Guidance Document - Annex 13 to the Current Edition of the Good Manufacturing Practices Guidelines Drugs Used in Clinical Trials (GUI-0036)

Contact Information and for Drug Good Manufacturing Practices Unit

Notification

Our Mandate:
To promote good nutrition and informed use of drugs, food, medical devices and natural health products, and to maximize the safety and efficacy of drugs, food, natural health products, medical devices, biologics and related biotechnology products in the Canadien marketplace and health system.

Supersedes: June 1, 2004

Date issued: August 7, 2009

Date of implementation: December 1, 2009

Disclaimer

This document does not constitute part of the Food and Drugs Act (Act) or the Food and Drugs Regulations (Regulations) and in the event of any inconsistency or conflict between that Act or Regulations and this document, the Act or the Regulations take precedence. This document is an administrative document that is intended to facilitate compliance by the regulated party with the Act, the Regulations and the applicable administrative policies. This document is not intended to provide legal advice regarding the interpretation of the Act or Regulations. If a regulated party has questions about their legal obligations or responsibilities under the Act or Regulations, they should seek the advice of legal counsel.

Table of Contents

1.0 Preface

Drugs intended for use in clinical trials in Canada are regulated under Division 5 of Part C of the Food and Drug Regulations. Section C.05.010(j) requires the sponsor to ensure that drugs for use in clinical trials are manufactured, handled and stored in accordance with the applicable Good Manufacturing Practices requirements referred to in Divisions 2 to 4, except for Sections C.02.019, C.02.025 and C.02.026. Sponsors of clinical trials shall ensure that imported drugs are fabricated and packaged/labelled in accordance with these requirements.

This Annex to the current edition of the Canadian "Good Manufacturing Practices (GMP) Guidelines (GUI-0001)" is intended to provide guidance relevant to the fabrication and packaging/labelling of drugs intended for use in human clinical trials, including the placebo and comparator product. If further clarification is required, reference should be made to the Canadian "GMP Guidelines (GUI-0001)".

The Health Products and Food Branch Inspectorate (the Inspectorate) has based this Annex on the current Pharmaceutical Inspection Cooperation Scheme's (PIC/S) version of their Annex 13 "Manufacture of Investigational Medicinal Products" with changes necessary to adapt the text to meet Canadian requirements.

The changes are as follows:

The "GMP Guidelines (GUI-0001)" and a link to the Food and Drug Regulations can be found on Health Canada's Compliance and Enforcement website.

2.0 Principle

Investigational medicinal productsFootnote 1 are produced in accordance with the principles and the detailed guidelines of the Good Manufacturing Practice for Medicinal ProductsFootnote 2. Other guidelinesFootnote 3 should be taken into account where relevant and as appropriate to the stage of development of the product. Procedures need to be flexible to provide for changes as knowledge of the process increases, and appropriate to the stage of development of the product.

In clinical trials there may be added risk to participating subjects compared to patients treated with marketed products. The application of GMP to the manufacture of investigational medicinal products is intended to ensure that trial subjects are not placed at risk, and that the results of clinical trials are unaffected by inadequate safety, quality or efficacy arising from unsatisfactory manufacture. Equally, it is intended to ensure that there is consistency between batches of the same investigational medicinal product used in the same or different clinical trials, and that changes during the development of an investigational medicinal product are adequately documented and justified.

The production of investigational medicinal products involves added complexity in comparison to marketed products by virtue of the lack of fixed routines, variety of clinical trial designs, consequent packaging designs, the need, often, for randomisation and blinding and increased risk of product cross-contamination and mix up. Furthermore, there may be incomplete knowledge of the potency and toxicity of the product and a lack of full process validation, or, marketed products may be used which have been re-packaged or modified in some way.

These challenges require personnel with a thorough understanding of, and training in, the application of GMP to investigational medicinal products. Co-operation is required with trial sponsors who undertake the ultimate responsibility for all aspects of the clinical trial including the quality of investigational medicinal products.

The increased complexity in manufacturing operations requires a highly effective quality system.

The Annex also includes guidance on ordering, shipping, and returning clinical supplies, which are at the interface with, and complementary to, guidelines on Good Clinical Practice.

Note

Products other than the test product, placebo or comparator may be supplied to subjects participating in a trial. Such products may be used as support or escape medication for preventative, diagnostic or therapeutic reasons and/or needed to ensure that adequate medical care is provided for the subject. They may also be used in accordance with the protocol to induce a physiological response. These products do not fall within the definition of investigational medicinal products and may be supplied by the sponsor, or the investigatorFootnote 4. The sponsor should ensure that they are in accordance with the notification/request for authorisation to conduct the trial and that they are of appropriate quality for the purposes of the trial taking into account the source of the materials, whether or not they are the subject of a marketing authorisation and whether they have been repackaged. The advice and involvement of a Qualified PersonFootnote 5 is recommended in this task.

