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Standard Operating Procedure (SOP) #4: Completion of the Guidance Document Template

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Standard Operating Procedure
TPD SOP Template WP Version 1: Effective Date 2006-04-01
Title
Completion of the Guidance Document Template
Doc. Number
GGP SOP #4
Version
2.0
Bureau / Office / Area
Good Guidance Practices WG
Status
Final
Effective Date
August 2007
Approved for external consultation by
TPD Management Committee
BGTD Management Committee
Date
July 27, 2007 (TPD-MC)
August 1, 2007 (BGTD-MC)

Table of Contents

1. Purpose

The purpose of this procedure is to provide additional information (including examples) to assist with the drafting of a guidance document. It provides explanations, definitions and examples for the various sections of the guidance document template.

2. Scope

This procedure applies to all Therapeutic Products Directorate (TPD) and Biologics and Genetic Therapies Directorate (BGTD) staff responsible for drafting a guidance document. It should be read in conjunction with Standard Operating Procedure (SOP) #1 (Issue Analysis in TPD/BGTD) and SOP #2 (Guidance Development in TPD/BGTD).

This procedure should also be read in conjunction with the GGP Style Guide (Chapter 6 of the GGP Manual).

3. Definitions

Definitions applicable to the guidance development process are outlined in Chapter 2 of the GGP Manual.

4. Responsibilities

The Project Lead (with the input of a Working Group if one is formed) bears primary responsibility for drafting the guidance document in accordance with the guidance template. Additional roles and responsibilities for those involved in the issue analysis and guidance development processes are outlined in Chapter 3 of the GGP Manual.

5. Instructions

*Note that examples provided within this procedure are samples only and may not accurately reflect a published Health Canada guidance document.

The draft guidance document template should be used for draft documents being published for consultation. The final guidance document template should be used for final documents being published for implementation.

Cover Page

The "Guidance Document" title should remain (preceded by DRAFT in the draft guidance document template). Underneath, include the title of the guidance document. For draft guidance documents, the draft date should be included on the document and updated as the document is revised.

For draft documents, the Approval Date should be included. For final documents, the Date Adopted and the Effective Date should both be given.

For revised documents, the original Date Adopted should remain; a Revised Date should be added once Directorate (pl.) management approval is given for the adoption of the revised guidance document.

Foreword

This section should not be changed. The headers and footers should be modified to include the guidance document name and relevant dates (draft date, date adopted, effective date, revised date, etc.). There should be two headers and two footers (included in the template), which alternate even/odd pages; note that the Publications Unit (TPD) or Website Coordinator (BGTD) will include (or correct) these as part of their quality check before the document is posted.

Document Change Log

This section should only be included for revised guidance documents; otherwise click on Edit, Select Page and delete. An overview of the significant changes made to the guidance document should also be described in the accompanying Notice to Stakeholders.

Table of Contents

This section should include all major sections of the guidance document, as well as any appendices.

Section 1: Introduction

Section 1.1: Policy Objectives

Policy objectives outline clearly and concisely what the government is seeking to achieve, i.e. the larger aim or goal. They should be linked both to the relevant Acts and Regulations, and to Health Canada's objectives. This is not a statement of the purpose of the document.

Policy objectives should explain how to resolve the issue identified. Policy objectives should be stated in the infinitive, i.e. "To ensure...."

Policy objectives must be included within every guidance document and are developed as part of the issue analysis process. Depending on the nature of the issue, they may be developed and consulted upon separately from the guidance for implementation (operational details).

Example 1: {Pharmaceutical Quality of Nasal and Inhalation Products}
Issue: Sponsors of inhalation and nasal product submissions are not aware of the data required to satisfy the Food and Drug Regulations.

Policy Objective: "To ensure sponsors of inhalation and nasal product submissions have the information necessary to comply with Sections C.08.002(2) or C.08.002.1(2) of the Food and Drug Regulations."

 

Example 2: {Notice of Compliance with Conditions}
Issue: Patients suffering from life-threatening diseases are waiting too long for access to promising new drugs.

Policy Objective: "To ensure patients suffering from serious, life-threatening or severely debilitating diseases or conditions have earlier access to promising new drugs."

Section 1.2: Policy Statements

Policy Statements specify the policy (or position) that will achieve the policy objectives, and general principles to guide decisions on the issue. The policy statements will serve as the underpinning for the remaining text of the document, i.e. the guidance for implementation, which will describe how the policy statements will be applied.

