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Phytopharmaceutical Drugs and GMP

Prof. Ramesh K. Goyal, Ph.D.

F.I.C., FICN., FIPS, FAMS, FIACS, FNASc., FSCH

(Former Vice Chancellor, The M. S. University of Baroda)

Vice Chancellor

Delhi Pharmaceutical Sciences & Research University

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Changes in Practice of Medicine & IRs

Empirical

Herbals

&

Minerals

Before 1900 1900s-1970s 1970s–2000s 2000– 2020

1st IR 2nd IR 3rd IR 4th IR

Chemicals

&

Biochemicals

Industrial Production

Genome

Health ATMs

Nanotech based

Biomarker Based DD

Biotechnology

Biologicals

Immunological

Systematic Drug Discovery

Availability of Medicines

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Modern Vs. Herbal Drugs

  • Mostly single entity with structure known,
  • Rigorously tested
  • Meeting Regulatory requirements (Whose?)
  • Clinical trials done
  • Toxicity tests cleared then Why Pharmacovigilance?

[ 4th-6th largest cause of death in US ].

  • Many times Number of active entities is not known,
  • Time Tested?
  • Safety & efficacy based on experiences of practitioners
  • Used by large population
  • MOA many times unknown.

Why 4th IR cannot be used to promote Ancient Systems of Medicine?

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System Practiced Since

Ayurveda 6000 B.C.

Chinese herbals 5000 B.C.

Egyptian medicine 1600 B.C.

Chinese Yin Dynasty 1500 B.C.

Greek medicine 500 B.C.

Roman medicine 200 B.C.

Unani Tibb 1400 A.D.

Homoeopathy 1800 A.D.

Allopathy medicine 1800 A.D.

Asia & Evolution of Different

Systems of Medicine

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Digitalis Discovered Over 2 Centuries Ago

An Account of the Foxglove and Some of its Medical Uses

William Withering

1785

Cardiac glycosides (Digoxin, Digitoxin, etc.)

remained the mainstay for the treatment of Heart failure especially for the Congestive heart failure for

over two centuries

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William Withering (1783)

out of 158 patients 101 patients

with congestive heart failure

experienced relief following administration

of Digitalis purpurea (Foxglove) leaves”

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Cardiac Glycosides

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Advance Access Online Publication March 11, 2013

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Progress in Traditional Medicine w.r.t

4th Industrial Revolution

  • Herbal Extracts
  • Minerals
  • Mechanical
  • Tictures
  • Powders

  • Isolation

Strychnine (1817)

Quinine (1820)

Nicotine (1828)

  • Cultivation
  • Packaging

Ethnopharm

  • Tissue Culture
  • Analytical
  • Chromatography
  • Standardization
  • Botanicals
  • WHO Recognition
  • HTS
  • Leads, Hits, Candidates

  • Reverse Pharmacology
  • Nutraceuticals
  • Asian Regulations
  • Genomics
  • Molecular Modeling
  • HTS
  • Leads, Hits, Candidates

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1st Industrial Revolution in TM�The 18th century, Pharmacognosy

  • Johann Adam (1759-1809)
  • Linnaeus (Naming and classifying plants)
  • BUT At the end of the 18th century,

crude drugs were still being used as powders, simple extracts, or tinctures

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2nd Industrial Revolution in TM �The era of pure compounds(In 1803, a new era in the history of medicine)

  • Isolation of morphine from opium
  • Strychnine (1817)
  • Quinine and caffeine (1820)
  • Nicotine (1828)
  • Atropine (1833)
  • Cocaine (1855)

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3rd Industrial Revolution in TM �Pharmacological Studies

  • 1783-1855: Francois Magendie Isolation of Strychnine

  • 1813-1878: Claude Bernard Site of action of Curare

  • 1820-1879: Rudolf Buchheim Own lab at home: Site of action

  • 1907 John J. Abel (USA) Ephedrine from adrenal

  • 1937 A. J. Clark/ Receptor concepts

J. H. Gaddum (UK)

  • 1940-60 Col. R. N. Chopra Herbal Drugs

(India)

