This notice is being issued to clarify to drug manufacturers and sponsors that elements of Risk Management Plans required by Health Canada, such as controlled distribution programs, are not intended to restrict access to Canadian Reference Products (CRPs) for generic drug manufacturers for the purposes of conducting comparative testing. Any RMP elements should not delay or hinder comparative testing with generic products, or hinder their ability to enter the market.
Implementation of RMPs in Canada
In February 2009, Health Canada announced the implementation of risk management planning and in June 2015 released the Guidance Document – Submission of Risk Management Plans and Follow-up Commitments.
Quick Facts on RMPs
An RMP is a document that outlines pharmacovigilance activities and interventions to identify, characterize, prevent or minimize risks related to drug products. The RMP also contains an evaluation of the effectiveness of such risk minimization measures.
Risk minimization measures in an RMP aim to optimize the safe and effective use of a drug throughout its life cycle (e.g. appropriate labelling). However, for certain drugs with serious risks, more restrictive measures may be required when labelling alone is not enough to ensure the benefits outweigh the risks. For these drugs, Health Canada may require more restrictive risk minimization measures, such as a controlled distribution program. Under such programs, drugs may only be distributed through certain channels, and pharmacies, physicians, and patients may need to register to access the drug.
RMPs and Access to CRPs for Generic Drug Manufacturers
Before a generic drug can enter the market, a generic drug manufacturer must prove that the drug is safe and effective by submitting testing to demonstrate that it is pharmaceutically equivalent to the branded drug. To complete this testing, the manufacturer needs access to samples of the branded drug, also known as the Canadian Reference Product (CRP). These studies are then submitted to Health Canada for regulatory approval to market the generic drug.
Elements of an RMP, such as controlled distribution programs, cannot restrict access to CRPs for generic drug manufacturers that are conducting comparative testing.
Health Canada is committed to making sure that RMPs continue to contribute to patient safety, and reminds sponsors that RMP elements should not be cited as a reason to delay or hinder comparative testing with generic products, or hinder their ability to enter the market…