Overview of the Complementary Medicines regulatory framework Australian Acupuncture and Chinese Medicine Annual Conference Perth 2016 Lyndall Soper, Assistant Secretary Complementary and Over-the-Counter Medicines Branch Medicines Regulation Division Therapeutic Goods Administration 20-22 May 2016
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Presentation: Overview of the TGA's Complementary Medicine ... · What is a Complementary Medicine? Complementary Medicines . Herbal Medicines ... • audit of manufacturing ... Overview
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Overview of the Complementary Medicines regulatory framework Australian Acupuncture and Chinese Medicine Annual Conference Perth 2016
Lower risk Higher risk Overview of the Complementary Medicines regulatory framework
8
Overview of the Complementary Medicines regulatory framework 9
Listed Medicines Regulatory Framework
Medicine listed on the ARTG
Post-market compliance
Pre-approved
ingredients
Good manufacturing
practice (GMP)
Low level therapeutic
claims
Overview of the Complementary Medicines regulatory framework 10
Applying for a listed medicine • Electronic application:
– Electronic Listing Facility (ELF)
• Easy access to market: – Supply within 48 hours of
applying
Overview of the Complementary Medicines regulatory framework 11
Pre-approved ingredients
Pre-approved ingredients
GMP
Low level therapeutic
claims
• Low risk
• Some restrictions: • Limits • Route of administration • Plant parts, type of preparation • Labels • Container type
Overview of the Complementary Medicines regulatory framework 12
We are often asked why the TGA does not allow some TCM? • Potential reasons:
• Legislative restriction • Negative outcome from previous evaluation • No previous application
• Risk based approach
• Something that has been used traditionally doesn’t always mean it is safe
• Safety concerns require further scientific data to show absence of the concern
• We can consider internationally recognised safety reports (e.g. from Health Canada, EFSA)
Overview of the Complementary Medicines regulatory framework 13
Good Manufacturing Practice (GMP)
Pre-approved ingredients
GMP
Low level therapeutic
claims
• Licence or clearance
Overview of the Complementary Medicines regulatory framework 14
Evidence for Listed Medicines
Pre-approved ingredients
GMP
Low level therapeutic
claims
• Sponsor: evidence for all indications and claims
• Complementary medicines indications: – Traditional – Scientific – Cross-paradigm
• Evidence Guidelines
Overview of the Complementary Medicines regulatory framework
15
Listed Medicines Compliance Framework
Pre-approved
ingredients
Good manufacturing
practice (GMP)
Low level therapeutic
claims
Overview of the Complementary Medicines regulatory framework 16
Medicine listed on ARTG
Post-market Compliance
review
Fully compliant
Cancelled from
ARTG
Non compliant
TGA: Post market compliance
Risk based regulatory approach includes: • desk-based audits of listed medicines – ‘compliance
reviews’ • laboratory testing of products and ingredients • monitoring of adverse reactions • recalls • audit of manufacturing sites • controls for advertising
Overview of the Complementary Medicines regulatory framework 17
Post market compliance at our Branch Risk based regulatory approach includes: • desk-based audits of listed medicines – ‘compliance
reviews’ • laboratory testing of products and ingredients • monitoring of adverse reactions • recalls • audit of manufacturing sites • controls for advertising
Overview of the Complementary Medicines regulatory framework 18
• If the medicine cannot be listed then it may need to be Registered
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Traditional Indications – Evidence “Tradition of use”
• Evidence to show use for its intended purpose for at least 3 generations (75 years)
• Only refer to terms within that paradigm
Sources of evidence include: • National formularies • Materia medica • Monographs • Official pharmacopoeias e.g. Pharmacopoeia of the People’s Republic
of China
Overview of the Complementary Medicines regulatory framework 20
Overview of the Complementary Medicines regulatory framework 22
Traditional Chinese Medicines within the regulatory framework • Adulteration • Aristolochic acids • Homeopathic ingredients
Akebia, Asarum, Bragantia, Clematis, Cocculus, Diploclisia, Menispernum, Saussurea, Sinomenium, Stephania, Vladimiria. Products containing Mu Tong and Fang Ji as ingredients also at risk of containing the Aristolochia species.
Overview of the Complementary Medicines regulatory framework 23
Traditional Chinese Medicines within the regulatory framework