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4th Industrial Revolution in TM

Integrated Medical Research: Translation

Clinical Pharmacy & Translational Science

  • Drug design
  • Discovery
  • Preclinical toxicity
  • Biomarkers & molecular diagnostics
  • Development
  • Delivery systems

  • Clinical efficacy
  • PK/PD Studies
  • Side effects & ADEs
  • Ineffectiveness
  • Pharcogenomics
  • Pharmacovigilence
  • Applied therapeutics

Improving Human Health

Translation

DRUG

Pharmaceutical Development

Clinical Research

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1st to 4th Change in Trend in the 20th century�Production of natural drug products

  1. Collection
  2. Cultivation (commercial),
  3. Collection, harvesting, drying, garbling, packaging, storage and preservation
  4. Fermentation (Recombinant DNA technology or Genetically engineered drugs)
  5. Cell-culture techniques
  6. Biologics (prepared from the blood of animals)

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2nd to 4th Change in Trend in the 20th century �Isolation of Active Principles

  1. Chromatography
  2. Combinatorial chemistry
  3. HPLC, LC-MS
  4. Combinatorial biosynthesis

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Biomarkers

Biomarker (Biological Marker): A characteristic that is measured and evaluated as an indicator of normal biological processes, pathogenic processes, or pharmacological responses to a therapeutic intervention. Biomarkers may relate to efficacy, safety, differentiation etc.

Surrogate Endpoint: A biomarker accepted by regulatory agencies as a substitute for a clinical endpoint (e.g. HIV load for the stage of AIDS, LDL level for the risk of coronary artery disease, blood pressure for the incidence of stroke & hemoglobin A1C for the control of diabetes).

Diagnostic: A biomarker that has applicability in clinical use or patient management

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Guidelines for the Ayurveda, Siddha, Unani Drugs

 

Quality control methods for medicinal plant material

WHO, 1998

General methodologies and research evaluation traditional medicines 

WHO, 2000

OECD Guidelines

2001

Protocol for testing of ASU medicines

PLIM, 2007

Quality control manual for ASU medicine

Pharmacopoeial laboratory for Indian medicine

PLIM, 2008

Laboratory manual for the analysis of Ayurveda and siddha formulations

CCRAS, 2010

Quality control methods for herbal materials

WHO, 2011

GCP guidelines for ASU medicines, Ministry of AYUSH

2013

General guidelines for safety, toxicity evaluation of ayurvedic formulation

CCRAS, 2016

General guidelines for drug development of ayurvedic formulation

CCRAS, 2016

General guidelines for clinical evaluation of ayurvedic interventions

CCRAS, 2016

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Documents required for the approval of premises� 

·        Forwarding letter

·        Application form filled and signed by the authorized person

·        The firm details filled and signed by the authorized person

·        Original challan for license and fee as per the requirement

·        1 copy of the premises plan – original

·        Possession of the premises

·        Constitution of the firm

·        4 copies – list of products

·        3 copies – draft table of each product

·        1 copy – List of machines, equipment’s and laboratory equipment’s

·        4 copies – Technical persons (with details)

·        Raw materials and analysis methods details

·        Consent letter of public testing laboratories

·        Standard Operating Procedure (SOP) list

·        Master Formula Record (MFR) of all products

·        Product ingredient reference book (Xerox copy) 

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Herbal regulations in ASEAN countries

Malaysia

The registration is done with the Suruhanjaya Syarikat Malaysia or the Malaysian registrar of business under the traditional products or health supplements.

Singapore

In Singapore, a Chinese Proprietary Medicine (CPM) refers to a medicinal product that: Is in the form of a finished product, such as a capsule or tablet, and Contains one or more active ingredients from any plant, mineral, or any combination of sources and there is no registration requirement for the herbal medicines.

