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European Pharmaceutical Contractor

Journey to the Centre of eCTD

Nancy Smerkanich of Octagon Research Solutions charts the evolution of electronic submissions, and calls for a convergence of standards within the regulatory arena

Over the past 10 years there has been an evolution in electronic submissions to regulatory authorities both in the US and Europe. Companies who develop drugs for the purpose of marketing them in multiple markets were early adopters of the technologies that facilitated electronic document use and reuse for these purposes. This evolution was initially driven by the US Food and Drug Administration (FDA), but the EU has been involved, through the activities of the International Conference on Harmonization (ICH), in developing the standards that will take current submission formats to the next level, namely the electronic Common Technical Document (eCTD). This article attempts to provide the history behind eCTD as well as the direction and areas it can and most likely will move forward.

TECHNOLOGY PLATFORMS

There are some basic technologies or platforms that have formed, and will continue to form, the basis for electronic submissions. The first of these is portable document format (PDF). Word processed documents can be easily converted to PDF and have the advantage of preserving the formatting of the document in which they were created. In addition, as the functionality of the software for creating these documents has matured, there are many more features that can be leveraged that add navigation to the PDF documents. These include: hypertext linked tables of contents; heading styles that convert to bookmarks; and cross-references that are retained as hypertext links within the document. PDF documents can also be created from image-based sources, but with less functionality.

Text-based PDF (that is, where the source is a word processed document as opposed to a scanned image of a paper document) can be searched by term and can easily be cut and pasted, using readily accessible software, into documents and reports by agency reviewers. Because PDF documents preserve the format of the original or source documents and because they can be viewed through the use of tools such as Acrobat Reader (freeware), they became acceptable as both the review copy as well as the archive copy of the submission.


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Prior to joining Octagon Research Solutions as Vice President, Regulatory Affairs, Nancy Smerkanich held various positions within regulatory affairs departments. She has prepared and maintained IND applications for over 30 compounds and prepared multiple new drug applications, background packages, safety update reports, summary basis of approval documents, efficacy and labelling supplements, annual NDA and periodic ADR reports for submission to regulatory authorities. She has served as Regulatory Liaison with FDA/CBER and the Orphan Drug Product Office and has also directed activities relating to quality assurance audits and participated in training activities for in-house personnel and industry leaders. Nancy holds a BSc in Microbiology and a BA in Russian from the University of Connecticut.
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