The Policy Statements Section is not a mandatory component of every guidance document. The Project Lead (with the input of a Working Group if one is formed) should assess whether it is feasible to draft clear, concise statements describing the general principles of the document. Policy statements will usually be more appropriate for guidance documents that are process-related or broader in scope, and may be less appropriate for detailed scientific guidance documents.

Policy statements are developed (along with policy objectives) as part of the issue analysis process. Depending on the nature of the issue, policy objectives and statements may be developed and consulted upon separately from the guidance for implementation (operational details).

Example 1: {Reconsideration of Final Decisions Issued for Human Drug Submissions}
The Reconsideration process is a formal dispute resolution process and is intended to be initiated when informal mechanisms have failed to resolve the issue(s).

The Directorates will make every effort to expedite those processes and steps that are within their control; in addition, the sponsor may request that an expedited process be followed as outlined in Section 5.3.1(c).

If, at any time during the Reconsideration process, the sponsor files a Notice of Application to the Federal Court to resolve the matter, the Directorate will terminate the Reconsideration process.

Following the issuance of a final decision (Section 5.1), sponsors may file a Request for Reconsideration. A Letter of Intent must be filed within 30 calendar days of the date of the final decision under dispute, clearly stating the sponsor's intention to commence the Reconsideration process (Section 5.1.1).

Within 45 calendar days of the date of the acknowledgement of the Letter of Intent, the sponsor must submit a Request for Reconsideration to the Director General of the appropriate Directorate (Section 5.1.2). The Request for Reconsideration should be a brief, high-level summary of the issue(s) in dispute, and should not introduce new issues (Section 5.2).

The information filed will be assessed for relevance to the issue(s) under dispute. The Reconsideration process is not an opportunity to add to the content of the original submission, or to circumvent established processes for refiling submissions. As such, new studies will not be accepted as part of the Request for Reconsideration (Section 5.2.1).

The sponsor and the review bureau/centre will have the opportunity to present their positions on the issues under dispute to the Director General, who will make the Reconsideration decision. To assist with the resolution of a Request for Reconsideration, the Directorate may refer one or more issues under dispute to an external panel for advice (either an existing Scientific Advisory Committee or a Reconsideration Panel). Other issues may not be appropriate for referral to an external panel and may be reviewed internally (Section 5.3).

The Reconsideration decision will be issued by the Director General. For each issue under dispute, the Director General may uphold or amend his/her original position, or refer the issue back to the review bureau/centre for re-evaluation and preparation of a new decision letter reflecting the re-evaluation of the issue under dispute (Section 5.3.4).

Reconsideration decisions will be disseminated externally via a Summary Basis of Reconsideration Decision to be posted on the Health Canada web site. The document will be a factual document summarizing the Directorate's position on a particular issue, and will not contain proprietary or identifying information about the drug or the sponsor (Section 5.7).

 

Example 2: {Draft Antiseptic Hand and Skin Disinfectants}
Each submission for market authorization should include replicate studies demonstrating the spectrum of claimed antimicrobial activity of the final formulation under the conditions of use recommended in the labelling.

The product should meet specific efficacy criteria, as outlined in the description of each standard method.

Dermal absorption of the submitted products should be assessed in order to determine the extent of safety data that may also be required before market authorization can be granted.

Work in the test laboratory should be performed in accordance with an appropriate Quality Assurance System.

Test protocols should be followed and any departures from the specified protocol should be documented and justified.

Section 1.3: Scope and Application

Each guidance document must include a Scope and Application section, which will describe the applicability of the guidance document. For example, a guidance document may apply to all stakeholders, to staff and stakeholders, or to specific stakeholders (e.g. manufacturers of Class IV medical devices). It may also be applicable to certain types of products, therapeutic classes, submissions/applications, or decisions.

If the guidance document supercedes an earlier document (policy, guidance, Information Letter, Notice, etc.), the following statement should be included: "This guidance document supercedes the Health Canada <policy, guidance, etc.>: <Title of superceded document>, which came into effect <effective date of superceded document>.

Example 1:
"This guidance document applies to all sponsors of human drug submissions, and to all TPD and BGTD staff involved in the drug submission process."

