Law - Semester 2 Flashcards
Which regulations determine licensing requirements?
HMR
Which aspects of medicines does licensing affect?
Manufacture
Sale
Supply
Importation
Which bodies can provide licensing for medicines?
Medicines and Healthcare products Regulatory Agency (MHRA)
European Medicines Agency (EMA)
What are the objectives of legislation surrounding licensing?
- Efficacy, safety and quality of medicinal product
- Withdrawal of the product should any danger be discovered
What medicinal products are covered by licensing legislation?
- Authorised medicinal product
- Investigation medicinal products
Which stages does licensing legislation cover?
Initial development and research through to final marketing
What are the different types of licenses or certificates?
Marketing authorisation Certificate of registration Traditional herbal registration Manufacturer's license Wholesale dealers license Clinical trial authorisation
Describe the three stages of clinical trials
- Drug given to small groups - Evaluating safety, therapeutic range and side effects
- Drug given to a larger group - Testing efficacy and safety
- Drug given to even larger group - Increased safety, confirm efficacy, monitor side effects. Compare to other common treatments
What is a marketing authorisation and who must have one?
- Allows the sale, supply, import and export of a relevant medicinal product
- Must be held by the person in charge of the product manufacture
What must an application for a marketing authorisation contain?
- Name and address of applicant (and manufacturer)
- Name of product and specification
- Evaluation of environmental risks
- Method of manufacture and quality control
- Indications, contraindications, compatibility and clinical studies data
- Pharmacovigilance system
- Product characteristics, package and leaflet
- Proposed legal category
What type of products may require application for a marketing authorisation?
- New active substances
- Generic medicinal products
- Biological/Biotechnology products
What is important for a marketing authorisation to be granted?
- Product determined safe and effective
- Manufacturing/quality control facilities must be adequate
How long is an initial marketing authorisation valid for?
5 years
What should be continuously relayed to the licensing authority for renewal of a marketing authorisation?
Changes to products and procedures
Any new information
What records must a marketing authorisation holder have?
- Adverse reports
- Sales and supplies
- Sources of materials
- Any document that will support product withdrawal
What must a marketing authorisation holder produce regarding safety?
Periodic safety update report
When may a product name be rejected by the MHRA?
if name is misleading, could cause confusion or is generally unsafe
In what patient group are unlicensed medicines used and why?
Children - medicinal products generally only have clinical trials in adults due to ethical issues
How do clinical trials for paediatric medicines differ to adult clinical trials?
Clinical trials for every age group within paeds
What are the EU regulations to increase availability of medicines for paeds?
- Paediatric investigation plan
- Paediatric use marketing authorisation
What legislation sets out the labelling requirements for relevant medicinal products?
HMR and Misuse of Drugs Regulations
What are the requirements for labelling medicinal products?
- Easily legible and comprehensible
- Indelible
- English only or English PLUS other languages
- Braille on outer packaging and PIL for blind patients
What are the outer and immediate packaging requirements?
- Name, strength and formulation of medicinal product
- Patient group intended
- Name and amount of active substance
- Pharmaceutical form by weight/volume/no. of doses
- List of excipients that have an effect (all excipients if injectable, topical or eye prep)
- Method and route of administration
- Prescribed dose (if appropriate)
- Children statement and cautionary warnings
- Expiry date
- Storage/disposal instructions
- MA holder name and address, MA number
- Batch no
- Instruction for use
- Classification
- NO PROMOTIONAL STYLE INFO
What must a blister pack contain?
- Name, strength and formulation of RMP
- Who the product is for (if appropriate)
- Name of active substance
- Name of MA holder
- Expiry date and batch no
What is the difference between the labelling of a small container and a blister pack?
All requirements of a blister pack but method of administration too
What are the labelling requirements for paracetamol?
- ‘Contains paracetamol’ if name does not state this
- ‘Do not take more than the label tells you to’
- Direct patients to doctor in case of overdose
- If consequences of overdose on PIL, does not need to be on outer packaging
Define manufacture
Any process carried out in the course of making the product
Not simply dissolving, dispersing, diluting or mixing the substance with a vehicle
Define assembly
Dividing up, packaging and presentation of the substance
What does a manufacturer’s license enable the holder to do?
