October 16, 2003 

No. 21-03   

CONTENTS

MCS attendees get the inside scoop on policy and practical manufacturing issues

2nd CHPA/FDA seminar takes on monograph challenges

BDC is sold out—wait list registrations will be accepted

Benefit-risk management takes center stage at RSC 2003

CHPA prepares FSA tip sheets for consumers and pharmacists

Extend your reach . . . in Washington

CHPA provides recommendations on safety reporting

CHPA and PhRMA nominate Alfano to NDAC

FDA publishes interim final bioterrorism rule

FDA's expert panel on pharmaceutical science to convene

FDA announces staffing changes

OTC ingredient lists updated

EU pharmaceutical legislation moving forward

CHPA staff travel inside the Beltway and beyond

CHPA plays a major role in IIR conferences

Pharma.Congress.com readies for regulatory, compliance, and best practices forum

Calendar of events

Use the table of contents to jump directly to a story of interest, or use the scroll bars. "Back to the top" options after every story will take you to the beginning of the table of contents.

MCS attendees get the inside scoop on policy and practical manufacturing issues

Over 120 pharmaceutical professionals convened in Parsippany, New Jersey, October 9-10, for informative sessions and workshops on how risk management and business issues interrelate in manufacturing. The information was delivered at CHPA’s Manufacturing Controls Seminar, or MCS, and featured industry and FDA insiders, and  professionals who monitor the industry. 

The first general session opened with welcomes by Chris Allen, CHPA board member and Manufacturing Controls Committee (MCC) chairman; Douglas Ellsworth, director, FDA New Jersey District; Timothy Hayes, senior vice president of Bayer Corporation and CHPA chairman-elect; and Douglas Bierer, Ph.D., CHPA vice president of regulatory and scientific affairs. 

The keynote speaker was John Haystead, editor-in-chief of the Journal of Pharmaceutical Technology, selected specifically by the MCC to represent an observer’s view of the current state of the industry. Haystead noted the increasing pressure of profit margins within the industry. He commented on the growing automation within manufacturing and the shift to electronic documentation and auditing systems as efforts to reduce costs. To this latter point Haystead commended the goals of the 21 CFR Part 11 initiative on electronic records and signatures, and praised industry for helping set FDA on a more clear and thorough course of action. 

Over the course of the two-day seminar, attendees also had a chance to hear directly from FDA personnel. Helen Winkle, director of FDA’s Office of Pharmaceutical Science in the Center for Drug Evaluation and Research, provided a report on the progress of her office on current issues and outlined areas of mutual interest between the Agency and CHPA. Winkle and her staff are engaged in a number of activities involving the drug quality initiative and the Agency's strategic plan, as well as internal quality improvement goals, including:

  • Speeding up reviews,
  • Developing a clearer understanding of goals,
  • Determining and continually evaluating best practices and standards for both process and scientific content,
  • Training, and 
  • Measuring performance.

John M. Taylor, III, associate commissioner for regulatory affairs, was the featured general session speaker on day two. Taylor is FDA’s top field operations executive and led MCS attendees on a discussion of FDA’s current Good Manufacturing Practices initiative, dietary supplement claims enforcement activities, counterfeit drug issues, and the development of a strategic plan for the Office of Regulatory Affairs (ORA). According to Taylor, the benefits of an ORA strategic plan

“include a better allocation of resources to maximize the impact on the public health; a better articulation to industry of the Agency’s compliance priorities; a better articulation of why [FDA is] bringing cases in one context but not another; a better enforcement infrastructure and process that is less subject to swings in the enforcement pendulum; a greater emphasis on mission relevance when the Agency performs its compliance functions; and a better understanding of, and a subsequent decrease in, the disparity between perceived risks and actual risks.”

Dr. Jeffry Macher of Georgetown University School of Business delivered an update on an important research project in collaboration with the Washington University in St. Louis. The two academic institutions have a collaborative agreement with FDA to develop a report on strengths and weaknesses within the manufacturing community for release in 2004. According to Macher, so far 20 companies have provided information to the project from 80 plants. CHPA members are encouraged to participate in this project.

