原料药 DMF分开还是不分开（指南建议）

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Proposed common criteria for issuing a new ASMF - PDF (Version 1.0)
Criteria for when a Separate ASMF/DMF should be Submitted

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这是一份PMDA代表IGDRP做的一份关于ASMF/DMF frameworks and procedures of IGDRP members的差距分析。
SIMILARITIES AND DIFFERENCES OF INTERNATIONAL PRACTICES AND PROCEDURES FOR THE REGULATION FOR ACTIVE SUBSTANCE MASTER FILES/DRUG MASTER FILES OF HUMAN USE: MOVING TOWARD REGULATORY CONVERGENCE(2016)

Maki Matsuhama1, Tomoko Takishita1, Ryosuke Kuribayashi1, Kazunori Takagi1, Rika Wakao1, Kenichi Mikami1

1Office of Generic Drugs, Pharmaceuticals and Medical Devices Agency, Tokyo, Japan

ABSTRACT

Purpose. A gap analysis survey of international practices for Active Substance Master Files (ASMFs)/Drug Master Files (DMFs) of human use was conducted as a project of the ASMF/DMF working group of the International Generic Drug Regulators Pilot (IGDRP) to identify similarities and differences among ASMF/DMF procedures of 10 IGDRP members and 2 observers.

Methods. We conducted a questionnaire survey and compared the following aspects: overall ASMF/DMF procedures, submission requirements for ASMFs/DMFs, assessment processes for ASMFs/DMFs, the technical requirements for active pharmaceutical ingredients (APIs), generation of assessment reports for ASMFs/DMFs, procedures for changing ASMF/DMF details, and Good Manufacturing Practice (GMP) inspection/certification of API manufacturers. Twelve organizations participated in this project: the Brazilian Health Surveillance Agency (Anvisa), the European Union (EU), Health Canada (HC), the Singapore Health Sciences Authority (HSA), the South African Medicines Control Council (MCC), the South Korean Ministry of Food and Drug Safety (MFDS), the Japanese Pharmaceuticals and Medical Devices Agency (PMDA), the Swiss Agency for Therapeutic Products (Swissmedic), the Taiwan Food and Drug Administration (TFDA), the Australian Therapeutic Goods Administration (TGA), the European Directorate for the Quality of Medicines & HealthCare (EDQM) (Observer) and the Prequalification Team (PQT) of the World Health Organization (WHO), which includes the PQT–Medicines (Observer).

Results. Although there were many similarities among the participating agencies surveyed, there were also differences that should be discussed such as assessment processes of ASMFs/DMFs and Technical requirements for APIs.

Conclusions. These differences revealed by this survey will be key considerations in order to facilitate the filing of ASMFs/DMFs globally and to establish a framework for sharing and utilizing information related to ASMFs/DMFs among IGDRP members in the future.

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MARK一下：
Drug Master Files: Requirements and Challenges（2009)