Outsourcing Clinical Supplies Manufacturing | Page 2

Outsourcing Clinical Supplies Manufacturing Part 1: Navigating US Import Laws Revenue for contract manufacturing of bulk and dosage form drugs reached $48.6 billion worldwide in 2010 and is projected to reach $86.3 billion by 2016, increasing at a compound annual growth rate of 10.1%.1 Many contract manufacturing organizations (CMOs) are now Figure 2. Clinipace Approach to Clinical Supplies Manufacturing located outside of the US or EU, and this shift presents significant challenges to ensuring both the quality of the supply chain and the timeliness of receiving products intended for clinical or commercial distribution. Figure 1. Within the Regulatory and Strategic Development (RSD) division Revenue for Contract of Clinipace, our international team of quality assurance and Manufacturing of Bulk & Dosage Form Drugs Worldwide regulatory professionals assists clients with these challenges every day. The cornerstone of our approach is a set of quality systems (defined within SOPs) that are applied to the qualification, selection, and management of contract manufacturing organizations (CMOs) for virtual companies and sponsors of clinical trials. These documents delineate roles, set up the infrastructure for SOPs, and address key issues such as batch release, training, and change control. Many of these procedures should be established before the CMO is selected, and almost all should be put in place before the actual manufacturing of the active pharmaceutical ingredient (API)/drug product begins. With our clients, we also emphasize the need to decide up front if the drug supplies will be imported into the US, the EU, or both, as the rules and regulations vary by region/country. Understanding the labeling, documentation, and timing requirements for importation is critical, as changes late in the process can significantly delay time lines. This white paper, part 1 in a series, focuses on a change in the standard practice in the import of clinical trial supplies into the US. After reviewing the law, we explore the implications of the change and offer suggestions about overcoming this latest hurdle. clinipace.com 1