- Manufacture or assemble licensed medicinal products
- Export product to countries outside the EEA
- Import licensed products from outside the EEA
What must the licensing authority know before granting a license?
- Operations to be carried out
- Premises
- Equipment available
- Qualifications of supervisors
- Safekeeping records
- Maintenance of adequate records
Who must hold a marketing authorisation before its manufacture?
Manufacturer OR person ordering the product
What does a manufacturer ‘specials’ license allow the holder to do?
- Manufacture of unlicensed medicines
- Import unlicensed products from outside the EEA
When is a ‘specials’ license not required?
If special product is being extemporaneously prepared in pharmacy
When are unlicensed products used?
- When licensed products do not meet the patient’s clinical needs
- Supplied according to unsolicited order from appropriate prescribers (for use by patient under their direct care)
What is a manufacturers license for investigational medicinal products?
- Allows manufacture of IMPs for clinical trials
- For phase 1, 2 and 3 clinical trials
Define wholesale dealing
Supplied to someone before the medicine reaches the patient
What classifications can be sold with a wholesale dealers license?
- Pharmacy
- POM
- Traditional herbal medicines
- GSL medicines
What other action can be undertaken with a wholesale dealers license?
Import of unlicensed products from inside the EEA
Who can medicines be distributed to?
- Wholesale dealer license holder (for those products)
- Equivalent EEA wholesale license holder
- Those who can lawfully sell or supply in retail sale
- Those who can lawfully administer
What are the conditions of a wholesale license?
- Staff, premises, equipment and facilities must be adequate for the handling, storage and distribution go medicinal products
- Distribution records must be kept for at least 5 years
When are licenses not required?
- If product prepared for an individual or for someone who holds relevant authorisations
- If activity takes place in registered pharmacy under supervision of a pharmacist
- If preparation and dispensing against a practitioner’s prescription or customer’s recipe/specification
- Counter prescribing
- Product assembly or stock mixtures
What are the conditions for own name products and is a license required to produce them?
No license - prepared under pharmacist supervision and not advertised to public
When are doctors and dentists exempt from licensing?
When preparing or assembling products on an individual patient basis
When are nurses and midwives exempt from licensing?
When assembling medicines for individual patients
What are the herbalist exemptions to licensing?
Products can be manufactured or assembled without a license or authorisation if:
- Herbal practitioner is present and premises can be locked
- Product is for administration to a person present at the time
- Product does not contain specific listed substance
When do manufacturers/marketing authorisation holders not require a wholesale dealers license?
If marketing own product
When is a wholesale dealers license not required for importing a product?
If product is imported for a specific patient
When is a wholesale dealers license not required for exporting a product?
If product is being re-exported without making any alterations
When is a marketing authorisation required for food and cosmetics?
If promoting products to practitioners
When do food and cosmetics require appropriate licensing?
If administered orally for beneficial/medicinal purposes - has a stated dose
When do vitamins require licensing?
- Oral administration with no dosage direction
- If dose exceeds a specified amount
- If foods with added vitamins exceed the daily range
Cosmetics containing what excipients must be appropriately licensed?
- Antibiotics
- 0.004% or more of a hormone
- 0.1% or more of hexachlorophane
- More than 1% resorcinol
What is a herbal medicinal product?
Products where the only active substances are herbal substances or preparations
Define ‘herbal substance’
A plant or part of a plant, fungi, lichen or algae or unprocessed exudate of a plant, defined by the plant part used and its biological name
Can be fresh or dried but otherwise unprocessed
Define ‘herbal preparation’
Herbal substance subjected to processes such as extraction, distillation, expression, fractionation, purification, concentration or fermentation
Contains a commented/powdered herbal substance, tincture, extract, essential oil, expressed juice or processed exudate
What are the types of herbal remedies and what licensing does each require?
- Licensed herbal medicines (MA and relevant classifications)
- Registered traditional herbal medicines (traditional herbal registration)
- Unlicensed herbal products (individual production based on face-to-face consultation)
- Food supplements or cosmetics (no licensing required)
Who are recognised suppliers of herbal remedies?