A highlight of MCS every year is the workshops, and this year was no exception. One of the most popular workshops was Douglas Ellsworth’s, “GMPs and the Impact of the Drug Quality Initiative.” This session provided a practical ORA field view of the impact of the current FDA activities in the areas of drug product quality.

CHPA and FDA have worked collaboratively this year on providing educational opportunities on the drug quality initiative. Additional public workshops on the subject are being planned for 2004. 

CHPA contact: Fred Razzaghi

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2nd CHPA/FDA seminar takes on monograph challenges

CHPA’s Scientific Affairs Committee and FDA sponsored the second in a series of educational seminars for Agency and OTC industry personnel October 2 with the topic “OTC Drug Monographs: Challenges for the Future.” The speakers, from FDA and industry, explored how the monograph review process differs from the new drug application (NDA) approval process and the challenges presented by the monograph system for both industry and FDA. Several interactive case studies were used to illustrate options a manufacturer could choose in developing new claims, product dose forms, or product enhancements of current OTC monograph drugs.

A joint CHPA/FDA steering committee is designing at least two more seminars in 2004 on OTC drug topics of mutual interest.

CHPA contact: Dr. Lorna Totman

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BDC is sold out—wait list registrations will be accepted

All 120 seats for the Business Development Conference (BDC) have been reserved by CHPA members anxious to attend the Wal-Mart-focused October 27-28 conference in Bentonville, Arkansas. Due to the unprecedented interest in the conference, however, wait-list registrations will be accepted as cancellations are received. To register for the wait list, download the conference registration form from the Members Only section of www.chpa-info.org and fax it to CHPA’s Maria Sarabia at (202) 223-6835. 

We are pleased to announce that the following companies have graciously offered to sponsor events at the conference, thereby helping to make it an even better networking opportunity:


and




W. F. Young, Inc.
www.absorbine.com

Monday night dinner



Tuesday morning continental breakfast



Tuesday luncheon

As always, we sincerely appreciate the generosity of the CHPA membership. Their generosity adds value to CHPA events and helps defray the registration costs for all attendees.  

CHPA contacts: Ted Peterson and Phyllis Taylor

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Benefit-risk management takes center stage at RSC 2003


The Regulatory and Scientific Conference (RSC) is now just three weeks away, but it’s not too late to register. With the theme “The New Age of Benefit-Risk Management,” the conference will be held November 6-7 at The Fairmont Hotel in Washington, D.C. 

Insights from Washington insider Kay Holcombe, executive vice president, Policy Directions, Inc., on the role of self-medication in our future healthcare system will be a highlight of the first general session. The session program focuses on the timely topics of benefit-risk assessment for OTC products, the role and impact of epidemiology in benefit-risk assessment, and FDA’s use of epidemiology study data. The featured speakers are Peter A. Gross, M.D., chairman, Department of Internal Medicine, Hackensack University Medical Center; J. Michael Gaziano, M.D., director of cardiovascular epidemiology, Division of Preventive Medicine, Brigham and Women’s Hospital, and principal investigator in the Physicians’ Health Study II; and Paul J. Seligman, M.D., MPH, director, Office of Pharmacoepidemiology and Statistical Science, Center for Drug Evaluation and Research (CDER), FDA. They will be joined by Charles J. Ganley, M.D., director, Division of Over-the-Counter Drug Products, Office of Drug Evaluation V (ODE V), CDER, FDA, and Eric Brass, M.D., chair, Department of Medicine, Harbor-UCLA Medical Center, in a panel discussion moderated by Randy P. Juhl, Ph.D., vice chancellor for research conduct and compliance, University of Pittsburgh.

Three concurrent workshops will provide opportunities for learning and interaction among conference participants. The workshop topics are the benefit-risk equation for chronic-use OTC switch candidates, tools and rules for improving benefit-risk assessments, and optimizing the FDA Nonprescription Drugs Advisory Committee.

