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Drugs and Health Products

Status of Applications Quarterly Report

Quarter 1 (April 1, 2012 to June 30, 2012)

Natural Health Products Directorate
Health Canada

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The Status of applications quarterly report is a publication of Health Canada's Natural Health Products Directorate (NHPD), the federal department responsible for the regulation of natural health products sold in Canada. The purpose of this report is to provide the Canadian public with statistical data on the product licence, site licence and clinical trial applications received and processed by NHPD.

Reporting Schedule*:

  • 1st Quarter: April 1 to June 30
  • 2nd Quarter: July 1 to September 30
  • 3rd Quarter: October 1 to December 31
  • 4th Quarter: January 1 to March 31

*Based on fiscal year, not calendar year.

Questions, comments or feedback regarding the content of the Status of Applications Quarterly Report may be addressed to the Natural Health Products Directorate.

Table of Contents

Performance summary and highlights

Format and content of report

The Natural Health Products Directorate's (NHPD's) Quarterly Report reflects the coming into force of the Natural Health Products (Unprocessed Product Licence Applications) Regulations (NHP-UPLAR) on August 4, 2010 and the publication of performance targets related to Product Licence Applications (PLAs) in the NHPD Application Management Policy on August 9, 2010.

NHPD reports on two types of PLAs:

  1. applications received before NHP-UPLAR came into force (pre-UPLAR PLAs), and
  2. applications received after NHP-UPLAR came into force (post-UPLAR PLAs).

Overall PLA statistics summary

NHPD has received 69 934 PLAs from January 1, 2004 to June 30, 2012. Of this total,
63 493 (91%) PLAs have been completed, including the issuance of 36 160 Product Licences representing 51 992 products. The remaining completed applications were either refused by NHPD or withdrawn by the applicant. In total, 1 817 companies have received a product licence to date.

Pre-UPLAR PLA statistics summary

Of the 10 885 PLAs and amendments received before August 5th, 2010 (pre-UPLAR PLAs) and which had not been completed prior to that date, 7 219 (66%) have now been completed. NHPD is committed to completing the remaining 3 666 applications before NHP-UPLAR is repealed in February 2013.

Post-UPLAR PLA statistics summary

Of the 18 732 applications and amendments received on and after August 5th, 2010 (post-UPLAR PLAs), 46% fully meet NHPD's pre-cleared information (60-day review target) and the remaining 54% require full assessment (180-day review target).

During Quarter 1, NHPD met performance targets as follows:

  • 30-day initial assessment: 96%
    60-day pre-cleared information: 99%
    180-day full assessment: 86%

Chart 1 - Performance targets met by the Natural Health Products Directorate Quarter 1 compared to Quarter 4

Chart 1 - Performance targets met by the Natural Health Products Directorate: Quarter 1 compared to Quarter 4
Performance target Percentage Q4 11-12 Percentage Q1 12-13
30-day initial assessment 86% 96%
60-day initial pre-cleared information 94% 99%
180-day full assessment 85% 86%

Overall site licence application statistics summary

The Natural Health Products Directorate has received 1 985 Site Licence Applications (SLAs) from January 1, 2004 to June 30, 2012. Of this total, 1 939 (98%) SLAs have been completed, including the issuance of 1 333 Site Licences. The remaining completed applications were either refused by NHPD or withdrawn by the applicant. A total of 2 526 Site Licence Renewals have been received for issued Site Licences. 98% of all Site Licence Renewals have been completed.

During Quarter 1, NHPD received 37 SLAs and 60 Site Licence Renewals and completed 48 SLAs and 89 Site Licence Renewals.

Overall clinical trial application statistics summary

From January 1, 2004 to June 30, 2012, NHPD has received 390 clinical trial applications (CTAs). Of this total, 378 (97%) CTAs have been completed, including the issuance of 322 Notices of Authorization. The remaining completed applications were either refused by NHPD or withdrawn by the applicant. A total of 336 CTA Amendments and Notifications have been received for issued Notices of Authorization. 99% of all CTA Amendments and Notifications have been completed.

During Quarter 1, NHPD received 13 CTAs and 6 CTA Amendments and completed 10 CTAs and 5 CTA amendments.