Philippines

The herbal medicine registration for the manufacture, import and marketing are regulated by the Bureau of Food and Drugs (BFAD).

Thailand

The herbal medicines are classified as products to sell/ import/ order and it is required for the distributors of the medicinal products to obtain permission from the Food and Drug Administration.

Indonesia

The GMP of the Traditional drugs is regulated by the directorate of the Ministry of Health (MOH).

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No

Countries

Regulations

Year

1.

United States of America

“Dietary Supplement Health and Education Act”

1994

2.

United Kingdom

Market authorization (Directorate 2001/83/EC)

Traditional Herb Registration (THR) (Directorate 2004/24/EC)

2001 & 2004

3.

Saudi Arabia

Manufacturing Requirement same as the GMP rules for conventional pharmaceuticals and WHO GMP

1996

4.

Brazil

Manufacturing requirement similar to the information in the pharmacopoeia and monographs

1967

5.

European Union

Traditional herbal medicine product (THMP)

2004

6.

Canada

The Natural Health Product directorate of the Health Product and Food Branch

1999

7.

Australia

Therapeutic Goods Administrative (TGA)

-

8.

Russia

Same as the prescription medicines, OTC medicines or dietary supplements and the GMP rules are the same used for the conventional pharmaceuticals

1993

9.

South Africa

Medicine Related and Related substance Act and Herbal medicines are known as Complementary medicines

1965

10.

China

State Food and Drug Administration

-

Regulations for Herbal Drugs in Other Countries

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Regulations in India

  • 1911 Act of Patent and Designs : Allopathic medicines
  • MNCs utilized for importing drugs

  • 1948 Foreign companies allowed to set up plants
  • Formulations rather than bulk drugs

  • 1956, Manufacture of drugs from the basic stage
  • 1972 Amendment of the Patent Act

  • 1988 D & C Act & Schedule – Y

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Ministry of Health & FW: Allopathic System of Medicine(Single molecule as drugs or Phytopharmaceuticals DCGI Route)Ministry of AYUSH: Indian System of Medicine

A

Y

U

S

H

Ayurveda

Yoga & Naturopathy

Unani

Siddha

Homeopathy

  • Indian System of Medicine under Ministry of Health and Family Welfare (1995)

  • Renamed as Deptt. Of AYUSH (2003)

  • Ministry of AYUSH (2015)

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Classification of drugs from Herbal Sources

    • Classical Medicine
    • Proprietary Medicine
    • Phyto- pharma-ceuticals
    • Pharma-ceuticals

Arjuna arista Himalaya LIV 52 Vincristine

Yograja Guggulu Dabur Vatika Nil Vinblastine

Narayana Taila Zandu Balm Morphine

Sarpagandha Churna Himalaya’s Serpina Reserpine

Pharma-ceuticals

Phyto- pharma-ceuticals

Proprietary Medicine

Classical Medicine

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Requirements for formulation to be classified as phytopharmaceutical drugs

Govt. of India: GAZETTE NOTIFICATION made public on 30th November, 2015

GSR 918 (E), issued by Ministry of Health & family Welfare, D & C Rule 122 EB

“Phytopharmaceutical drug” includes purified and standardised fraction with defined minimum four bio-active or phyto-chemical compounds (qualitatively and quantitatively assessed) of an extract of a medicinal plant or its part, for internal or external use of human beings or animals for diagnosis, treatment, mitigation or prevention of any disease or disorder but does not include administration by parenteral route.’

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Why Phytopharmaceuticals Regulations?

  • Shrinking of NCE pipeline with Pharma MNCs
  • Phytopharmaceutical concept may open new vista of drug discovery
  • Being in line with regulations in USA, China, & other countries involving scientific basis and Standardization will have global recognition
  • Will promote innovations & transform the concept of botanicals to drug formulations

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Why Phytopharmaceuticals Regulations?

