Presentation: Complementary Medicines Regulatory Reforms: Permitted indications
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The document outlines regulatory reforms for complementary medicines in Australia, primarily focusing on establishing a list of permitted indications from which sponsors must draw for listed medicinal products. It details the criteria for permitted indications, including therapeutic significance, compliance with advertising codes, and consistency with treatment paradigms, while also emphasizing a transition period for existing products to adapt to these new regulations. Additionally, it highlights the legislative changes needed for implementation, the process for feedback and proposals, and the types of indications that will be permissible.
Presentation: Complementary Medicines Regulatory Reforms: Permitted indications
- 1. Complementary Medicines Regulatory Reforms Permitted indications Dr Allison Jones Director, Complementary and OTC Medicines Branch Medicines Regulation Division, TGA Complementary Medicines: Regulatory Obligations Seminar 11 April 2017
- 2. Permitted indications Recommendation Thirty-Eight The Panel recommends that the TGA establishes the list of Permitted Indications, from which sponsors must exclusively draw, for listed medicinal products in the ARTG. Government Response The Commonwealth accepts Recommendation Thirty-Eight, noting that implementation of the list of Permitted Indications will require legislative change and will be subject to consultation with consumers, sponsors and health professionals. Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 1
- 3. What does Permitted Indications mean for sponsors? Sponsors listing a medicine on the ARTG will only be able to use indications from a permitted indications list “Free text” field will no longer be available TGA will also have the ability to create a non-permitted indications list e.g. smoking cessation 3 year transition proposed Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 2
- 4. Permitted indications on labels Indications will not have to be ‘word for word’ on the label or advertising material: the intent and meaning of the indication must not change this will give flexibility to sponsors and contain the size of the list For example: ARTG indication: ‘Maintain/support bowel regularity’ Label indication - same meaning: ‘X helps maintain regular bowel movements’ Label indication - different meaning: ‘X relieves constipation’ Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 3
- 5. Steps in the development of permitted indications list… 1. We will publish the draft list on TGA website by July 2017 2. TGA inbox for feedback and proposing new indications 3. List will be closed on 1 October 2017 to enable the drafting and publication of the legislative instrument 4. New indications proposed after this time will incur a fee Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 4
- 6. Criteria for permitted indications 1. Must be a therapeutic indication (describe a therapeutic use) 2. Must be a low level indication 3. Must be capable of complying with the Advertising Code when included on promotional materials 4. Must be consistent with the treatment paradigm (scientific/ tradition of use) Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 5
- 7. Criteria for permitted indications continued 1. Must be a therapeutic indication (i.e - describe a therapeutic use) • Therapeutic use for listed medicines means use in, or in connection with, ‘influencing, inhibiting or modifying a physiological process in persons’ • Indications can be: – specific (e.g. refer to a named non-serious condition); or – non-specific (e.g. general health maintenance) • Indications can be based on scientific evidence or a tradition of use Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 6
- 8. Criteria for permitted indications continued 2. Must be a low level indication • Must only refer to: – health enhancement – health maintenance – prevention or alleviation of dietary deficiency; and/or – a health benefit for a non-serious forms of a disease, ailment, defect or injury • Permitted indications can only refer to conditions that are: – self-diagnosable – self-manageable • A delay in medical treatment would not be detrimental to the consumer Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 7
- 9. Low Level Indications What this means Examples Health enhancement Beneficial effects of substances on the physiological and /or psychological state of the body; - above and beyond normal growth, development and functions of the body Helps improve immune system May increase energy / reduce fatigue Helps stimulate digestive function Health maintenance Normal physiological effects of substances in; growth, development and normal functions of the body Helps maintain healthy hair, skin and nails Assists with normal liver function Helps support healthy connective tissue / joints Prevention or alleviation of a dietary deficiency Prevention of mild dietary deficiency (not prevention of diseases resulting from severe deficiency) When taken regularly, may prevent vitamin D/ calcium deficiency Helps reduce the risk of iodine deficiency Helps prevent dietary vitamin B12 deficiency
- 10. Low Level Indications What this means Examples A non-serious disease, ailment, defect or injury (other than prevention or alleviation) Those low risk conditions that are non-serious and self manageable. May be related to; - reduction in risk/frequency/duration - relief - management or improvement in quality of life …without resolution of the underlying non-serious disease, ailment, defect, condition or injury. May relieve symptoms of mild osteoarthritis Helps reduce the severity of common cold symptoms For the management mild dermatitis symptoms May relieve post-menopausal/PMS symptoms Helps reduce the frequency of common cold sore outbreaks Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 9
- 11. Criteria for permitted indications continued 3. Must be capable of complying with the Advertising Code when included on promotional materials Permitted Indications when linked to ingredients must not: – mislead, or be likely to mislead consumers – contain any implication that the medicine is infallible, unfailing, magical, miraculous, or that it is a certain, or guaranteed cure – contain any claim, statement or implication that it is effective in all cases of the condition Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 10
- 12. Criteria for permitted indications continued 4. Must be consistent with the treatment paradigm • Must be consistent with the evidentiary support (scientific or tradition of use) – Indications based on scientific evidence should not use traditional terminology, eg ‘alterative’ or Indications based on a ‘tradition of use’ should not reference a scientific procedure or investigation eg ‘increase haemoglobin in red blood cells’ or ‘increase bone mineral density’ Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 11