The second general session will emphasize the roles of the media and public relations professionals in communicating healthcare issues, with presentations by Nancy Snyderman, M.D., vice president of medical affairs, Johnson & Johnson, and Richard W. Edelman, president and chief executive officer, EDELMAN. Conference participants also will hear from Curtis J. Rosebraugh, M.D., MPH, deputy director, Division of Over-the-Counter Drug Products, ODE V, CDER, FDA, about current OTC drug issues at FDA.

_________________________

Provided rooms are available, 
the RSC room rate of $199 per night 
will remain in effect through October 17
_________________________

A preliminary program and registration materials are available on CHPA’s web site. Room reservations should be made directly with The Fairmont Hotel at (800) 441-1414. The Fairmont has agreed to honor the special CHPA conference rate of $199 per night through October 17, provided rooms are available. 

CHPA thanks this year’s RSC sponsors: 

  • McNeil Consumer & Specialty Pharmaceuticals;
  • Novartis Consumer Health, Inc.;
  • Perrigo Company; 
  • Pfizer Inc.; and
  • The Procter & Gamble Company.

CHPA contact: Dr. Lorna Totman

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CHPA prepares FSA tip sheets for consumers and pharmacists

In an effort to help communicate how consumers and health professionals can take advantage of the IRS's new ruling allowing OTCs as reimbursable expenses within healthcare flexible spending accounts (FSAs), CHPA has prepared two tip sheets: the consumer-focused "Paying for OTCs with Pre-Tax Dollars" and a pharmacist-directed "Help Your Consumers Pay for OTCs with Pre-Tax Dollars." These tip sheets are part of an overall campaign to educate the public about IRS Revenue Ruling 2003-102, the vital role OTCs play in the U.S. healthcare system, and the need to make nonprescription medicines tax deductible. 

CHPA will continue to promote the FSA ruling and full tax parity for OTCs with prescription medicines. For more information about the campaign or to request materials, visit CHPA online. 

CHPA contact: Virginia Cox

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Extend your reach . . . in Washington
CHPA provides entrée with the
D.C.-based March 2004 AEC

Mark your calendars now for next year’s CHPA Annual Executive Conference (AEC), March 17-19, 2004, at the Grand Hyatt in Washington, D.C.

With its inside-the-Beltway location, the conference will feature a business program strong on government and policy themes. Business program chair Lynne Millheiser of Novartis Consumer Health and the program committee are working to make the conference a vehicle to help members extend their reach in the Washington community.

___________________________

Extending Your Reach
CHPA Annual Executive Conference
March 17-19, 2004
Washington, D.C.
___________________________

Sponsorship opportunities are still available for the Association’s marquee event. Contact Kass Kassouf for sponsor questions.

A preliminary program overview is available with an outline of the conference.

CHPA contacts: Kass Kassouf and David Spangler

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CHPA provides recommendations on safety reporting

In comments to FDA October 14, the Association commended the Agency's goal of moving towards global harmonization of safety reporting requirements for drugs as enumerated in a March 14 proposed rule, but recommended reconsideration of the impact on OTCs of many of the proposed provisions. 

In its comments, CHPA supported the "underlying rationale" for the Safety Reporting Requirements for Human Drug and Biological Products proposed rule, highlighting how it "will save considerable valuable resources for both industry and the governmental agencies in the processing of safety reports and allow more effective pharmacovigilance and continued protection of the public health." However, in terms of the postmarketing safety reporting requirements for consumer healthcare products marketed under new drug or abbreviated new drug applications (NDA and ANDA, respectively), the Association pointed out that the practical implications of the proposal could be "problematic" and in some cases "extraordinarily resource-intensive," leaving the benefit to the public debatable.

CHPA raised a number of points within its nine pages of comments, including: 

  • The proposed definition of a suspected adverse drug reaction was too broad and inconsistent with certain International Conference of Harmonisation (ICH) guidelines on the subject. 
  • FDA should concentrate on the quality of safety reports rather than their source, consistent with ICH. 
  • Only those medication errors with a "serious" adverse event should be submitted in expedited reports for OTC NDA and ANDA products.  

