 Keith Williams (left), Dr. Neil Rotherham (center), and Patrick Hughes of Good Products smile for a photo in front of their
booth in the Exhibit Hall.
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"We don't want the paper. It's just that plain and simple."
So said Michael Fauntleroy, program manager of FDA's Electronic Submissions Gateway, at the Drug Information Association's
(DIA) Electronic Document Management (EDM) Conference held February 5–8 in Philadelphia, PA. Though he was speaking specifically
about FDA, no sentence could better assess the current state of EDM in general.
It may seem like a burden to uproot paper-based ways in favor of electronic document and data management, but the consensus
is that EDM ultimately makes work easier, more efficient, and more accurate for all concerned. At the conference, presenters
examined changes that are both presently underway as well as on the horizon and discussed suggestions for adopting a new EDM
solution.
MetadataThe proper use of metadata is absolutely crucial to the success of EDM, as it affects Document Lifecycle Management, rules-based
document generation and assembly, submission assembly and publishing, and integrated submission management, noted Gabor Farii,
life sciences solution specialist for Microsoft. The key to creating usable metadata is simple: Organizations must focus on
making it consistent, as disciplined, well-structured metadata enables a more efficient workflow by helping eliminate extra
work due to mistakes.
"This is really where the problem lies. Metadata is inconsistent," said Ed Chase, solutions architect–life sciences, health
care, manufacturing for Adobe. "You have different file formats and each is going to have a different metadata structure.
The second challenge is the application inconsistencies. This is when you start talking about the tags, file tags, and that
stuff."
As a proposed solution to this problem, Chase cited Adobe's XMP: The Extensible Metadata Platform, which is a framework for
storing information and allows users to synchronize centralized and document-centric metadata, as well as preserve domain-specific
metadata across file types.
Microsoft is currently working on a different system that will aid in simplifying metadata—namely, an Office program in which
content management goes hand in hand with the document so you never need to leave the Office interface. This type of federated
system is favorable, since it "talks" to all other systems that are both metadata aware and unaware.
Regulatory
Standardization and consistency were also prominent in sessions delivered by regulatory personnel. Lise Stevens-Hawkins, CBER
data standards project manager, asserted that the FDA is committed to using open, consensus-based data exchange standards
whenever possible in order to support functional interoperability, data reuse, and cross-referencing. Due to the current state
of submissions, she said, the FDA is receiving the same information over and over again with no way to use it practically
because of all the different terminology. To address this problem, there are a few standards under development, including
CDISC to HL7 Content Message, which promotes data exchange using the HL7 standard; the creation of one message model for standard
study clinical data; and integration with SPL, ICSR, and RPS standards to enable data reuse and cross-referencing.
The changing regulatory landscape focuses particularly on the electronic Common Technical Document (eCTD). As of January 1,
2008, the eCTD became the only recognized electronic submissions format without a waiver in the United States. While paper
submissions are still accepted, the FDA discourages them.
The FDA is also continuing to try and make eSubmissions as simple as possible with the creation of the Electronic Submissions
Gateway (ESG), an agency-wide solution and central transmission point for accepting secure electronic regulatory submissions
over the Internet, automatically routing submissions to the proper FDA center or office.
The EU shares the FDA's preference for the eCTD, as can be seen by examining the guidance on the horizon: Current guidance
remains in place through July 2008, at which point the EMEA will accept electronic-only submissions in either eCTD or non-eCTD
format, though eCTD is preferred. By January 2009, the EMEA will strongly recommend submitting electronically in either eCTD
or non-eCTD format, and will strongly recommend eCTD only as of July 2009.