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Performance Standards for NHP Applications

The coronavirus-19 (COVID-19) pandemic has had a long-lasting effect on many of the processes done in business and everyday life. One of the resulting main effects is delays in application processing times. From simple applications such as passports to larger-scale applications such as NHP licensing.

Prior to the pandemic, Natural and Non-Prescription Health Products Directorate (NNHPD) had a well-established service standard for Class I, II and III applications, which is outlined in the Management of Application Policy (MAP) guidance as shown below:

As the focus had started to shift to prioritize COVID-related product applications, a resultant de-prioritization of the non-COVID-related applications occurred. Not surprisingly, the volume of priority applications began to create a backlog on the non-priority product, site, and post-license submissions, thereby increasing the service standards. Within the past year, NNHPD has managed to achieve the following:

  • NNHPD licensed 4,290 new alcohol-based hand sanitizers and issued 2,054 interim Covid site licenses.
  • NNHPD issued 10,826 Non-COVID related product licence and 1,126 site licence decisions

To manage stakeholder expectations, NNHPD provided discretionary dates in which they hoped to see 90% of applications fulfill their original committed service standard. These dates were further broken down into application type and class. In addition, regular updates were provided by NNHPD via the Performance standards for NHP applications Stakeholder Meetings, with the most recent one being March 24, 2021.

As of this fiscal year, NNHPD has already completed 5,046 Class I submissions, which is up 343 submissions from the previous year. The standard processing time for Class I submissions is 60 calendar days from the date of submission. NNHPD was able to meet the 90% target in months of January (93.8%), February (97.4 %), and March (91.4%).

For Class II, 2,221 submissions were completed in this fiscal year, which is up 301 submissions from the previous year. The standard processing time for Class II submissions is 90 calendar days from the date of submission. NNHPD was able to meet the 90% target in January (93.7%), February (93 %); however, they fell slightly below in March (89%).

Lastly, 3,298 Class III submissions were completed within the current fiscal year, which is up by 585 submissions from the previous year. Therefore, as a result, NNHPD is on track to meeting their 80% goal for the original 210 calendar day service standard, with over 88% of the backlog completed.

While much has been achieved, NNHPD has warned about the impacts of further volume increases will have on the current system. For example, a 40% increase in Class II and Class III applications was observed in March; thus, NNHPD has asked to limit submissions to critical applications.

Post-licensing submissions are subdivided into two categories: amendments and notifications.

Amendments are defined changes to an NHP that may have an impact on the safety, efficacy and/or quality of the product. In contrast, notifications are defined as changes to an NHP that do not significantly impact the product’s safety, efficacy, and/or quality. Similar to new product submissions, amendments follow the 3 Class application system and service standard. On the other hand, notifications have no established service standard and do not follow the 3-class system.

Only 63.9% of the received amendments have been issued a decision. There are approximately 147 submissions received in 2020, which remain to be processed. Similarly, 62% of received notifications have been completed to date.

The target has been successfully met for both Stream I (94%) and Stream II (96%) site license applications. Approximately 201 Stream I submissions, 389 Stream II submissions, and 318 renewals have been completed this year. In addition, extensions were granted for renewals to accommodate further processing.

Although it may seem that little can be done as a stakeholder to speed up the licensing process, there is one way, using the most up-to-date licensing forms. Within the last year, NNHPD has launched online webforms to be used in application submission. The web-based Product Licence Application (web PLA) and the amendment and notification form (ANF). The forms have a validation component built-in, which thereby lessens the burden for NNPHD.  A lower burden allows for greater processing times and avoids unwarranted application refusals.

The ever-present changes resulting from COVID make it increasingly challenging to keep up with the most up-to regulatory information. As planning is a large part of the product launch, it is crucial to be in the know on impacts to your product plan. Our Experts at Quality Smart Solutions can offer support to your needs for foods, cosmetics, OTC drugs and medical devices for North America.

Contact us today to learn more about how we can support your compliance needs during and after licensing!

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The Difference between a Class I, II and III NHP Application

nhp, nnhpdIdentifying the correct application type has become increasingly more crucial for Natural Health Product (NHP) applications. Incorrect classification can result in detrimental outcomes such as the issuance of rejection notices (RN) and further delays to go-to-market plans.

A basic understanding of the different NHP application classes (Class I, Class II, Class III) can help to better plan for this. Our Experts at Quality Smart Solutions can help you navigate this decision process and understand some of the limitations and benefits each application type offers.

Health Canada currently defines NHP applications as three types of application classes, which are then further subdivided into two application streams: compendial and non-traditional. The compendial application stream is exclusive to Class I applications, while the non-traditional application stream includes Class II and Class III applications.

First, let’s begin by discussing one of the primary points of deciphering application classes: the compendium of monographs. The compendium of monographs is an online repository created by Health Canada for a variety of NHP ingredients. The monograph outlines pre-cleared information (PCI) by Health Canada which is defined as:

  • Any form of information supporting the safety, efficacy or quality of a medicinal ingredient or natural health product that the Natural and Non-prescription Health Products Directorate (NNHPD) has reviewed and determined to be acceptable. PCI can be used to speed up the evaluation of the NHP and serves as a reliable source of product information for consumers.

With the monographs as a reference point, the application streams can now be better defined as follows :

  • Class I: must comply with all of the parameters of an individual NNHPD monograph with no modifications. Only one NNHPD monograph per application in Class I can be referenced. 
  • Class II: supported entirely by a combination of 2 or more NNHPD monographs or 1 NNHPD monograph, where slight deviations to claims are permissible. 
  • Class III: a full assessment required as in the following cases: novel preparations, ingredient master files, ingredient combinations, and going beyond NNHPD monograph parameters

One may ask, what are the main differences between the three? While Class I applications are referencing pre-approved information from Health Canada, it is also is the most restrictive of three but with the shortest application processing time.

Class II applications, by contrast, have greater flexibility than Class I. However, there are still limitations on the extent to which claims can be made. Class II applications have a median application processing time of the three.

Lastly, Class III applications offer the greatest flexibility; however, this also is at the cost of application processing time. Of the three application types, Class III is the longest.

As always, there are exceptions to these general guidelines. In some cases, there may be some exemptions or further restrictions.

How We Can Help

Our Experts at Quality Smart Solutions also offer to support your needs for foods, cosmetics, OTC drugs and medical devices for North America.

Contact us today to learn more about how we can support your compliance needs during and after licensing!

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