Standard Operating Procedure for Pre-Submission Meeting with Regulatory Authorities in BA/BE Studies
| Department | BA-BE Studies |
|---|---|
| SOP No. | SOP/BA-BE/020/2025 |
| Supersedes | SOP/BA-BE/020/2022 |
| Page No. | Page 1 of 12 |
| Issue Date | 17/04/2025 |
| Effective Date | 20/04/2025 |
| Review Date | 17/04/2026 |
1. Purpose
To define a structured procedure for initiating, planning, conducting, and documenting pre-submission meetings with regulatory authorities (e.g., CDSCO, USFDA, EMA) prior to submitting Bioavailability/Bioequivalence (BA/BE) study applications or dossiers.
2. Scope
This SOP applies to Regulatory Affairs, Clinical Development, and R&D personnel involved in interactions with regulatory agencies for scientific advice, clarification on study
3. Responsibilities
- Regulatory Affairs: Initiates the meeting request, coordinates preparation of briefing documents, and manages communication with regulatory bodies.
- Clinical & Bioanalytical Teams: Provide technical input and clarification on the proposed study design and methodology.
- Medical Affairs: Participates in the meeting and provides clinical rationale and justifications.
- Documentation Lead: Records minutes and circulates post-meeting action points.
4. Accountability
The Director – Regulatory Affairs is accountable for ensuring that pre-submission meetings are conducted with appropriate preparation, alignment, and documentation to support the BA/BE submission strategy.
5. Procedure
5.1 Meeting Request Initiation
- Identify the need for a meeting based on:
- Complex study design
- Need for waivers
- Ambiguities in product-specific guidance
- Uncertainty in local regulatory requirements
- Submit formal request per agency guidelines:
- CDSCO: Submit request via SUGAM portal
- USFDA: Use Type B meeting request format
- EMA: Submit scientific advice request through IRIS portal
- Log request in Annexure-1: Meeting Request Log.
5.2 Preparation of Briefing Package
- Compile briefing package containing:
- Study background and objective
- Proposed study design and rationale
- Questions for agency (categorized as clinical, analytical, regulatory)
- Data to support the request
- Submit briefing document at least 2–4 weeks prior to scheduled meeting date.
- Maintain version-controlled copy in eTMF and Annexure-2: Briefing Document Tracker.
5.3 Internal Pre-Meeting Preparation
- Schedule internal mock meeting with stakeholders.
- Assign speaking roles and prepare backup responses to anticipated questions.
- Share finalized presentation materials with participants in advance.
5.4 Conduct of Meeting
- Attend the meeting as scheduled (physical/virtual).
- Ensure that:
- Designated spokesperson addresses questions
- Discussion is focused and professional
- All attendees sign attendance record (Annexure-3)
5.5 Post-Meeting Activities
- Prepare draft meeting minutes within 3 business days.
- Circulate for internal review and submit to agency for confirmation if required.
- Log action items in Annexure-4: Regulatory Advice Action Tracker.
- Update protocol and regulatory strategy as needed based on discussion outcomes.
6. Abbreviations
- BA: Bioavailability
- BE: Bioequivalence
- CDSCO: Central Drugs Standard Control Organization
- EMA: European Medicines Agency
- eTMF: Electronic Trial Master File
7. Documents
- Meeting Request Log – Annexure-1
- Briefing Document Tracker – Annexure-2
- Meeting Attendance Record – Annexure-3
- Regulatory Advice Action Tracker – Annexure-4
8. References
- USFDA Guidance on Formal Meetings with Sponsors
- EMA Scientific Advice and Protocol Assistance Guidelines
- CDSCO Handbook for Applicants – SUGAM Portal
9. SOP Version
Version: 2.0
10. Approval Section
| Prepared By | Checked By | Approved By | |
|---|---|---|---|
| Signature | |||
| Date | |||
| Name | |||
| Designation | |||
| Department |
11. Annexures
Annexure-1: Meeting Request Log
| Date | Agency | Request Type | Status | Requested By |
|---|---|---|---|---|
| 01/04/2025 | CDSCO | Scientific Advice | Accepted | Rajesh Kumar |
Annexure-2: Briefing Document Tracker
| Version | Date | Prepared By | Reviewed By | Status |
|---|---|---|---|---|
| V1.0 | 03/04/2025 | Sunita Reddy | QA | Submitted |
Annexure-3: Meeting Attendance Record
| Name | Designation | Department | Signature |
|---|---|---|---|
| Dr. Aarti Deshmukh | Regulatory Manager | Regulatory Affairs |
Annexure-4: Regulatory Advice Action Tracker
| Date | Advice Given | Follow-Up Action | Status |
|---|---|---|---|
| 06/04/2025 | Clarify PK sampling duration | Updated protocol V2.1 | Completed |
Revision History:
| Revision Date | Revision No. | Details | Reason | Approved By |
|---|---|---|---|---|
| 15/01/2022 | 1.0 | Initial Release | New SOP | QA Head |
| 17/04/2025 | 2.0 | Added Annexures and clarified IRIS/SUGAM submission flows | Regulatory Alignment | QA Head |