  • This regulation is expected to develop new drugs from botanicals in a scientific way and would help in the acceptance of the use of herbal products by modern medical profession.
  • Phytopharmaceutical’s proposal would promote innovations and development of new drugs from botanicals, and would give boost to research in drug development for innovators, industry, and national laboratories and pharmaceutical research labs in India.

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Phytopharmaceutical Drugs ?How does it differ from ASU drugs?

  • Chapter IV of the D & C Act deals with drugs of Allopathic system.
  • Chapter IV A deals with ASU drugs (restricted to drugs of texts of the First schedule of D & C Act)
  • The definition, the D & C act does not include the words like TM, herbal drugs, herbal medicines, Phytomedicines, MCBT.
  • Phytopharmaceuticals can be from any medicinal plants of the globe (not restricted to plants mentioned in the texts of Schedule First of D & C Act.)
  • Leads for phytopharmaceuticals may have their origin not only in ASU but also in TCM, Kampo, ethnobotanicals tribal plant drugs or any plant of the globe.
  • It does not encroach upon the wholistic approach of ASU drugs of Chapter IV A of D & C Act rather encourages innovative approach for new drug discovery for unmet needs
  • NCE pipeline with pharma MNC’s shrinking drastically. Introduction of phytopharmaceuticals category of drugs open new hope of drug discovery from rich biodiversity of medicinal and aromatic plants.

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Requirements for formulation to be classified as phytopharmaceutical drugs

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  • Purified and standardized fraction with defined minimum four bio-active or phyto-chemical compounds
  • Qualitatively and quantitatively assessed
  • Obtained from an extract of a medicinal plant or its part
  • For internal or external use of human beings or animals
  • For diagnosis, treatment, mitigation or prevention of any disease or disorder
  • Does not include administration by parenteral route.

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Phytopharmaceutical Drug Development

Plant

Extraction

Extract/Fraction

Purification

TLC (Qualitative)

HPLC ( Quantitative)

Dosage – Oral/external but not parenteral

Human / Animal

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Requirements for as ‘Phytopharmaceutical drugs Approval’: Part 1A

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1. Data to be submitted by the applicant

A brief description or summary of the phytopharmaceutical drug

Published literature on plant or phytopharmaceutical drug

Information on any contraindications, side effects

Published scientific reports on safety and pharmacological studies of phytopharmaceutical drug

Present usage of the phytopharmaceutical drug

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Identification, authentication and source of plant used for extraction and fractionation

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Taxonomical identity

Morphological and anatomical description, confirmation of identity and authenticity

Natural habitat and geographical distribution of the plant

Season or time of collection.

Source of the plant including its geographical location and season or time of collection.

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Phytopharmaceuticals Drugs…..

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Data generated

Identification, authentication and source of the plant used for extraction and fractionation

Process for extraction and subsequent fraction and purification

Formulation details of phytopharmaceutical drug

Manufacturing process of formulation

Stability data

Safety and pharmacological information

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Requirements for as ‘Phytopharmaceutical drugs Approval’: Part 1B

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2. Human or clinical pharmacology information

Published scientific reports on pharmacological studies including human studies or clinical studies or epidemiological studies

Pharmacodynamic information

Monographs, if any, published on the plant or product or extract or phytopharmaceutical

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Under Schedule Y: Appendix IB

For issue of license with respect to Phytopharmaceutical drug

DATA TO BE GENERATED BY APPLICANT

IND Filing of Phytopharmaceutical Drugs�Data to be submitted along with application to DCGI

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Safety and Pharmacological information

  • Animal toxicity and safety data:
    1. 28 to 90 days repeat dose oral toxicity on two species of animals.
    2. in vitro genotoxicity data
    3. Dermal toxicity test for topical use products
    4. Teratogenicity study (intended for use during pregnancy)

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Part 4�Process for extraction and subsequent fractionation and purification

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    • Quality specifications and test methods for starting material
    • Details of packaging of the purified and characterized final product, storage conditions and labeling.
    • Steps involved in processing

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Other Parts�Phytopharmaceutical drugs….

