From: Regulatory framework in Pakistan: situation analysis of medicine quality and future recommendations
Parameter | Pre DRAP status | Current status under DRAP |
---|---|---|
Name | Drug Control Organization | Drug Regulatory Authority |
Established | 1976 | 2012 |
Administrative status | Under MoH | Autonomous (financial, technically and administrative) |
Human resource (Total No. of technical staff) | 36 | 185 technical personnel, including predominantly pharmacists, pharmacologists, physicians, chemists, and microbiologists |
Financial system | Dependent on MoH for budgetary allocation and funding | Self-sustained system with minimal dependence on the external funding through federal government resulting in a stronger independent position and autonomous structure |
Organizational structure | • Two divisions including premises licensing, Quality Assurance, and drug registration (market authorization) • Two drug controllers reporting to Director | • 13 divisions, five thereof related to non-technical areas • Financial and administrative autonomy with secretary health as chair to policy board and Chief Executive Officer of DRAP as secretary policy board |
Infrastructure | • Four provincial offices run by deputy director general, (DDGs), Federal Drugs inspectors (FIDs), and Assistant Drug Controllers (ADC) • Limited staff and authorities with most of the decisions referred back to central offices in Islamabad • Other infrastructure includes two central Drug testing Laboratories (DTLs) and a National Biological Control Laboratory • A Federal Drug Surveillance Laboratory (FSDSL) was shifted to health ministry outside the sphere DCO earlier to the establishment of DRAP | • The current provincial offices are run under additional directors with the team of twenty-five FIDs, Assistant Director Quality Assurance, and Deputy Director Quality Assurance • A higher number of technical staff with more autonomy and powers results in swift decision making • Provincial level issuance of import/export permissions, API/raw material import, sampling, inspection • assistance in customs release • With respect to working CDL has shifted to full compendial testing with the exception of a few tests including impurity testing • FDSL is reverted to its status as component of DRAP and now steps are being taken for its functional role. |
Market authorization procedures | • Drug registration applications were placed in a meeting of the product registration board without any structured evaluation procedure (e.g. at times, the agenda distribution used to take place merely an hour before the meeting) | • All applications are submitted as Common technical Document (CTD) as per internationally accepted format which are subjected to a comprehensive evaluation and review procedure [40, 41] implemented through a discrete evaluation cell • Facilitation of USP-PQM in capacity building |
Capacity building opportunities and their outcome and liaison with international agencies | • No formal liaison with international agencies was established. | • Hands-on support by the United States Pharmacopoeia (USP) and USAID since inception of DRAP • The liaison was a driver to implementation of CTDs [40, 41], GMP standards, Quality Management Systems (QMS), membership to Pharmaceutical Inspection Corporation Scheme (PICS), pharmacovigilance and achieving of global bench marking (GBM) • Two phases of QMS have already been completed by the end of 2017 [42] |
PV status with respect to International Drug Monitoring | No status | Observer status to full Member |
WHO’s National Regulatory System Global benchmarking Tool (GBT) grading on Maturity Level (ML) 1–4 [43] | No assessment | • Maturity Level status with “Reactive approach” was documented in the initial assessment done in 2014 which was shifted to “Proactive approach” in the second assessment (2017) • A third assessment is planned in 2019 for attainment of Maturity Level 3 (Stable Formal System approach) compliance certification [44] • NRAs with ML3 and ML4 compliance status are regarded as WHO listed authorities (WLAs) [43] |
CRF liquidation and research initiatives | Only a meagre amount has been used and no concrete research priorities, policies or plans were present | The area is still unaddressed |