TABLE 1.
Regulator’s considerations and possible regulatory actions by subject of potential interest in the different steps of the drug lifecycle.
Drug lifecycle steps | Data related subjects | Models and applications related subjects | Considerations/possible regulatory actions |
---|---|---|---|
A- Drug discovery | Use of chemical and pharmacological big data Genetic association analysis, pathway mapping, molecular docking, and signature profile matching data |
Mode of action/AI prediction Ranking of promising drug compounds Drug repurposing |
If determinant in the body of evidence: Assessing relevance of data used/ability to check comprehensiveness and relevance models used |
B- Non-clinical testing and toxicity prediction | Use of toxicological big data | Specific models for toxicity prediction (ex: RASAR) | Assessing data used: ability to check comprehensiveness and relevance New regulatory standards for toxicity prediction if used in animal full replacement methods Evolution of pharmacopeial monographs |
C-Translational and clinical research | Synthetic data | Digital twins | Ability to check relevance of the synthetic data |
EHR, data from various sources (omics, imaging, pathology, etc.) real-world data | Clinical trial design optimization | Checking/assessing data used Relevance of potential regulatory action to be determined |
|
EHR, use of real-world data | Selection of patients | Expected regulatory adaptations needed | |
Use of clinical big-data (imaging, pathology, omics, etc.) | Analysis of clinical trials | Enhancement of classical routine clinical trial analysis Relevance of potential regulatory action to be determined. Use of clinical big-data already in research hospitals (clinical trials) |
|
D- Pharmaceutical manufacturing, QC, QA | Use of in-house firms’ data | Specific models and applications: process design, optimization, in-control advanced process control, used before process or on-site | Potential confidentiality issues. Regulations to be adapted Knowledge of model precision, accuracy, and state-of-the-art. For continuous production or models used in live production control, specific training of inspectors Evolution of pharmacopeial monographs |
E- Pharmacovigilance (PV) | Usual and “Non-conventional” big-data use: social networks, medical forums | Early or wider detection of PV signals/detection from more sources and big-data | Validate relevance and usefulness of data Check and test relevance of detections: part of model training. Might be put in routine production soon |