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Published on 22/12/2025

PMDA Submissions and Notifications SOP

Department	Clinical Research
SOP No.	CS/PMDA-SUB/169/2025
Supersedes	N.A.
Page No.	1 of 24
Issue Date	28/08/2025
Effective Date	05/09/2025
Review Date	05/09/2027

Purpose

This SOP describes the process for preparing, submitting, and managing Clinical Trial Notifications (CTNs), amendments, safety reports, and trial notifications to the Pharmaceuticals and Medical Devices Agency (PMDA). It ensures alignment with Japanese Good Clinical Practice (J-GCP), the PMD Act, and ICH-GCP guidelines to protect participant safety, maintain regulatory compliance, and ensure inspection readiness.

Scope

This SOP applies to all clinical trials sponsored or managed by the organization that require submissions to the PMDA. It covers CTN submissions, substantial and administrative amendments, trial start/termination notifications, safety updates, and responses to Requests for Information (RFIs). It applies to Regulatory Affairs, Clinical Research, Pharmacovigilance, and Investigator Sites.

Responsibilities

• Regulatory Affairs (Japan): Leads preparation and submission of CTNs, amendments, and notifications.
• Principal Investigator (PI): Provides site-level documents and ensures compliance with authorized protocols.
• Clinical Project Manager: Coordinates timelines and ensures documentation completeness across functions.
• Pharmacovigilance (PV): Submits safety reports and integrates case narratives into lifecycle submissions.
• Quality Assurance (QA): Reviews submission packages for completeness, consistency, and inspection readiness.

Accountability

The Head of Clinical Research holds ultimate accountability for ensuring that all PMDA submissions and notifications are accurate, timely, and compliant. The PI is accountable for ensuring site documentation and REB notifications align with PMDA submissions.

Procedure

1. Initial CTA/CTN Preparation

1. Compile core documents: protocol, IB, ICFs, CMC data, investigator qualifications, and site information.
2. Translate subject-facing documents into Japanese, with certified translation certificates filed in TMF.
3. Prepare eCTD package in accordance with PMDA electronic submission guidelines.
4. Perform internal QA review before dispatch.

2. Submission Process

1. Submit electronically via the PMDA Gateway.
2. Record submission date, acknowledgement ID, and control number in Regulatory Submission Log.
3. File submission package and acknowledgements in TMF.

3. Amendments

1. Determine amendment type: substantial (affecting safety, subject rights, or scientific validity) or administrative.
2. Prepare updated documents, summary of changes, and rationale.
3. Submit to PMDA before implementation, unless urgent safety measures are required.
4. Update Amendment Log and inform sites of approval status.

4. Notifications and Trial Updates

1. Notify PMDA of trial initiation, site activations, and trial termination/withdrawal.
2. Maintain Trial Notification Log capturing activity, submission date, and acknowledgement.

5. Safety Submissions

1. Submit expedited SUSAR reports in accordance with PMDA timelines.
2. Integrate cumulative safety updates into annual reports.
3. Maintain SUSAR and Safety Reporting Logs in TMF.

6. Responses to PMDA RFIs

1. Log all RFIs within 24 hours of receipt.
2. Assign subject matter experts to draft responses, reviewed by QA.
3. Submit responses within the required timeline, filing correspondence in TMF.

7. Documentation and Archiving

1. Maintain Submission Log, Amendment Log, Safety Reporting Log, and Communication Log in TMF.
2. Archive bilingual versions of subject-facing documents for at least 15 years or per PMDA rules.
3. Conduct self-inspections to confirm audit readiness.

Abbreviations

• PMDA: Pharmaceuticals and Medical Devices Agency
• CTA: Clinical Trial Application
• CTN: Clinical Trial Notification
• PI: Principal Investigator
• REB: Research Ethics Board
• IB: Investigator’s Brochure
• ICF: Informed Consent Form
• CMC: Chemistry, Manufacturing, and Controls
• PV: Pharmacovigilance
• QA: Quality Assurance
• TMF: Trial Master File
• RFI: Request for Information

Documents

1. Regulatory Submission Log (Annexure-1)
2. Amendment Log (Annexure-2)
3. Trial Notification Log (Annexure-3)

References

• PMDA — Pharmaceuticals and Medical Devices Agency
• PMDA Clinical Trial Guidance
• ICH E6(R2) Good Clinical Practice
• ICH Guidelines — Efficacy

Version: 1.0

Approval

Prepared By	Checked By	Approved By
Name: Rajesh Kumar Date: 20/08/2025 Signature: __________	Name: Sunita Reddy Date: 22/08/2025 Signature: __________	Name: Dr. Meera Iyer Date: 28/08/2025 Signature: __________

Annexures

Annexure-1: Regulatory Submission Log

Date	Submission Type	Protocol No.	Submission ID	Status	Submitted By
05/08/2025	Initial CTN	JPN-2025-01	PMDA-CTN-001	Acknowledged	Rajesh Kumar

Annexure-2: Amendment Log

Date	Amendment	Summary of Change	Status	Submitted By
18/09/2025	Amendment 1	Updated eligibility criteria	Under Review	Sunita Reddy

Annexure-3: Trial Notification Log

Date	Activity	Protocol No.	Notification ID	Status	Owner
25/09/2025	Trial Initiation	JPN-2025-01	PMDA-NTF-010	Acknowledged	Neha Sharma

Revision History

Revision Date	Revision No.	Revision Details	Reason for Revision	Approved By
28/08/2025	1.0	Initial SOP for PMDA submissions and notifications.	New SOP established for J-GCP compliance.	Head of Clinical Research

For more SOPs visit: Pharma SOP.