Title: Workshop on Electronic Submissions of Biologics: eCRFseCRTs and the eBLA, ePLAELA
1Workshop on Electronic Submissions of Biologics
eCRFs/eCRTs and the eBLA, ePLA/ELA
- Mary A. Buesing, M.D.
- CBER, FDA
- May 22, 1998
2Agenda
- Important milestones
- Organization content of an eBLA
- CRTs
- CRFs
- roadmap.pdf
- readme.pdf
- cover.pdf
- Demo
3Important preparation milestones
- Ideally 8-10 months before submission notify an
offices CALA coordinator - 4-6 months ahead of time, plan to demo the
submission structure, content and navigational
capability - 30 days - provide a mock-up version for testing
on the network - on day of submission provide all of the
certifications and cover.pdf information
4Critical success factors
- Simultaneous receipt of paper and electronic
portions - still a major problem due to underestimations of
the time needed to put together a PDF CALA - A fully navigational, viewable and printable
submission - CBER recommends that you test these features
using our DSP standards before submission - Limit scanned documents submitted (e.g.
CRFs,pubs,C.V.s)
5Organizational Structure
- Harmonized form 356h backbone of the
e-submission - for the eBLA embed 356h in a pdf file under
cover.pdf - for ePLA embed the appropriate licensed
application form - eg 3212 for a vaccine - until regs change and everything becomes a BLA
- for eELA embed a filled out 3210 as pdf file(s),
or use the guidance - item 15
619 Subsections of the Harmonized form 356h
- 10. Statistical Section
- 11. Case Report Tabulations
- 12. Case Report Forms
- 13. Patent information
- 14. Patent certification
- 15. Establishment Description
- 16. Debarment certification
- 17. Field copy certification
- 18. User fee cover sheet
- 19. Other (specify)
- 1. Index
- 2. Labeling
- 3. Summary
- 4. CMC
- 5. Nonclinical Pharmacology
- 6. Human Pharmacokinetics
- 7. Clinical Microbiology
- 8. Clinical Data
- 9. Safety Data Update
7Folder or pdf file names corresponding to each
item
- clinical
- update
- stats
- safety
- crt
- crf
- labeling
- summary
- cmc
- pharmtox
- cpbio
- micro
- estab
- patinfo.pdf
- patcert.pdf
- userfee.pdf
Exceptions items 13,14,16 amd 18 are pdf files
and do not need folders. Item 17 -field copy
certificaton is not applicable
8The BLA or PLA/ELA is a collection of individual
documents
- Convert each document to a PDF file
- Place all files for each item into its
appropriate folder -
9Organizing the folders
-
- Please label the folders to facilitate
easy identification for downloading of
files from the network
10The BLA or PLA/ELA is a collection of individual
documents
- Place all folders into a main folder with the
submissions number
B000000 (or I000000) Amendments B0000000.001
thru B0000000.999
11Each items folder may contain
- Subfolders
- The item PDF files
- A table of contents file
- An index (PDX) file
12Each items folder includes a TOC
- Hypertext linked to each subfolders content pdf
files - It includes the location of the file
13and may include bookmarks...