38

    • 5
      • Formulation of phytopharmaceutical drug applied for:

    • 6
      • Manufacturing process of formulation:

    • 7
      • Stability data:

    • 8
      • Safety and pharmacological information:

    • 9
      • Human studies:

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Stability data

  • Stability data of the Phytopharmaceutical drugs: stored at room temperature at 40 °C ± 2 °C , humidity at 75% RH ± 5% RH for 0, 1, 2, 3 and 6 months
  • Stability data in dosage form or formulation: stored at room temperature at 40 °C ± 2 °C , humidity at 75% RH ± 5% RH for 0, 1, 2, 3 and 6 months in the packet intended for marketing.

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Phytopharmaceuticals Drugs…..

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Data generated

Human Studies

Confirmatory clinical trials

Regulatory Status

Marketing Information

Post marketing surveillance

Regulatory

ASU drugs have been under the purview of Ministry of AYUSH

Phytopharmaceuticals are under the purview of CDSCO

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    • 10
      • Confirmatory clinical trials:

    • 11
      • Regulatory status:

    • 12
      • Marketing information:

    • 13
      • Post marketing surveillance (PMS):

    • 14
      • Any other relevant information:

Other Parts�Phytopharmaceutical drugs….

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Comparision of Attributes of ASU Vs Phyto

Attributes

ASU /

Proprietary

Phyto-

pharmaceuticals

Number of herbs?

Multiple

Single

Source of herbs?

Authoritative text

Anywhere

Minerals/metals

Permitted as per DCAR

Not allowed

Use of organic solvents?

Water or hydroalcoholic

Permitted

Licensing Authority?

AYUSH

CDSCO (DCGI)

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What is Not Included Or Included Phytopharmaceuticals?

  • One step extracts of Botanicals using any solvent & converted into powders

Steps involving more than one solvents for Fractionation

  • Fixed Oils extracted from botanicals

Fractionated fatty acids from vegetable oils, fractionated distilled oils extracted from botanicals

  • Extracts obtained by traditional methods using other solvents like vegetable oil, milk or clarified butter

Distilled oils or volatile components from botanicals

  • Single step oleo-resin extracts
  • Fractions or Purified Fractions tested for bioactivity or phyto-chemicals (4 Analytically assed) & At least one of the Phytopharmaceutical biologically assessed

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Summary

  • Introduction of Phytopharmaceuticals as a new class of drug is an important, timely and progressive step

  • It would inculcate higher level of scientific inputs in herb based products

  • Phytopharmaceuticals may help as a booster dose for the Herb based drug business.

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Thank you

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��Case Study�Scutellaria barbata D. Don as Phytopharmaceutical drugs……

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Requirements for formulation to be classified as phytopharmaceutical drugs

“Phytopharmaceutical drug” includes purified and standardised fraction with defined minimum four bio-active or phyto-chemical compounds (qualitatively and quantitatively assessed) of an extract of a medicinal plant or its part, for internal or external use of human beings or animals for diagnosis, treatment, mitigation or prevention of any disease or disorder but does not include administration by parenteral route.’

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S. barbata D. Don as Phytopharmaceutical drugs……

  • Purified and standardised fraction: ethyl acetate
  • Minimum four bio-active or phyto-chemical compounds
  • Qualitatively assessed: Scutellarin, scutellarein, hispidulin and wogonin
  • Quantitatively assessed: Scutellarin (27 µg/mg), scutellarein (20.16 µg/mg), hispidulin (13.02µg/mg) and wogonin (3.27 µg/mg)
  • A medicinal plant or its part: Whole plant of Scutellaria barbata

  • Animals for diagnosis, treatment, mitigation or prevention: LACA mice, for the treatment of depression

  • Route: Oral

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