3.0 Glossary

Blinding A procedure in which one or more parties to the trial are kept unaware of the treatment assignment(s). Single-blinding usually refers to the subject(s) being unaware, and double-blinding usually refers to the subject(s), investigator(s), monitor, and, in some cases, data analyst(s) being unaware of the treatment assignment(s). In relation to an investigational medicinal product, blinding shall mean the deliberate disguising of the identity of the product in accordance with the instructions of the sponsor. Unblinding shall mean the disclosure of the identity of blinded products.

Clinical trialFootnote 6Footnote 7 An investigation in respect of a drug for use in humans that involves human subjects and that is intended to discover or verify the clinical, pharmacological or pharmacodynamic effects of the drug, identify any adverse events in respect of the drug, study the absorption, distribution, metabolism and excretion of the drug, or ascertain the safety or efficacy of the drug.

Comparator product An investigational or marketed product (i.e., active control), or placebo, used as a reference in a clinical trial.

Investigational medicinal productFootnote 6Footnote 7 A pharmaceutical form of an active substance or placebo being tested or used as a reference in a clinical trial, including a product with a marketing authorisation when used or assembled (formulated or packaged) in a way different from the authorised form, or when used for an unauthorized indication, or when used to gain further information about the authorised form.

InvestigatorFootnote 6Footnote 7 The person responsible to the sponsor for the conduct of the clinical trial at a clinical trial site, who is entitled to provide health care under the laws of the province where that clinical trial site is located, and who is

Lot Number Means any combination of letters, figures, or both, by which any food or drug can be traced in manufacture and identified in distribution.

Manufacturer/importer of Investigational Medicinal ProductsFootnote 8 In connection with investigational medicinal products, any holder of the authorisation to manufacture/import.

Order Instruction to process, package and/or ship a certain number of units of investigational medicinal product(s).

Product Specification File A reference file containing, or referring to files containing, all the information necessary to draft the detailed written instructions on processing, packaging, quality control testing, batch release and shipping of an investigational medicinal product.

Randomisation The process of assigning trial subjects to treatment or control groups using an element of chance to determine the assignments in order to reduce bias.

Randomisation Code A listing in which the treatment assigned to each subject from the randomisation process is identified.

Shipping The operation of packaging for shipment and sending of ordered medicinal products for clinical trials.

SponsorFootnote 6 An individual, corporate body, institution or organization that conducts a clinical trial.

4.0 Quality Management (C.02.013, C.02.014, C.02.015)

5.0 Personnel (C.02.006)

6.0 Premises and Equipment (C.02.004, C.02.005, C.02.007)

7.0 Documentation

7.1 Specifications and instructions (C.02.009, C.02.010, C.02.011, C.02.015, C.02.016, C.02.018, C.02.020)

7.2 Order (C.02.011)

7.3 Product Specification File (C.02.009, C.02.014, C.02.016, C.02.018, C.02.020, C.02.027)

7.4 Manufacturing Formulae and Processing Instructions (C.02.011, C.02.020)

7.5 Packaging Instructions (C.02.011)

7.6 Processing, testing and packaging batch records (C.02.020, C.02.021, C.05.012(4))

8.0 Production

8.1 Packaging materials (C.02.011, C.02.016)

8.2 Manufacturing operations (C.02.004, C.02.005, C.02.011, C.02.029)

8.3 Principles applicable to comparator product (C.02.011, C.02.018, C.02.027)

8.4 Blinding operations (C.02.011, C.02.014)

8.5 Randomisation code (C.02.011, C.02.014, C.02.020)

8.6 Packaging (C.02.006, C.02.011, C.02.015)

8.7 LabellingFootnote 12 (C.02.011, C.02.016, C.05.011)

9.0 Quality Control (C.02.011, C.02.014)

10.0 Release of Batches (C.02.014)

11.0 Shipping (C.05.006, C.02.011, C.02.012, C.02.015, C.02.022)

12.0 Complaints (C.02.015, C.02.023)

13.0 Recalls and Returns

13.1 Recalls (C.02.012, C.02.022)

13.2 Returns (C.02.014)

14.0 Destruction (C.02.011, C.02.014, C.05.012(3)(e))

Appendix 1: Comparison of terms

Comparison of terms
Terms used in this Annex Comparable terms commonly used in Canada Where the Canadian terms are defined / described
Qualified Person Person in charge of the quality control department Section C.02.006, GMP Guidelines (GUI-0001)
Investigational medicinal product Drug Section C.05.001
Investigator Qualified investigator Section C.05.001
Manufacturer Fabricator, packager / labeller Glossary, GMP Guidelines (GUI-0001)
Starting Material Raw material Glossary, GMP Guidelines (GUI-0001)

Appendix 2: Comparison of the Structure of this Annex with the Canadian Food and Drug Regulations