- If the pdf files are large they may also contain
bookmarks for easy navigation - eg batch records
often require bookmarks - If some of the items material is in paper,
include the location of the paper by volume
number if possible
14Example
Item folder
CMC
CMCtoc.pdf
CMC.pdx
substan
product
invest
enviro
batch
15e-TOC includes
- BLA TOC
- located in the main folder
- lists all items in the e-submission
- hypertext links to each items TOC
- Items TOC
- located in the items folder
- lists all documents in the items folder
- hypertext links to each document
- Documents TOC
- located in the documents PDF file
- lists all sections/subsections
- bookmarks link to the sections
16For each document provide hypertext links to
- annotations
- related sections
- references
- appendices
- tables
- figures
- embedded forms
Note Please do not try to use hypertext linking
across CD-ROMs
17For large technical sections include a text index
(pdx) file
- An index is not a table of contents but provides
a search function - Index all file text and document information
fields - An Index consists of an index file (PDX) and
associated files contained in a single folder
18Identify the document in the PDF Document
Information Title Field
19eCRTs
- Can be provided in 2 types of formats
- Domain profiles
- Patient profiles
Please consult with the product office
re preferences for submisison
20eCRTs- domain
- Also known as data listings
- Consist of all data for a CRF domain
- such as demographics, vital signs, labs, etc
- Provide a table for each CRF domain
- display the variables as column headings
- results per patient per row
21eCRTs - domain
- Provide a single PDF file for each CRF domain
- All domain profiles for a single study should be
placed in a subfolder identified with the study
number - Place all subfolders within a single folder
domain
22eCRTs - domain
- A table should be provided for each CRF domain
that displays variables as column headings and
results for each patient in rows - Datasets can be submitted in lieu of PDF files if
reviewing office agrees - submitted as SAS Transport files under the
statistical section
23eCRTs - domain
- The title field of the document information field
for adverse events in study 2001 would be - dp, study 2001, adverse events
24eCRTs - patient profiles
- Consist of one or more pages that contain all of
the study data collected for an individual
patient - A table should be included for each CRF domain
for each patient - such as vital signs,
demographics, labs, efficacy measures - the organization of tables should be oragnized by
time and consistent across domains and patients
25eCRTs - patient profiles
- 3 approaches depending on size and navigational
function - each patients profile can be provided as a
single PDF file - all patient profiles for a single site in one
file - all patient profiles for a study in one file
- place all study subfolders into a folder named
crt
26eCRTs - patient profiles
- The title field of the document information field
for patient 001 in study 2001 at site 003 would
be - pp, study 2001, site 003, PID 2001-003-001
27crt
domain
dptoc.pdf
domain.pdx
Aes.pdf labs.pdf vs.pdf include.pdf exclude.pdf co
nmeds.pdf
study 2001
site 3
site 1234
profile
pptoc.pdf
profile.pdx
study 2001
28eCRFs
- Usually scanned documents
- use 300-600 dpi
- make sure they are legible printable
- please test these on computers with CBERs
current DSP settings (800 x 600) - Each patients CRF should be provided as a single
PDF file, or if small (usually 50 MB) place all
patients CRFs per site/study as a single folder - All CRFs for a single site should be placed in a
subfolder with the site number within the study
folder
29eCRFs
- Each patients CRF should provide a bookmark link
to each study visit with each CRF domain - such
as demographics, vital signs, labs ,etc - Alternaitvely, a TOC could be provided as page 1
of each patients CRF, listing the page location
of all CRF domains collected at each study visit
30eCRFs
- The title field of the Document Information
dialogue should contain - the study number
- the site number
- the unique PID
- For example, for patient 001 in study 2001 at
site 003 would be entered as - crf,study2001, site 3, PID 2001-3-1
31eCRFs
32Clinical Study Reports
study003.pdf
333 Important Contents of an Application Folder
B9800000
roadmap.pdf
readme.pdf
cover.pdf
365h
any certifications
34roadmap.pdf
- Used to establish links between the applications
main toc (blatoc.pdf) and the respective files
and folders of the submission - Also, it is a means of chronologically linking
subsequent applications to each others
blatoc.pdf files thereby, creating a growing toc
for all components of the submission
35roadmap.pdf
- It is unique for every submission
- It is replaced/updated using the replace file
command under Document menu option - see Table 1 of the guidance document
36readme.pdf
- contains directions for installing, configuring
and navigating through the submission - the roadmap.pdf file and the blatoc.pdf should be
hypertext linked to the readme.pdf file
37cover.pdf
- A description of the submission
- A table summarizing which portions of the
submission are in electronic vs. paper format - A table summarizing the submission size and format
38cover.pdf
- A virus verification table
- A table of a sponsors points of contact
- a completed 356h form
- any certifications
39DEMO