- Pharmacists
- Dealers - give product requested
- Practitioners - Prescribe using specialist knowledge
When can practitioners deal in any herbs?
Following 1-1 consultation and if patient is present
When do HMR restrictions for sale and supply of herbal products not apply?
- When product manufactured by herbalist practitioner on their premises (which can exclude public)
- If product is for administration to a person who has requested it in person
What ingredients prohibit the manufacture, sale, supply and importation of unlicensed medicines?
- Aristolochia
- Mu Tong
What ingredient prohibits the sale, supply and importation of products (unless for external use)?
Kava kava
What ingredient cannot be sold, supplied or imported?
Senecio
What are the restrictions of supply of herbal medicinal products by herbalists?
- If plant listed in schedule 20 part 1: Can only be sold in registered pharmacy under the supervision of a pharmacist
- If plant listed under schedule 20 part 2: Max. dose and percentage can be supplied after consultation with a herbalist, anything exceeding this can only be sold in a pharmacy under pharmacist supervision
What are the main groups of herbal products listed under schedule 20?
- Part 1: Daily anthelmintics and irritants
- Part 2: Alcaloids
Why may herbal products containing aconite have adverse effects?
- Extremely poisonous
- Cardiotoxic
What herbal remedies can be sold by pharmacists?
- Substances in pt1 and pt2 of schedule 20
- Anything that can be sold by a herbal practitioner, shopkeeper or herbal dealer
What herbal remedies can be sold by herbal practitioners?
- Any substances in pt2
- GSL herbal medicines
- Anything that can be sold by a shopkeeper or herbal dealer
What are the conditions for sale of herbal remedies by herbal practitioners?
- If remedy requested by person present
- Written record of sale/supply given to UK enforcement authority
What herbal remedies can be sold by shopkeepers/herbal dealers?
- GSL herbal medicines
- Products with a traditional herbal registration
- Food supplements or cosmetics
What are the conditions for a product to be given a traditional herbal registration?
- Used without need for medical practitioner
- Intended for use at a specific dose/strength
- Intended for oral, inhaled or external administration
- Been in use for min 30 years and 15 in the EU
- Traditional use should be effective and not harmful
What are the labelling requirements for traditional herbal medicines?
- Statement that product is a herbal medicine for a specific purpose
- Statement advising patient to seek medical attention if experiencing adverse effects
What license is required for importation of a traditional herbal medicinal product from a non EU country
Wholesale’s (import) license
What statements must be included in adverts for traditional herbal medicinal products?
‘THMP for use for [indication] exclusively based upon long standing use as a traditional remedy’
What regulatory body is responsible for the registration, manufacture and SPC of THMP? What powers do they have?
MHRA
Can ban sale or supply of herbal remedies that are thought to have adverse effects
How are THMP adverse effects reported?
Yellow card scheme
What are homeopathics?
Self treatment for minor conditions
Usually products in high dilutions
What is the national rules scheme similar to?
MA - but for homeopathics
What is the purpose of advertisements for medicinal products?
Promote prescription, sale, supply and use of the product
What are the methods of advertisement for medicinal products?
- Door-to-door canvassing
- Medical sales representatives visits (to those qualified to prescribe or supply)
- Samples
- Benefit of bonus to induce prescription or supply of product
- Sponsorship of promotional meetings attended by those who can prescribe or supply
- Sponsorship of scientific congresses
What are the different places of advertisement?
- Medical journals, magazines, newspapers
- Posters, public billboards
- TV, radio, internet
- Films/cinema
- Letters (circulating or direct)
When may a medicines advertisement be changed by the advertising standards authority?
If it is deemed misleading
Which regulatory body must confirm advertisements before their release?
MHRA
Which substances may have their promotional material vetted?
- New active substances with MAs
- Reclassified products
- Products that may have previously breached advertising regulations
What happens in the cases of a complaint against a medicines advertisement?
- Handled by MHRA or self-regulatory bodies
- Outcome of investigation published