- 13. Indications NOT suitable for permitted indications list A permitted indication, must not: • refer to, or imply, the prevention or cure of any form of a disease, ailment, defect or injury • contain a prohibited representation • contain a restricted representation • be specified in a non-permitted indications list Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 12
- 14. What is a prohibited representation? Under the Therapeutic Goods Advertising Code 2015, a prohibited representation is defined as: (i) any representation regarding abortifacient action; or (ii) any representation regarding the treatment, cure or prevention of the following diseases: – Neoplastic (i.e. cancer) – Sexually Transmitted Diseases (STD) – HIV AIDS and/or HCV; or – Mental illness (e.g. depression, anxiety, low mood) Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 13
- 15. What is a restricted representation? A restricted representation is serious form of a disease, condition, ailment or defect included in Table 1, Appendix 6 Part 2 of the Therapeutic Goods Advertising Code 2015 • Cardiovascular diseases • Dental and periodontal diseases • Diseases of joint, bone, collagen, and rheumatic disease • Diseases of the eye or ear likely to lead to blindness or deafness • Diseases of the liver, biliary system or pancreas • Endocrine diseases and conditions including diabetes and prostatic disease • Gastrointestinal diseases or disorders • Haematological diseases • Infectious diseases • Immunological diseases • Mental disturbances • Metabolic disorders • Musculoskeletal diseases • Nervous system diseases • Poisoning, venomous bites and stings • Renal diseases • Respiratory diseases • Skin diseases • Substance dependence • Urogenital diseases and conditions 14
- 16. What is a serious form? ‘Serious’, means those diseases, conditions, ailments or defects that are generally accepted: • not to be appropriate to be diagnosed and/or treated without consulting a suitably qualified healthcare professional, and/or • to be beyond the ability of the average consumer to evaluate accurately and to treat safely without supervision by a qualified healthcare professional Examples • ‘Reduces risk of atherosclerosis’ • ‘Beneficial for anaphylaxis’ Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 15
- 17. Permitted indications – structure Traditional CONTEXT (mandatory if applicable) Action qualifier ACTION mandatory Target qualifier TARGET mandatory Indication qualifier E.g. Help to maintain/support healthy joints in elderly individuals Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 16
- 18. Options for implementing the list 1. Prescriptive list 2. Core indications with modifiable qualifiers 3. Build a unique indication from pre-approved indication components Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 17
- 19. Option 2: ‘Core’ permitted indications (preferred) 1. Select tradition of use (Optional) Indications that do not specify a tradition of use are by default scientific. 2. Select core permitted indication (Mandatory) At least one core indication is selected in ELF using drop down lists or key word search. 3. Select specifying qualifiers (Optional) Sponsors can choose to apply one or more pre-approved qualifiers to each core permitted indication by selecting from a drop down list. Healthy target population Effectiveness Time of use Tradition of use N/A Core permitted indication ‘Relieves muscle aches and pains’ Specifying qualifiers Healthy target population: ‘in healthy individuals’ Effectiveness: ‘Temporarily’ Time of use: ‘after exercise’ Final permitted indication on product label E.g. Temporarily relieve muscle aches and pains after exercise in healthy individuals. 18
- 20. Option 3: Build unique indications from pre-approved indication components ARTG Indication – sponsor creates the indication by selecting from drop down lists for each component below Tradition of use If applicable Action qualifier optional ACTION mandatory Target qualifier optional TARGET mandatory Indication qualifier optional 19 Tradition of use Action qualifier ACTION Target qualifier TARGET Indication qualifier Traditionally used in Western herbal medicine - To help May help Stimulate Relieve Healthy Symptoms of Digestion Eye strain - Associated with prolonged computer use
- 21. Transition to the Permitted Indications List • From 1 January 2018, all new listed medicines must select permitted indications (free text will be turned-off) • Sponsors of existing listed medicines will be required to transition their existing indications to ‘permitted indications’ by 31 December 2020: AUST L numbers will not change Fee waiver/reduction if indications changed by 31 June 2019 • Listed medicines that do not transition to permitted indications will be cancelled from the ARTG from 1 January 2021 Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 20
- 22. Indications not on the permitted list? During the 3yr transition period, sponsors with intermediate indications will be required to: – transition to the ‘new pathway’ for TGA assessment of evidence; or – transition to ‘permitted indications’ Sponsors can apply for permitted indications that meet the agreed criteria – free until 1 October 2017 Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 21
- 23. Applying for a new indication • Sponsors can apply for new permitted indications to be added to the list – A fee will apply • Evidence to support a proposed indication will not be evaluated by the TGA – However, applications will be assessed against the established criteria • The permitted indication list is likely to be updated on a quarterly basis 22
- 24. How are we developing the permitted indications list? • A comprehensive list of permitted indications is being developed in consultation with industry based on agreed criteria • List is based on industry submissions to previous consultations • Targeted consultation on the list also includes stakeholders concerned with traditional paradigms, such as TCM’s Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 23
- 25. Development of the list of permitted indications General indications ~ 1300 Can be supported by either scientific evidence or a tradition of use e.g. ‘Help relieve dry skin’ Traditional indications ~ 200 Include traditional terms that may be applicable across multiple traditional paradigms e.g. ‘cholagogue’, ‘alterative’ ‘adaptogen’ Traditional Chinese Medicine indications ~ 200 Contain TCM specific terminology that can only be supported by evidence of TCM use e.g. ‘Increase Qi flow’ Scientific indications ~ 200 Can be supported by scientific evidence only. e.g. ‘Maintain /support normal/healthy red blood cells’ 24
- 26. Initial outcomes of public consultation • Majority agree for the proposed criteria for permitted indications • A majority of stakeholders support Option 2 - Core indications with modifiable qualifiers • A majority of stakeholders agree that the proposed three year transition period is adequate Complementary Medicines: Regulatory Obligations Seminar – 11 April 2017 25
- 27. Questions? 26