Transitioning Chemistry, Manufacturing, and Controls Content With a Structured Data Management Solution: Streamlining Regulatory Submissions

The process of assembling regulatory documents for submission to multiple global health agencies can present a repetitive cycle of authoring, editing, and data verification, which increases in complexity as changes are made for approved products, particularly from a chemistry, manufacturing, and controls (CMC) perspective. Currently, pharmaceutical companies rely on a workflow that involves manual CMC change management across documents. Similarly, when regulators review submissions, they provide feedback and insight into regulatory decision making in a narrative format. As accelerated review pathways are increasingly used and pressure mounts to bring products to market quickly, innovative solutions for assembling, distributing, and reviewing regulatory information are being considered. Structured content management (SCM) solutions, in which data are collated into centrally organized content blocks for use across different documents, may aid in the efficient processing of data and create opportunities for automation and machine learning in its interpretation. The US Food and Drug Administration (FDA) has recently created initiatives that encourage application of SCM for CMC data, though many challenges could impede their success and efficiency. The goal is for industry and health authorities to collaborate in the development of SCM for CMC applications, to potentially streamline compilation of quality data in regulatory submissions.