WPF DHL CD Dist Final
WPF DHL CD Dist Final
WPF DHL CD Dist Final
takeholders involved in controlled substance or narcotics clinical trials will know that these studies can be the most challenging and complex types of clinical research: from the sponsor and the clinical research organisation (CRO) to the packagers, logistics companies and investigators, everyone understands that obtaining approvals and ensuring drug availability in order to conduct the research is often problematic. Delays and challenges in the supply chain not only slow down advances in clinical research and impact the benefit to patients, but can also be very costly to the sponsor. Inefficiency leads to inflated expenditure, insufficient clinical data, and delays can result in rival products being released to the market first.
Traditional practices
When deciding which countries to select for a clinical trial, site feasibility, patient recruitment, key opinion leader endorsement, clinical trial approval times and investigator site relationships are more often than not at the forefront of the design discussions. Once the clinical trial sponsor has agreed these with the CRO, a list of countries and sites is produced so that work on site initiation can begin. It is often only after this point that the interactive voice recognition system (IVRS) provider and logistics company are brought into the discussions and are asked to agree the lead-times for shipping into each country. Inevitably, shipments are expected to commence as soon as possible.
Challenges of supply
Different drugs under research can present unique challenges in consideration of their distribution. Controlled substances are naturally one of the more challenging due to the security considerations associated with their frequently more dangerous or addictive nature. These drugs are classified in five schedules according to different levels of control. Complexity is further increased because different countries have different rules and regulations regarding the importation or exportation of these substances when conducting a clinical study. The EU has recognised in general the need to harmonise the regulatory landscape to facilitate more clinical research taking place in Europe within the member states. As a result the following clinical trial legislation has been implemented over the past six years:
2001/20/EC (GCP) 2003/94/EC (GMP) EUDRALEX Vol 4.
Article 13 (Manufacture and Import of IMP) Annex 13 (Manufacture of IMP) Annex 16 (QP Cert and Batch Release)
This regulatory harmonisation has made an impact. For example, all clinical trials supplies being imported to France previously had to be shipped to an in-country warehouse to undergo checks before they could be moved on to the investigator site conducting the research. This added extra time and further unnecessary handling in the supply chain, along with the extra costs of an in-country warehouse. With the passing of the harmonisation in member state country regulation, drugs can be shipped from a central stockholding location within the EU directly to an investigator site. This enables a 24-48-hour turn-around time, from an order being placed on the IVRS through to delivery to site, which in turn enables supply
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Table 1: Examples of the different authorities that regulate all matters pertaining to controlled narcotics
Country uK italy Germany France Clinical trial regulator MHRA Ministero della Sanit BfArm (National Competent Authority) AFFSAPS GIF (Main Pharmaceutical Inspectorate) narcotics authority DoH (Home Office) Ministero della Sanit Bundesopiumstelle (Federal Opium Agency) AFFSAPS (Narcotics and Psychotropics Unit) National Bureau for Drug Prevention (Narkomania) narcotics legislation 1971 Misuse of Drugs (Safe Custody) Act Decreto Presidente Repubblica (DPR) 9 Ottobre 1990, n. 309 Narcotics Act of 1981 1970 Law No. 70-1320 Respecting health measures in the fight against substance abuse and repression of the trafficking in and use of poisonous substances. Act of Law of 29 July 2005 on Counteracting Drug Addiction
Poland
chain companies to do what is logistically efficient by reducing transit times and the number of people that handle a drug. The issue, however, with controlled drugs is that, rather than a health authority regulating trials and their supplies, member state countries have separate narcotics authorities that have not been subject to regulatory harmonisation (see Table 1, above). Therefore there are narcotics rules within the EU with regard to pre-notification of a shipment, import and export permissions, safe custody of the product, and the destruction of unwanted medication, which vary from country to country. All are important factors that a logistics company has to be aware of, but that are not always considered at the design phase of the clinical trial.
chain at risk. A logistics company needs to take a lead role in the supply chain to address any inconsistencies through training and clearly defined responsibility matrices.
Balancing act
Despite many EU member states having different rules when importing, exporting and storing controlled drugs during a clinical trial, there is one regulation that is currently quite consistent the need for an in-country depot. This often consists of making someone in-country responsible and accountable for all deliveries of controlled substances to a hospital or pharmacy. Finding the right warehouse while trying to maintain standard operating procedures across all the depots within the clinical trial can be demanding. Globally, one can always find a specialist clinical trials supplies (CTS) organisation that can store, pick and distribute materials during a clinical trial. These CTS providers are used to deliver fine pick operations where individually serialised medication packs must be identified during blinded or double-blinded studies, and go through a number of checks to ensure picking accuracy. However, there are only a few with the expertise or infrastructure to store and distribute controlled drugs (as well as having knowledge of the unique demands of the clinical supply chain). This expertise may be found among wholesalers that have all the required licensing and comply with infrastructure and security regulations. Their experience lies in the need to supply pharmacies and doctors with prescribed medicines on a much larger scale than a clinical trial, with far more standardised products (for example, not blinded or needing the same degrees of cold chain control). Selecting between the two within each country can be a difficult choice, and often requires on-site training to up-skill a non-CTS companys capability while trying to maintain standard operating procedures across all the countries involved in the same clinical trial, so as to provide a service consistency that does not put the supply
Further information
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