CHPA contact: Dr. Lorna Totman

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CHPA and PhRMA nominate Alfano to NDAC

CHPA and the Pharmaceutical Research and Manufacturers of America (PhRMA) nominated Michael C. Alfano, D.M.D., Ph.D., to serve as the industry liaison to FDA's Nonprescription Drugs Advisory Committee. Alfano is the dean of New York University's College of Dentistry and has participated in previous NDAC meetings as a guest participant. The associations sent Alfano's nomination October 10 to the Advisors and Consultants Staff department within FDA's Center for Drug Evaluation and Research. 

CHPA contact: Dr. Lorna Totman

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FDA publishes interim final bioterrorism rule
Dietary supplement facilities must register by December 12

FDA published interim final rules October 10 implementing the food registration and the import notification provisions of the Bioterrorism Act. The interim rules will require dietary supplement facilities to register with FDA by December 12 and to begin filing prior notices of imports by that deadline.

Food facilities can register electronically

As mandated by the bioterrorism statute itself, FDA will require the registration of all facilities engaged in the manufacturing, processing, packing, or holding of food, including dietary supplements, for consumption in the United States. The mandate applies to domestic as well as foreign facilities. whether food from the facility enters interstate commerce or not. Domestic and foreign food facilities have between October 16 and the December 12 deadline to register. Electronic registration is available at http://www.fda.gov/furls

Importers must file prior notice, timing depends on method of shipment

The second interim final rule requires prior notice of imported food, including dietary supplements, beginning December 12. FDA must receive prior notice no more than five days before foods are imported or offered for import into the United States. FDA has different minimum timeframes for road, air and rail, ship, or mail arrivals. FDA intends to provide a transition period in enforcement policies through a guidance to FDA staff, during which time the Agency will emphasize education to achieve compliance.  

FDA addressed some CHPA concerns

CHPA submitted written comments to these proposed rules earlier this year. FDA responded favorably to CHPA’s concerns about the breadth of term “food” that would have included substances that come into contact with food during processing or packaging. That would require the plant where the contact substance is manufactured to register, as well as the facility where the food is manufactured or processed. In the interim final rule, FDA expressly excludes food contact substances, including food packaging material, from the definition of food. Thus, manufacturers of food packaging will not be required to register those facilities under the interim rule nor will they be required to provide prior notices of imported food contact substances.

FDA also reacted favorably to CHPA concerns about the amendment process and time lines for filing import notices. CHPA had pointed out that the proposed rules actually created disincentives for filing notices as far in advance as possible and discouraged filing amendments as more information about the contents of a shipment became available. In response, FDA reduced the deadline for submission of prior notices and adopted a more flexible approach that accounts for differences among shipments arriving by rail, road, water, or air. The interim final rule also eliminates the requirement for amendments and updates because of the shorter timeframe in which to file.

In other bioterrorism-related matters, FDA announced October 8 it will conduct a November 6 meeting of the Science Board to discuss FDA's Food Security Program. On October 10, the Agency announced the availability of a risk assessment for food terrorism and other food safety concerns.

CHPA contact: Steve Mister

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FDA’s expert panel on pharmaceutical science to convene

The Advisory Committee for Pharmaceutical Science will meet October 21 – 22 in Rockville, Maryland. The panel’s agenda for October 21 includes receiving updates from FDA’s manufacturing, clinical pharmacology, and pharmacology/toxicology subcommittees, as well as a discussion of the Agency’s draft guidance on Process Analytical Technologies. For more information about this meeting, please review the Federal Register notice on the subject. 

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FDA announces staffing changes

A number of key FDA professionals have taken new posts recently. 

  • Margaret O'K. Glavin was appointed FDA's new assistant commissioner for counter-terrorism October 10. Glavin is a food safety policy expert and will be the senior counter-terrorism advisor to the commissioner.
  • Paul Seligman, M.D., has been named acting director of the Office of Drug Safety.
  • Steve Galson, M.D., will be the acting head of the Center for Drug Evaluation and Research, while the center's director, Janet Woodcock, M.D., completes a six-month assignment in the Office of the Commissioner. 

