By Dr. Niels Buch Leander
ISO IDMP is the next wave in the pharmaco vigilance legislation after xEVMPD. But with a global scope and requiring data integration from the entire company it is a much bigger wave. In 2012, the five ISO standards referred to as “ISO IDMP” were approved. Their purpose is to standardise the identification of medicinal products, ultimately leading to improved pharmacovigilance across products, companies and jurisdictions.
2019 is by no means far away when planning to be compliant with ISO IDMP. Although the implementation guides and messaging stand- ards for ISO IDMP are still to be seen, one thing is clear already: Being globally compliant with the ISO IDMP standards will require more than just an isolated solution. On the contrary, the entire IT landscape across the different divisions in the pharmaceutical company will have to be considered, and integration will have to be planned. Your IT strategy should plan for this already now.
Any change in a regulated company is naturally a challenge. In the case of ISO IDMP the chal- lenge is even greater. First of all, because the regulators’ plans are not entirely clear, and even when the implementation plans become avail- able, much will rely not just on the overall ICH guidance, but on regional guidance that can be difficult to track and maintain. With parallel regional implementations of differing scope and timelines, it will be a challenge alone to manage the portfolio of ISO IDMP implementations. Moreover, the breadth of data contributors to the IDMP product information is overwhelming, from Regulatory Affairs to Pharmacovigilance to Clinical Trials, Marketing and Product Supply. Finally, the data source may not be ready.
For instance, much product information is stored in documents, and this information needs to be made available as data that can be managed and submitted. In conclusion, the challenge of ISO IDMP is on an entirely different scale from xEVMPD, and it will be necessary to look simulta- neously at the data process and data accessibility as well as at the IT landscape that should be prepared to deal with this daunting data task.
Although ISO IDMP is first and foremost a regulatory challenge, an early start will allow a company to identify the opportunities that also arise when the data landscape is being analysed and transformed. In other words, it is a good time to plan for a strategic solution to ISO IDMP. In fact, due to their global scope, the ISO IDMP standards can be treated as an extensive and consistent data model for the entire IT land- scape. One advantage is for instance that ISO IDMP offers vocabularies that are maintained externally and not in the company alone. Using a data model may yield a number of benefits as systems are streamlined against each other with the opportunity to automate integration.
By using the ISO IDMP standards as the com- pany’s data model, the company can build a data warehouse with data stemming from various company repositories. In this way, there is one authoritative repository for the product information, which can then be used both inside the company and submitted externally to the authorities. This means that existing applications may be retained, and yet it offers the opportu- nity to establish integration points that can eliminate double data entry. Moreover, a data warehouse offers reporting and business intel- ligence opportunities that have hitherto not been possible in the Regulatory Affairs IT landscape. For instance, future regulatory requirements may be met by simply changing the reporting requirements rather than having first to locate and make data accessible from various sources before setting up a new report or application. Also, the data in the central data warehouse will enable KPI monitoring of the entire value chain in a regulatory change, from change request to batch release.
The time is right for starting strategic considera- tions of the ISO IDMP data flow in your company. ISO IDMP is part of legislation and will come into effect, even if the precise implemen- tation scope may still shift. Therefore, it is important that you have analysed the aspects that will be important in an integrative and well-defined solution to ISO IDMP.For an initial ISO IDMP analysis, NNIT suggests four parallel streams:
With a solid analysis of the challenges as well as the opportunities that lie ahead, it is possible to design and build the solution that both makes ISO IDMP compliance possible and prepares Regulatory Affairs IT for having complete insight into the regulatory activities, with the opportunity of eliminating administrative bottlenecks and meeting future regulatory requirements with a solid data management approach.