Quarter 1 (April 1, 2012 to June 30, 2012)

Highlights

2 114
NHPs licensed during Quarter 1

301
PLAs refused during Quarter 1

333
PLAs withdrawn during Quarter 1

During this quarter, a total of 2 748 Product Licence Applications (PLAs) were completed, 77% (2 114) of these completions resulted in product licences, 11% (301) were refusals and the remaining 12% (333) of completions were as a result of the applicant withdrawing the application.

Of the 301 applications refused this quarter, the reasons were as follows:

  • 41% failed to meet basic application requirements.
  • 37% were refused when applicants did not respond to a request for further information.
  • 15% were refused when the applicant's response to a request for further information did not meet the requirements.
  • 5% did not meet the definition of a NHP.
  • 2% were refused for containing an ingredient not listed in the Natural Health Products Ingredient Database (NHPID).

Unacceptable applications

Since June 2009, certain applications are returned to applicants via regular mail if they are deemed to be unacceptable for processing, as referenced in section 7.2 of NHPD's Application Management Policy. These applications are accompanied by a Rejection Notice - Administrative Deficiency. The Natural Health Products Directorate (NHPD) reports on these applications by stating the total number of unacceptable application packages and the reasons for rejection.

During this quarter, a total of 4 PLAs were deemed unacceptable and were not included in total PLA statistics.

Of the 4 applications deemed unacceptable for processing this quarter, the reasons were as follows:

  • 50% (2) missing attestation signature
  • 50% (2) third party did not have authorization to sign on behalf of a company

Quarter 1 statistics (April 1, 2012 to June 30, 2012)

Chart 2 - Total number of product licence applications received and completed during Quarter 1 compared to Quarter 4

Note - "Completed" includes all applications that were licensed, refused or withdrawn by the applicant.

Chart 2 - Total number of product licence applications received and completed during Quarter 1 compared to Quarter 4

PLAs received Q4 11-12 = 1 838
PLAs received Q1 12-13 = 1 777
PLAs completed Q4 11-12 = 3 423
PLAs completed Q1 12-13 = 2 748

Chart 3 - Total number of product licence applications completed during Quarter 1 compared to Quarter 4 (licensed, refused or withdrawn)

Chart 3 - Total number of product licence applications completed during Quarter 1 compared to Quarter 4 (licensed, refused or withdrawn)
Product licence applications (PLAs) completed (licensed, refused or withdrawn) Total number Q4 11-12 Total number Q1 12-13
PLAs licensed 2 339 2 114
PLAs refused 735 301
PLAs withdrawn 349 333

Chart 4 - Total number of product licence applications completed during Quarter 1, Pre vs. Post UPLAR (n=2 748)

Chart 4 - Total number of product licence applications completed during Quarter 1, Pre vs. Post UPLAR (n=2 748)

Total number of PLAs completed post-UPLAR 54%
Total number of PLAs completed pre-UPLAR 46%

Chart 5 - Total number of product licence applications - by application type - received and completed during Quarter 1

Note - "Completed" includes all applications that were licensed, refused or withdrawn by the applicant.

* See Appendix A for definitions of acronyms found in Chart 5.

Chart 5 - Total number of product licence applications - by application type - received and completed during Quarter 1

HM PLAs received = 66
HM PLAs completed = 122
LS PLAs received = 84
LS PLAs completed= 94
Non-trad. PLAs received = 821
Non-trad. PLAs completed= 1 463
AbLS received = 24
AbLS completed = 33
TPD CatIV LS received = 6
TPD CatIV LS completed = 18
Trad. PLAs received = 328
Trad. PLAs completed = 401
NHPs received = 3
NHPs completed = 62
PLAs received = 445
PLAs completed = 554

Chart 6 - Total number of product licence amendments received and completed during Quarter 1 compared to Quarter 4

Note - "Completed" includes all applications that were licensed, refused or withdrawn by the applicant.