 

Example 2:
"This guidance document applies to disputes arising between Health Canada and sponsors over final decisions (excluding those related to cost recovery) issued for one of the following drug submission types: <list of submission types>"
Section 1.4: Background

The guidance document may include a Background section, which will describe the history of this issue, including the triggers for the analysis and development of the guidance document. It should briefly describe the issue analysis process that resulted in the drafting of the guidance document. If the document is being revised, it may describe (at a high level) the major revisions made and the supporting rationale.

Note that if the guidance document is accompanied by an Issue Analysis Summary (IAS), the IAS will likely capture this information and this section likely will not be as detailed. In this situation it may be helpful to include a reference to the IAS in this section.

Section 2: Guidance for Implementation

The guidance for implementation section describes the operational details regarding the implementation of policy objectives and policy statements, for example, a process to be followed by a sponsor, submission requirements, performance targets, etc.

The Guidance for Implementation section should be included in every final guidance document published. Depending on the nature of the issue, a guidance document may be published for early consultation without this section (i.e. with just Policy Objectives, Policy Statements, and Scope and Application sections) - this would most frequently occur when the subject of the document was a significant new approach to TPD or BGTD business (e.g. probationary licensing, priority review, etc.).

Sub-sections within this section will vary depending on the nature of the issue and the guidance document being developed. Some examples follow; however, for most situations this section will need to be tailored to meet the needs of the issue at hand.

Note that a section on Roles and Responsibilities (likely Section 2.1) may be included in the guidance document, and should outline the roles and responsibilities of each of the key players (internal and external to the Directorate(s)) within the guidance document. This section will likely be more applicable for process-related documents than for very detailed scientific documents.

Project Leads should refer to recent documents posted on the TPD and BGTD websites for examples that may be relevant to the guidance document under development.

Example 1: Process-related guidance documents:
Process-related documents will likely have Section 2 divided by significant process step. For example:

  • 2.1 Roles & Responsibilities
  • 2.2 Filing of the Request for Reconsideration
  • 2.3 Format and Content of the Request for Reconsideration
  • 2.4 Review of the Request for Reconsideration
  • 2.5 Decision by the Director General
  • 2.6 Follow-Up Action
  • 2.7 Dissemination of the Reconsideration Decision: Internally
  • 2.8 Dissemination of the Reconsideration Decision: Externally

 

Example 2: Guidance documents re: submission/application requirements:
Detailed guidance documents related to submission/application requirements may be divided according to the submission/application format.

For example, for drugs the guidance document may be divided by section of the Common Technical Document submission format, or by steps in the drug development process. It may also be divided according to safety testing, clinical testing and labelling.

Medical device guidance documents related to application requirements may be divided as follows:

  • 2.1 Device Description
  • 2.2 Pre-clinical Bench Testing
  • 2.3 In vivo Studies
  • 2.4 Clinical Studies
  • 2.5 Process Validation
  • 2.6 Packaging Testing
  • 2.7 Quality System Certification
  • 2.8 Labelling
Appendices

An appendix contains detailed or technical information that is supplementary to the main text of a publication. Material properly relegated to an appendix includes explanations and elaborations that are not essential to the text but would be helpful to a reader seeking further clarification. This includes documents illustrating the text, long lists, official meeting minutes, or charts or tables.

The usual practice is to label a series of appendices by letter (Appendix A, B, C, etc.) if the information is not essential to the reader's understanding of the main text, and by upper-case Roman numeral (Appendix I, II, III, etc.) if the information is essential. Each appendix should be given a title and should be included in the Table of Contents.

Templates and Forms should not be appended to a guidance document; rather, they should be posted separately so that they can more easily be revised or updated.

Examples:
Examples of appendices could include a Glossary, List of Abbreviations, References, Process Map, Performance Targets, Detailed Test Methodology, Excerpts from Legislation or Regulations, Region-Specific Information (appended to an internationally developed guidance document), etc.

6. Reference Documents

6.1 References

GGP SOP #1:Issue Analysis in TPD/BGTD
GGP SOP #2: Guidance Development in TPD/BGTD

6.2 Templates

The following templates are located in Chapter 5 of the GGP Manual:

  • Draft Guidance Document
  • Final Guidance Document
  • Notice to Stakeholders

Additional templates may be needed and are identified in the Reference SOPs.

7. Authors

TPD & BGTD Good Guidance Practices Working Group

8. Document Revision History

Version Change Made Effective
Date
1 Initial issuance of document for internal consultation September 2005
1.1 Revisions after internal consultation. April 2006
1.2 Revisions after DMC discussion. Issuance for external consultation May 2006
2.0 Final version posted. August 2007