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OTC ingredient lists updated

The Association of the European Self-Medication Industry (AESGP) has updated a list of over 200 widely used ingredients on their prescription or nonprescription status in 32 countries, both in Europe and beyond. This year’s ingredient status list includes a number of new ingredient entries and five countries not included in previous editions, such as China, the Czech Republic, and Poland. The list is heavily footnoted with selected additional information on conditions and dosages.

The ingredient lists are available at www.aesgp.be/Ingredients/intro.html, organized under EU countries, non-EU European countries, and world.

CHPA contact: David Spangler

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EU pharmaceutical legislation moving forward

The EU Council of Ministers formally adopted a common position on the two key pieces of the EU’s pharmaceutical legislation package, clearing the way for its return to the European Parliament for the latter’s second and hopefully final round of consideration in the next few months. The legislation includes one year of data exclusivity for Rx-to-OTC switches with “significant” tests and trials and does not require that classification status be universal across the EU. For more information on the directive and its move through the legislative process, see the May 2 and June 12 Executive Newsletters

CHPA contact: David Spangler

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CHPA staff travel inside the Beltway and beyond

CHPA President Linda Suydam, Vice President of Government Relations Kevin Kraushaar, Vice President for Communications and Strategic Initiatives Virginia Cox, and Director of Government Relations Nancy Bukar traveled to New York City October 15 to attend the Partnership for a Drug-Free America's first gala event in honor of Jim Burke, former chairman and CEO of Johnson & Johnson. The festivities were emceed by television news anchor Tom Brokaw...

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CHPA plays a major role in IIR conferences

The Association will be represented by Vice President of Regulatory and Scientific Affairs Douglas Ws. Bierer, Ph.D., at two upcoming conferences sponsored by the Institute for International Research (IIR).

  • Rx-to-OTC Switch Marketers Forum, November 19-21, Philadelphia, Pennsylvania
    Chaired by Bierer and keynoted by Wyeth Vice President of Global Regulatory Affairs Sharon Heddish, this conference will deliver the latest intelligence on the current switch market and reveal new models for successful switches.

  • Preparing and Managing Rx-to-OTC Switch, January 14-16, 2004, Orlando, Florida
    The mission of this program, developed for pharmaceutical switch teams, is to present specific information on how to improve processes to respond to the OTC switch paradigm shift at the FDA. Bierer will present a perspective on the regulatory considerations of transforming the patient into the consumer on day two of the program.

CHPA members are eligible for a special discount. Contact IIR's Customer Service department at (888) 670-8200 and mention Priority Code XCHPA1.

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PharmaCongress.com readies for regulatory, compliance, and best practices forum

The Fourth Annual Pharmaceutical Regulatory and Compliance Congress and Best Practices forum is slated to take place in Washington, D.C., November 12-14. The agenda is packed with information on enforcement issues, compliance programs and best practices, advertising guidelines, etc. Continuing education credits are available. For more information and to review the conference program, visit www.pharmacongress.com

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2003 Business Development Conference
October 27-28, 2003
Clarion Hotel
Bentonville, Arkansas

Regulatory and Scientific Conference
November 6-7, 2003
The Fairmont Washington
2401 M Street, NW
Washington, D.C.

SAVE THE DATE

2004 Annual Executive Conference
March 17-19, 2004 [Wednesday-Friday]
Grand Hyatt Washington
Washington Center, 1000 H Street, NW
Washington, D.C.

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Executive Newsletter is published every other week by the
Consumer Healthcare Products Association
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Tel: (202) 429-9260
Fax: (202) 223-6835
Web site: www.chpa-info.org
 
Forward contact information changes to CHPA's Membership Department.
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Copyright © 2003 by the Consumer Healthcare Products Association (CHPA). CHPA's Executive Newsletter is for general information purposes only. Information reported in this newsletter is compiled from various sources. All efforts are made to assure the accuracy of the content, but CHPA cannot guarantee the information.  
 
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