Chart 6 - Total number of product licence amendments received and completed during Quarter 1 compared to Quarter 4

PLA's received Q4 11-12 = 455
PLA's received Q1 12-13 = 248
PLA's completed Q4 11-12 = 477
PLA's completed Q1 12-13 = 309

Chart 7- Total number of product licence notifications received and completed during Quarter 1 compared to Quarter 4

Chart 7- Total number of product licence notifications received and completed during Quarter 1 compared to Quarter 4

PLAs received Q4 11-12 = 387
PLAs received Q1 12-13 = 248
PLAs completed Q4 11-12 = 412
PLAs completed Q1 12-13 = 300

Chart 8 - Total number of site licence applications received and completed during Quarter 1 compared to Quarter 4

Note - "Completed" includes all applications that were licensed, refused or withdrawn by the applicant.

Chart 8 - Total number of site licence applications received and completed during Quarter 1 compared to Quarter 4

SLAs received Q4 11-12 = 47
SLAs received Q1 12-13 = 37
SLAs completed Q4 11-12 = 43
SLAs completed Q1 12-13 = 48

Chart 9 - Total number of site licence amendments, notifications and renewals received and completed during Quarter 1

Note - "Completed" includes all applications that were licensed, refused or withdrawn by the applicant.

Chart 9 - Total number of site licence amendments, notifications and renewals received and completed during Quarter 1

SL renewals received = 60
SL renewals completed = 89
SL amendments and notifications received = 94
SL amendments and notifications completed = 80

Update on product licence applications received before August 5, 2010 (pre-UPLAR)

This section provides figures on the current status of Product Licence Applications (PLAs) which were received before August 5, 2010 and not complete as of that date. All applications received after this date will be measured against the Natural Health Products Directorate's (NHPD's) performance targets (see Tables 2-5). These performance targets were communicated to applicants via the NHPD Application Management Policy. Please note these numbers also include product licence amendments.

As shown in Table 1 below, the number of applications remaining at NHPD as of August 5, 2010 was 10 885. The number remaining as of June 30, 2012 is 3 666. The objective is to complete the remaining 3 666 before NHP-UPLAR is repealed in February 2013. At the same time, NHPD will be focused on completing all applications received on or after August 5, 2010 in accordance with the performance targets communicated in the Application Management Policy.

Table 1: total product licence applications and amendments received before August 5, 2010 which were not complete as of that date
Status - product licence applications completed or in progress Number % of Total (10 885)
Licensed 4 047
Refused 1 795
Withdrawn by applicant 1 377
Total completed 7 219 66%
In Licensing - administrative processing required 36
To Be Refused - administrative processing required 0
Full Assessment in progress 1 146
With Applicant pending response to IRN 646
Total undergoing assessment 1 828 17%
In queue for Full Assessment 1 195
Total In queue for full assessment 1 195 11%
HaltedFootnote 1 pending internal decision related to safety or efficacy 641
Miscellaneous administrative issues 2
Total other 643 6%

Chart 10 - Pre-UPLAR applications not complete by application type (n = 3 666)

Chart 10 - Pre-UPLAR applications not complete by application type (n = 3 666)

Non-traditional = 59%
Traditional = 22%
Food-like NHP = 16%
Homeopathic = 3%
Non-PCI-amendment = <1%
AbLS = <1%

Chart 11 - Pre-UPLAR PLAs not complete: ability to sell (n = 3 652)

Chart 11 - Pre-UPLAR PLAs not complete: ability to sell (n = 3 652)

Received EN = 88%
Other = 12%
Other includes:

  • Not eligible for EN due to risk factor = 2%
    Opted out = 1%
    Did not apply for EN = 9%

Update on product licence applications received on or after August 5, 2010 (post-UPLAR)

This section provides figures on the current status of the Product Licence Applications (PLAs) which were received on or after August 5, 2010. All applications received after this date will be measured against the Natural Health Products Directorate's (NHPD's) performance targets. These performance targets were communicated to applicants via the NHPD Application Management Policy. Please note these numbers also include product licence amendments.

For the purposes of the performance targets, these applications are separated into two categories: those which fully meet pre-cleared information and those which require full assessment of safety, efficacy and/or quality information. Pre-cleared information includes NHPD Monographs, Labelling Standards and Abbreviated Labelling Standards. Products falling within the parameters described in these documents are subject to shorter review times. See Appendix A for the definition of pre-cleared information.

Applications fully meeting pre-cleared information (60-day review target)

The performance on these applications is outlined in Table 2 below. For these types of applications, NHPD has consistently met the 60-day performance target. Please note that this table only includes amendments supported by pre-cleared information.

