Regulated Product Submissions (RPS) – Overview

The Regulated Product Submission (RPS) is an HL7 standard introduced by the US Food and Drug Administration (FDA). As defined in the Prescription Drug User Fee Act (PDUFA), the Regulated Product Submission helps Life Sciences companies submit product information to Regulatory Authorities in a streamlined manner. The Regulated Product Submission HL7(RPS) standard is intended for broader use as compared to an electronic Common Technical Document (eCTD). Beyond drugs, it could potentially support submissions for medical devices, veterinary, and other regulated products such as tobacco.

The eCTD v4 is based on the Regulated Product Submission (RPS), which permits document reuse. In this system, each document is assigned a unique identification – the Universal Unique ID (UUID), which can be referenced as long as it is in a particular Agency’s system. Details about the file path are not needed. While compiling an application that utilizes UUIDs & Regulated Product Information, the following points need to be kept in mind by Regulatory professionals:  

• Metadata Revision: Typos and other errors in metadata can be easily corrected in eCTD 4. Users can also revise previously submitted metadata, like related sequences, submission type, operation attributes, manufacturer’s name, and so on, without facing any problems.
• Two-Way Communication:  Agencies and sponsors can now communicate between themselves and send correspondence to each other such as requests for information in the form of eCTD sequences.  
• Table of Contents (TOC): As compared to eCTD v3.2.2, the Table of Contents (TOC) or hierarchy in eCTD 4 is not defined.
• No Manual Editing of eCTD XML: Now that the XML stylesheet doesn’t display a hierarchy of documents, working with and reading XML manually will be incredibly difficult, if not impossible.
• Study Tagging Files (STFs): The function of STFs falls within the purview of Document Groups. Eliminating these STFs is a win for global harmonization.
• Document Groups These groups let eCTD users group files together based on the nature of their use (e.g., clinical study reports).
• Context of Use: The code for each Context of Use specifies where documents are to be inserted into the CTD/eCTD TOC when presenting a reviewable structure.
• Replace One Document with Many: As users perform lifecycle maintenance on submissions, they can now alter the granularity of documents.
• Append Lifecycle Operation: While “append” can no more be used in eCTD 4, it still does support the existing “new,” “replace,” and “delete” eCTD v3.2.2 lifecycle operators.
• Metadata: Metadata becomes more important overall, right from decoding information on application type to reviewing status to know the type of document and many other related activities. It is expected that metadata will be used for everything with eCTD 4.
• Controlled Vocabularies: These are essential components of eCTD 4 and will enable interoperability – i.e., clear, unambiguous communications between systems sending and receiving XML messages.
• Grouped Submission: A grouped submission is a single submission unit that is applied to more than one (01) submission. Grouped submissions are the only business cases for sending a submission unit with more than one (01) component of the submission element (e.g., manufacturing changes that affect more than one (01) application).

To take advantage of quick review procedures, the USFDA encourages sponsors to take the route of rolling eCTD submissions through which sponsors can submit some sections of the entire dossier for review without waiting for an entire application to be finished. Freyr’s publishing and Regulated Product submission experts assist the sponsors in the accurate filing of all the sections.