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COMPANY CORE DATA SHEET (CCDS) SERVICES |
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BACKGROUND |
A Company Core Data Sheet (CCDS) is a company-internal global reference labeling document used to direct the content of local (affiliate) labeling. The CCDS may also be used as an attachment to a Periodic Safety Update Report (PSUR); in this context, all the safety information in a CCDS ("Company Core Safety Information" or "CCSI"), or a specifically identified (e.g. by bold print) subset of this safety information, serves as reference information for determining "listedness".
A CCDS may be created for a new product, to be available at the time of a first submission of local labeling in a first market, or at any later point in a product's life cycle. Ideally, a CCDS is already available at the beginning of the first PSUR period for the second market that requires a PSUR.
The type and depth of information in a CCDS depends on how "active" the product is. The content of a CCDS written for a "mature, stable" product (no new indications or uses planned to be added) may be limited to CCSI, accompanied by a brief description of the product's uses as necessary to interpret the CCSI.
A CCDS for a new, active product may contain all information that most local affiliates might need to draft local labeling.
The CIOMS III/V and VI guidelines describe some general criteria for including safety information in a CCDS/CCSI. However, labeling regulations, guidelines and expectations have significantly changed and become more specific since the CIOMS III and III/V reports were published. Taking these developments into account is crucial from a regulatory and legal/litigation point of view. Equally important for the regulatory viability and defensibility of CCDS and CCSI content and for labeling harmonization are carefully drafted and effective rationales and supporting documentation.
Our unique experience in the field of labeling, and Core labeling in particular, makes QeL the ideal resource for companies that create or revise CCDS and CCSI and harmonize local safety labeling.
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PROCESS OF CREATING A CCDS/CCSI FOR A STABLE, MARKETED PRODUCT |
The process of creating a CCDS/CCSI for a marketed product typically begins with a comparative analysis of the content of local labels. Based on English language label texts provided by the Client, QeL prepares a labeling comparison table that highlights labeling similarities and differences. Following a telephone conference in which we explain selected findings and decision options, the Client then evaluates information that is present in all labels as well as information that is missing in some labels, to determine which elements deserve to be included in the CCDS/CCSI.
In this context, QeL provides the Client with guidance on the type and depth of supporting rationales and documentation needed for CCDS/CCSI elements that are not yet present in all local labels and require regulatory submission in one or several markets.
Based on Client feedback QeL drafts a document that, after further Client review, evolves into the final draft CCDS for approval by the Client's labeling committee. Upon request, QeL provides its CCDS template to the Client. This template (accompanied by instructions for CCDS authors and affiliate staff) reduces the implementation difficulties and workload that could result from a CCDS structure that, for example, mimics the EU SPC structure and conventions.
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SERVICE COMPONENTS |