GovWire

Guidance: Project Orbis

Medicines Healthcare Products Regulatory Agency

January 30
11:45 2023

The programme provides a framework for concurrent submission and review of oncology products among international partners. It aims to deliver faster patient access to innovative cancer treatments with potential benefits over existing therapies.

Project Orbis is coordinated by the US Food and Drug Administration (FDA). Alongside MHRA, it involves the regulatory authorities of:

  • Australia (Therapeutic Goods Administration (TGA))
  • Canada (Health Canada)
  • Singapore (Health Sciences Authority (HSA))
  • Switzerland (Swissmedic)
  • Brazil (Agncia Nacional de Vigilncia Sanitria (ANVISA))

Project Orbis Partners (POPs) may propose products for inclusion in the scheme. Each country remains fully independent on their final regulatory decision.

Products eligible for Project Orbis

Applications submitted to the MHRA within a Project Orbis procedure must be new marketing authorisation applications (MAAs) or new indication applications (variations) for oncology products.

Authorisations will be applicable in Great Britain only as oncology medicinal products fall within the mandatory scope of the European Medicine Agency (EMA) centralised procedure that applies in Northern Ireland.

You can find out more on the EMA website.

The FDA coordinate the selection of products that will be included. Initial enquires that MHRA receive will be referred to the FDA.

Submissions will only be forwarded to the FDA if they meet the qualifying criteria for the Innovation Passport within the Innovative Licensing and Access Pathway (ILAP).

MHRA, NICE and the Scottish Medicines Consortium (SMC) will collaborate within ILAP and a positive Innovation Passport designation is a requirement for inclusion in the Project Orbis programme.

You can find out more in our guidance about ILAP

Submissions will also need to meet the FDAs clinical criteria for priority review.

If you want MHRA to propose a product or new indication for the Project Orbis programme, email Orbis-MHRA@mhra.gov.uk with a summary of the product explaining how you meet the eligibility criteria. MHRA will arrange a meeting with you to discuss eligibility.

Types of submissions

There are three different types of submission depending on the timelines between the FDA and MHRA.

Type A

Applications should be submitted concurrently or near-concurrently (within 30 days) to FDA and MHRA. These are termed Type A Orbis (Regular Orbis) and allow for maximal collaboration during the review phase and the possibility of concurrent action with FDA.

Type B

Applications submitted with a greater than 30-day delay or a regulatory action greater than 3 months of the FDA action are termed Type B Orbis (Modified Orbis) and allow the possibility of concurrent review with FDA but no concurrent action.

Type C

If the FDA has already taken regulatory action, a Type C Orbis (Written Report Only Orbis) will allows the FDA to share their completed review documents with MHRA but there is no concurrent review or action with FDA.

Project Orbis Types

Orbis Type Type A Type B Type C
Submission Timeline Application submission to POPs ? 1 month of FDA submission Application submission to POPs > 1 month of FDA submission Any time after FDA submission1
Submission overlaps with FDA Expected Expected Permitted2
Sharing of FDA reviews Yes Yes Yes
Multi-country review meetings (POP TCONs) Yes Yes No
POP Attendance at FDA review meetings Yes Yes Unlikely
Concurrent review with FDA Expected Possible Unlikely
Near concurrent action with FDA Possible1 No1 No1

1 Regulatory action in other jurisdictions is unlikely to occur immediately after FDA action and will follow respective health authority timelines.

2Dependent on Project Orbis Partner (POP) guidelines. Contact specific POP(s) regarding optimal timing for submission of Type C dossier.

Inclusion of the MHRA in a Project Orbis Procedure

Once a product or new indication has been identified for inclusion in Project Orbis, FDA will contact the MHRA to request their interest in involvement. If the request is provisionally accepted by the MHRA, the parent US Company will be advised and should provide details of the local UK affiliate to MHRA.

MHRA participation is contingent on agreement with the UK affiliate and inclusion of the product or new indication in ILAP.

If the product or new indication is not already accepted for ILAP, the MHRA will arrange an Innovation Passport meeting as soon as possible after the request for inclusion in Project Orbis to confirm eligibility based on a review of the top-level clinical data. The meeting will also address practical arrangements for the submission, including the requirements for:

  • orphan products
  • paediatric investigation plans (PIPs)
  • pharmacovigilance including risk management plans (RMPs).

Requests for meetings should be emailed to Orbis-MHRA@mhra.gov.uk. MHRA will then arrange a mutually acceptable date for the meeting.

For products and new indications already

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