Table 2: Product licence applications and amendments completed in Quarter 1 that fully meet pre-cleared information
Application type Completed % Completed within 60 days
Compendial 553 99%
Labelling standards 94 100%
Abbreviated labelling standards 26 81%
Amendments 200 99%
Total 873 99%

*Of the 101 applications still in progress, 100% were received less than 60 days ago.

Applications requiring full assessment of safety, efficacy and/or quality information (30-day review target for administrative processing and initial assessment)

For these types of applications, NHPD's objective is to perform the administrative processing and initial assessment within a 30-day timeframe as described in the Application Management Policy. This 30-day target applies only to applications and amendments received on or after August 5, 2010. At the end of the 30-day timeframe, applicants receive an Application Acceptance Letter or a Notice of Refusal - Initial Assessment. In some cases, the application may be withdrawn by the applicant during the 30-day period. The performance on these applications is outlined in Table 3 below.

This quarter, 1 117 applications, which require full assessment of safety, efficacy and/or quality information, received an Application Acceptance Letter or decision. In 96% of cases, this was completed within the 30-day target.

Table 3: Breakdown of product licence applications and amendments for which an application acceptance letter or decision was issued during Quarter
Action Count % Completed within 30 days % of Total
n=1 117
Application acceptance letter issued 1 029 97% 92%
Notice of refusal - initial assessment issued 88 91% 8%
Withdrawn by the company 14 93% N/A

*Of the 322 applications which have not yet received an Application Acceptance Letter or decision, 100% were received less than 30 days ago.

Applications which require full assessment of safety, efficacy and/or quality information (180-day review target for full assessment)

For these types of applications, NHPD's objective is to meet the 180-day review target as described in the Application Management Policy. This 180-day target applies only to applications and amendments received on or after August 5, 2010 that have been issued an Application Acceptance Letter. This quarterly report provides more detail in regards to the 180-day timeline and the percentage of applications completed within that timeline.

This quarter, NHPD completed 756 applications requiring full assessment of safety, efficacy and/or quality. In 86% of cases, this was completed within the 180-day target.

Table 4: Breakdown of PLAs and amendments which require full assessment that were completed during Quarter 1
Action Count % Completed within 180 days % of Total
n=756
Product licence issued 690 89% 91%
Notice of refusal - full assessment 66 61% 9%
Withdrawn by the Company 36 64% N/A

Currently, there are 2 535 applications which require full assessment that have been accepted and are currently in progress. 976 have exceeded 180 days. In 86% of cases (843 applications), this was as a result of a haltedFootnote 2 issue.

Table 5 outlines the status of the 7 158 PLAs received after August 5, 2010 that were issued an Application Acceptance Letter and are therefore subject to NHPD's 180-day performance target for full assessment as outlined in the Application Management Policy.

Table 5: Status of all product licence applications and amendments received after August 5, 2010 which have received an application acceptance letter
Status Number % of Total (7 158)
Licensed 3 522  
Refused 868  
Withdrawn by applicant 233  
Total completed 4 623 65%
In Licensing - administrative processing required 49  
To be refused - administrative processing required 0  
Has received at least one request for further information 714  
Full assessment in progress 1 490  
Total undergoing assessment 2 253 31%
HaltedFootnote 3 pending internal decision related to safety or efficacy 282  
Total halted 282 4%

Chart 12 - Post-UPLAR PLAs not yet complete which have received an application acceptance letter by application type (n = 2 535)

Chart 12 - Post-UPLAR PLAs not yet complete which have received an application acceptance letter by application type (n = 2 535)

Non-traditional = 73%
Traditional = 13%
Food-like NHP = 6%
Amendment = 4%
Homeopathic = 3%
TPD CatIV LS = 1%

