - Production Chain is made on the application form "Corporate Entity creation / Marketed Substance-Production Chain / Structural Data".
The cmc entity persons responsible for the definition and subsequent development of each Marketed Substance - Production Chain are also defined and automatically generated enriched email notifications are sent.
At the same time, first set of replacement narrative files for the narrative definition of the Marketed Substance - Production Chain are generated. They can be seen on the application form "Corporate Entity creation / Marketed Substance - Production Chain / Narrative Data".
During subsequent correspondence, Marketed Substance - Production Chain(s) can be used as a topic. With the classification of the attachments, the attached document(s) are automatically uploaded to the Corporate Documentation Cloud and assigned to the appropriate replacement narrative files.
6. Completion of the structural definition
The structural definition process can be completed in two ways:
- In one session when all structural data are defined
- in several sessions where
- in the first session only minimal data set and maybe some of the additional data are defined
- in the next session(s) where remaining additional data are defined
Upon completion of the structural definition process, the Marketed Substance is assigned the status "completely structurally defined".
At the same time, the Substance track is advanced towards the complete structural definition of the Marketed Substance - Production Chain by an automatically generated:
- enriched email notification to the designated cmc entity person for a complete structural and narrative definition of the Marketed Substance Production Chain
6.1 Complete structural definition during the first session
The minimal data set denoted with (*) is prerequisite for the insertion of the record into the eCTD Integral information System.
If the minimal data set requirement is met, then confirmation of the complete structural definition is prompted. If the complete structural definition is confirmed the record is inserted into the database of the eCTD Integral Information System with the status "completely structurally defined" and with the ability to be used to define corporate entities of the higher level.
6.2 Complete structural definition in several sessions
In the first session only the minimal data set and maybe some additional data are defined. At the end of the session, confirmation of the complete structural definition is prompted. If the answer is negative, the record is inserted and the status of the entity is set to "incompletely structurally defined".
Additional data can be added on the same application form by clicking on the "Additional data" button and selecting the required Marketed Substance from the LoV of incompletely defined Marketed Substances. Previous enriched emails related to the selected Marketed Substance can be seen on the "correspondence" sub-application form.
The structural definition is completed when a positive response is given to the prompt for a complete structural definition.
The Marketed Substance is assigned the status "completely structurally defined" with the ability to be used to define corporate entities of the higher level.
Narrative definition
The designated cmc entity person is responsible for the complete narrative definition of the Marketed Substance.
The eCTD documents can be either:
- created by the designated cmc entity person and manually uploaded to the Corporate Documentation Cloud
and/or - collected from related Business Partners via email correspondence and automatically uploaded to the Corporate Documentation Cloud during the enriched email processing of the Business Partner's regular email messages.
Therefore, in order to narratively define a Marketed Substance following business processes must be performed:
- Creation of eCTD documents and manual uploading to the Corporate Documentation Cloud
and/or - Collection of eCTD documents via email correspondence and automatic uploading to the Corporate Documentation Cloud
- Completion of the process
1. Creation of eCTD documents and manual uploading to the Corporate Documentation Cloud
Using any regular text processor eCTD documents have to be created and pdf files generated for uploading to the Corporate Documentation Cloud. If required, a verification process by a senior manager can be included upon request.
The process is initiated by choosing the menu item "Corporate Entity creation /Marketed Substance / Narrative Data" on the "Corporate Entities" application module.
Other than that, the process is same as described in the "Substance - creation" page of this site, here.
2. Collection of eCTD documents via email and automatic uploading to the Corporate Documentation Cloud
In case the eCTD documents were originally generated by the Business Partner, they can be obtained via email correspondence. During the processing of such a Business Partner's regular email message by the Enriched Email Client and using the email attachments classification, attachments are automatically uploaded to the Corporate Documentation Cloud.
The process is same as described in the "Substance - creation" page of this site, here.
3. Completion of the process
When all mandatory replacement files in the directory tree are replaced with the written eCTD files, the process ends automatically and the Marketed Substance is set to be "completely structurally and narratively defined".