Comparison of the Structure of this Annex with the Canadian Food and Drug Regulations
Sections of this Annex Corresponding Canadian GMP Sections/ Regulations
Quality Management Quality Control Department C.02.013-15
Personnel Personnel C.02.006
Premises and Equipment Premises C.02.004
Equipment C.02.005
Sanitation C.02.007
Documentation Specifications and instructions Raw Material Testing C.02.009-10
Manufacturing Control C.02.011
Quality Control Department C.02.015
Packaging Material Testing C.02.016
Finished Product Testing C.02.018
Records C.02.020
Order Manufacturing Control C.02.011
Product Specification File Raw Material Testing C.02.009
Quality Control Department C.02.014
Packaging Material Testing C.02.016
Finished Product Testing C.02.018
Records C.02.020
Stability C.02.027
Manufacturing Formulae and Processing Instructions Manufacturing Control C.02.011
Records C.02.020
Packaging Instructions Manufacturing Control C.02.011
Processing, testing and packaging batch records Records C.02.020-21
Records C.05.012 (4)
Production Packaging materials Manufacturing Control C.02.011
Packaging Material Testing C.02.016
Manufacturing operations Premises C.02.004
Equipment C.02.005
Manufacturing Control C.02.011
Sterile Products C.02.029
Principles applicable to comparator product Manufacturing Control C.02.011
Finished Product Testing C.02.018
Stability C.02.027
Blinding operations Manufacturing Control C.02.011
Quality Control Department C.02.014
Randomisation code Manufacturing Control C.02.011
Quality Control Department C.02.014
Records C.02.020
Packaging Personnel C.02.006
Manufacturing Control C.02.011
Quality Control Department C.02.015
Labelling Manufacturing Control C.02.011
Packaging Material Testing C.02.016
Labelling C.05.011
Quality Control Manufacturing Control C.02.011
Quality Control Department C.02.014
Release of Batches Quality Control Department C.02.014
Shipping Personnel C.02.006
Manufacturing Control C.02.011-12
Quality Control Department C.02.015
Records C.02.022
Complaints Quality Control Department C.02.015
Records C.02.023
Recalls and Returns Recalls Manufacturing Control C.02.012
Records C.02.022
Returns Quality Control Department C.02.014
Destruction Manufacturing Control C.02.011
Quality Control Department C.02.014
Records C.05.012 (3) (e)

Appendix 3: Canadian Food and Drug Regulations Referenced in this Document

Division 2 - Good Manufacturing Practices

Premises
C.02.004

Equipment
C.02.005

Personnel
C.02.006

Every lot or batch of a drug shall be fabricated, packaged/labelled, tested and stored under the supervision of personnel who, having regard to the duties and responsibilities involved, have had such technical, academic and other training as the Director considers satisfactory in the interests of the health of the consumer or purchaser.

Sanitation
C.02.007

Raw Materiel Testing
C.02.009

C.02.010

Manufacturing Control
C.02.011

C.02.012

Quality Control Department
C.02.013

C.02.014

C.02.015

Packaging Material Testing
C.02.016

Finished Product Testing
C.02.018

Records
C.02.020

C.02.021

C.02.022

Every distributor referred to in section C.01A.003, wholesaler and importer of a drug shall retain records of the sale of each lot or batch of the drug, which enable them to recall the lot or batch from the market for a period of at least one year after the expiration date of the lot or batch unless otherwise specified in their establishment licence.

C.02.023

Stability
C.02.027

Every distributor referred to in paragraph C.01A.003(b) and importer shall establish the period of time during which each drug in the package in which it is sold comply with the specifications.

Sterile Products
C.02.029

Division 3 - Schedule C Drugs

C.03.202

Division 5 - Drugs for clinical trials involving human subjects

C.05.001

The definitions in this section apply to this Division.

"clinical trial" means an investigation in respect of a drug for use in humans that involves human subjects and that is intended to discover or verify the clinical, pharmacological or pharmacodynamic effects of the drug, identify any adverse events in respect of the drug, study the absorption, distribution, metabolism and excretion of the drug, or ascertain the safety or efficacy of the drug.

"drug" means a drug for human use that is to be tested in a clinical trial.

"qualified investigator" means the person responsible to the sponsor for the conduct of the clinical trial at a clinical trial site, who is entitled to provide health care under the laws of the province where that clinical trial site is located, and who is;

"sponsor" means an individual, corporate body, institution or organization that conducts a clinical trial.

C.05.010

Every sponsor shall ensure that a clinical trial is conducted in accordance with good clinical practices and, without limiting the generality of the foregoing, shall ensure that ... (j) the drug is manufactured, handled and stored in accordance with the applicable good manufacturing practices referred to in Divisions 2 to 4 except sections C.02.019, C.02.025 and C.02.026.

C.05.011

Despite any other provision of these Regulations respecting labelling, the sponsor shall ensure that the drug bears a label that sets out the following information in both official languages:

C.05.012

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2020-11-16