(Updated 15 June 2023)
A) General
Valid GMP evidence that contains the following information should be submitted:
- Name of Investigational Product (IP) manufacturer
- Address of manufacturing site under inspection
- Scope of Inspection
- Dosage form covered during inspection
- Inspection date
- Conclusion of the inspection
- Validity of GMP Status
- Official Stamp of the Issuing Authority
The trial site listed under the NPRA Phase I Unit Inspection & Accreditation Programme can conduct FIH studies in Malaysia. Please refer to the link below for more information on the NPRA Phase I Unit Inspection & Accreditation Programme:
It is specified in our guideline that "For local disposal, all investigational products should be disposed by the authorised bodies/ authority and documented." Hence, the drug destruction documentation should be provided.
It is specified in our guideline that applicant is advised to contact officers from Investigational Product Evaluation and Safety Section (IPESS), Centre of Product and Cosmetic Evaluation (CPCE) to schedule for an appointment to submit the CTIL application in person.
However, applicants also can submit CTIL and/or CTX applications by following this procedure:
1. In order to submit your CTIL and/or CTX application, email Dr. Zaril Harza Zakaria at zaril@npra.gov.my
2. The appointed screening officer will contact the applicant to obtain the cloud storage link of complete screening document.
3. Once the screening is deemed satisfactory, applicant will be notified via email on the screening status and payment amount will be verified by using Lampiran A Borang Penyerahan Yuran Pemprosesan.
4. Payment process [for CTIL application only]:
i. Document required for payment process:
• Credit card/ bank draft/ money order /wang pos
• Lampiran A: Borang Penyerahan Yuran Pemprosesan
• Cover letter
ii. Payment method:
A. Payment at Unit Hasil, NPRA
• Payment can be made using credit card/ bank draft/ money order/ wang pos physically at the Unit Hasil’s counter Monday to Friday (except on Public Holiday) from 8.00 am to 5.00 pm.
B. Payment by post
• Bank draft/ money order/ wang pos shall be posted to the following address:
Unit Hasil,
Bahagian Regulatori Farmasi Negara
Lot 36, Jalan Universiti
46200 Petaling Jaya
Selangor
[Note: Please ensure you get a copy of the receipt for proof of payment]
5. Once payment has been made, submit a copy of the official receipt together with the full dossier to the following address.
U/P: Name of Screening Officer
Seksyen Penilaian dan Keselamatan Produk Kajian,
Bahagian Regulatori Farmasi Negara
Lot 36, Jalan Universiti
46200 Petaling Jaya
Selangor
6. Upon acceptance, Lampiran C1: Pengesahan Penerimaan Permohonan Lesen Import Percubaan Klinikal for CTIL applications/ Lampiran B: Pengesahan Penerimaan Permohonan Kebenaran Mengilang Produk Tidak Berdaftar untuk Tujuan Percubaan Klinikal will be provided to applicant.
7. For CTX application, the submission can be done via courier.
B) Managing Trials during Covid-19 in Malaysia
Effective from 1st April 2023, to streamline with the amendment on the requirements for Conditional Registration of Pharmaceutical Products During Disaster dated 20th June 2022 (Section 5b: Eligibility Conditions), for Investigational Products (IP) in COVID-19 Trials with the following characteristics can be considered for Fast Track Reviews:
Therapeutic product with new active ingredient(s) and a different mechanism of action or a new vaccine with a different platform that has not been registered in Malaysia (either via full registration or via conditional registration). In addition, the said product should have as good as or compelling efficacy and/or safety profiles compared to current existing registered products.
C) Investigational Product (IP) Direct to Patients (DTP)
However, there is another option in which you can apply for exemption under Regulation 15(6) Control of Drugs and Cosmetics Regulation 1984, an exemption to import unregistered products for life-threatening diseases under Pharmacy Enforcement Division.
You can also contact the following officers in the Pharmacy Enforcement Division for further information:
1. Pn Astrina Bt Abdul Salam (astrina@moh.gov.my) – Legislation Branch
2. Pn Nursyila Roziana Binti Mohd Radzi (nursyila@moh.gov.my) – Licensing Branch
Below are additional comments from Good Clinical Practice (GCP) and Good Laboratory Practice (GLP) Section for further consideration:
NPRA recognise that the supply of IP to trial subjects may be disrupted during COVID-19 crisis due to quarantine, travel limitation, cancellation on the site visits or other considerations if site personnel or trial subjects become infected with COVID-19.
• Sponsor has a valid Clinical Trial Import License (CTIL) / Clinical Trial Exemption (CTX) with an approved import quantity.
• Sponsor shall only distribute the IP on Malaysian sites to trial subjects.
• The direct-to-patient (DTP) delivery of IP shall not raise any new safety risks.
• Sponsor shall ensure the conduct of appropriate alternative safety monitoring specifically if trial participants are not be able to come to the investigational site.
• Prior to direct distribution to the subject, sponsor should investigate the viability of the distribution via investigator or hospital pharmacy.
• If courier service is used. The sponsor need to ensure that the shortest route of transportation used during transportation and storage requirements are met. These have to be documented.
• Sponsor has to ensure that the standard operation procedure (SOP) is in place for delivery of IP to trial subject or their relative. In other words, the sponsor need to deliver the IP to the subject personally and not deliver to neighbor or placed outside the door. In addition, sponsor need to ensure the subject received adequate training for self-administration of the investigational product. All of these have to be documented.
• Sponsor is required to ensure that the subject will store the IP in a suitable way.
• Dispatch of the IP to the subject has to be done after agreement with the investigator and on the basis of the investigator prescription. Procedure for accountability must be in place.
• Sponsor may not store the personal data of the trial subject for a longer period than is required for the purpose of dispatching the medicine to the subject. Sponsor may only authorise a limited number of employees to process the personal data in order to dispatch the medicine. This has to be documented.
• Sponsor must ensure that trial subjects understand and provide consent that the trial medicine will be delivered directly to their homes.