OnCo
ideasIdea

Manufacturing-change passport: one approved CMC change accepted everywhere in 30 days

Changing how a cancer drug is made must be approved separately in over a hundred countries, which takes years and causes shortages. One approval should count for all.

Post-approval chemistry, manufacturing and controls changes (new site, new supplier, process improvement) take three to five years to be approved worldwide because each country reviews them separately; manufacturers therefore delay improvements and keep obsolete processes running. ICH Q12 provides tools for managed change but adoption is uneven. The proposal is a reliance passport: a CMC change approved by any WHO-listed authority is deemed approved by participating regulators 30 days after notification unless they object with reasons.

Hypothesis
Passport adoption cuts the time to global implementation of a CMC change for oncology medicines from a median above three years to under six months, and reduces the number of oncology drug shortages attributed to manufacturing changes.
Rationale
CMC changes are assessed against the same pharmacopoeial and comparability standards everywhere; duplicate review adds time but not safety. Shortages of platinum chemotherapy in 2023 were prolonged by the inability to switch or add sites quickly.
What would test it
Pilot among Access Consortium and Orbis members on 50 CMC changes for oncology products; measure time to global implementation and any post-change quality defects against matched historical changes.
Maturity
early clinical
Who has to act
regulator
Cost to try
Small (under $1M)
Years to first evidence
3
Bottlenecks it attacks

Connected

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