Appendix A - acronyms and definitions

PL:
Product Licence
SL:
Site Licence
PLA:
Product Licence Application
SLA:
Site Licence Application
NHPD:
Natural Health Products Directorate
Abbreviated Labelling Standard (AbLS):
Document created by NHPD outlining information about the established safety and / or efficacy of a product or ingredient. AbLS is one type of pre-cleared information.
Amendment:
Product Licence Application proposing revisions to an existing product licence
HM PLA:
Homeopathic Medicines Product Licence Application
Labelling Standard (LS):
Document created by NHPD outlining information about the established safety and efficacy of a type of product.  LS is one type of pre-cleared information.
Non-Trad. PLA:
Non-Traditional Product Licence Application
Trad. PLA:
Traditional Product Licence Application
TPD Cat IV / Label Standard PLA:
Product Licence Application citing a Category IV Monograph or Labelling Standard from the Therapeutic Products Directorate
Compendial PLA:
Product Licence Application citing a monograph found in the NHPD's Compendium of Monographs
Application Management Policy:
The Application Management Policy outlines the way in which PLAs for natural health products are submitted in accordance with the Natural Health Products Regulations. The policy also outlines the responsibilities and expectations for natural health product applicants before and throughout the application review process. In addition, the policy outlines the proposed performance targets for the management of all types of PLAs.  This policy is available on NHPD's website and applies to all PLAs submitted after August 5, 2010.
Completed:
When NHPD issues a Product Licence, Notice of Refusal or when the applicant withdraws their application, the application is considered to be "completed".
Halted:
An application which cannot be further processed due to the need for an internal decision related to safety and/or efficacy
Initial Assessment:
An assessment of the evidence in support of safety, efficacy and quality to ensure that the requisite information for the type of application in question, as defined in the Natural Health Product Regulations and as described in various guidance documents has been submitted.

An Application Acceptance Letter is issued when the information and material submitted are deemed complete and are acceptable for full assessment.

Alternatively, if deficiencies are identified during the initial assessment, a Refusal Letter - Initial Assessment will be issued.

For applications received on or after August 5, 2010, this assessment is performed within 30 days of receipt of the application.  This assessment is performed only for applications which require full assessment of safety, efficacy and / or quality information.

Information Request Notice (IRN):
A notice sent from NHPD to an applicant requesting additional information to support the safety, efficacy or quality of a product.  As outlined in the Application Management Policy, this notice is sent during the Full Assessment stage and the applicant has 30 days to respond.  Applicants can contact the Submission Coordinator indicated on the notice with questions or clarifications.
Natural Health Products (Unprocessed Product Licence Applications) Regulations:
Also referred to as UPLAR or NHP-UPLAR.  These Regulations allow for certain products to be issued exemption numbers by Health Canada. In order to qualify, products must: have had a complete product licence application (PLA) submitted; not have been withdrawn; still be with Health Canada for a final licensing decision; and not fall within certain risk criteria. Products for which an exemption number is issued by Health Canada will be exempted from the current prohibition against sale without a product licence (as set out in s.4 of the Natural Health Products Regulations). In other words, these products can now be sold legally.  These Regulations were registered on August 4, 2010 and will be repealed 30 months following that date on February 4, 2013.
Pre-Cleared Information:
Information which has been pre-cleared by the NHPD includes NHPD Monographs, Labelling Standards and Abbreviated Labelling Standards.  These documents outline the parameters under which a product can be sold including allowable claims, dose limits and risk information required on the product label.  If a company wishes to receive a licence and their product falls within the parameters of any of these documents, the licence can be issued in 60 days.  Pre-cleared information can also be used to help support other applications types; for example, one ingredient within a multi-ingredient product may be supported by a monograph for that ingredient.
UPLAR:
See definition of Natural Health Products (Unprocessed Product Licence Applications) Regulations above.
Pre-UPLAR PLAs:
PLAs received prior to the publication of the Natural Health Products (Unprocessed Product Licence Applications) Regulations on August 5th, 2010 which were not yet complete as of that date
Post-UPLAR PLAs:
PLAs received on or after August 5th, 2010.   These applications are subject to the performance targets set out in Application Management Policy.

Footnotes

Footnote 1

Halted applications during this quarter included those containing energy drinks, NHPs in food

Return to footnote 1 referrer

Footnote 2

Halted applications during this quarter included those containing energy drinks, NHPs in food format, aromatherapy products and weight loss / weight management products. Recently unhalted issues with review underway include enzymes and probiotics.

Return to footnote 2 referrer

Footnote 3

Halted applications during this quarter included those containing energy drinks, NHPs in food format, aromatherapy products and weight loss / weight management products. Recently unhalted issues with review underway include enzymes and probiotics.

Return to footnote 3 referrer