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Pandemic Special Access Route (PSAR) for Supply of Emergency Therapeutic Products

The interim authorisation enables regulatory agilities in responding to an emergency that may pose serious threats to the public, such as in the situation of a pandemic.

1.Introduction

This guidance outlines the special access route for the supply of an “emergency therapeutic product” through an interim authorisation under sub-regulations 60A(4) and (5)(b) of the Health Product (Therapeutic Products) Regulations. 

The interim authorisation enables regulatory agilities in responding to an emergency that may pose serious threats to the public such as in the situation of a pandemic. Given the urgent public health need, HSA will prioritise the review of novel therapeutics and vaccines to facilitate timely access while ensuring the scientific rigour of the assessment of their quality, safety and efficacy.

PSAR provides for the Government of Singapore to direct the supply of such emergency therapeutic products during the pandemic, taking into consideration the following:

a) there is reasonable evidence suggesting that the potential benefits outweigh the risks for their use in treating or preventing a disease in an emergency that may pose serious threats to the public; and

b) there is on-going quality, safety and efficacy data generated to support the eventual transition of the interim authorisation to product registration under section 15 of the Health Products Act and regulation 22 of the Regulations.

2.Emergency Therapeutic Product

A novel therapeutic or vaccine may be designated by the Health Minister as an “emergency therapeutic product” where:

a) the therapeutic product is needed —

i. to treat any medical condition resulting from a civil defence emergency;

ii. to prevent the spread or possible outbreak of an infectious disease; or

iii. to treat an infectious disease or any medical condition associated with an infectious disease,

where the medical condition or infectious disease is potentially serious or life-threatening; and

b) in the opinion of the Health Sciences Authority, there is —

i. preliminary scientific evidence that the therapeutic product has the potential —

  • to treat the medical condition resulting from the civil defence emergency;

  • to prevent the spread or possible outbreak of the infectious disease; or

  • to treat the infectious disease or any medical condition associated with the infectious disease,

             and

ii. ongoing scientific evidence that the potential benefits of the therapeutic product outweigh the known risks of the therapeutic product.

3.Application for an Emergency Therapeutic Product

a) Prerequisite criteria

Before making an application under the interim authorisation, the applicant must ensure that it fulfils the prerequisite criteria below:

i. The applicant is a supplier directed by the Government of Singapore to supply for or on behalf of the Government, thereafter referred to as the company; and

ii. The therapeutic product has been assessed by the Government of Singapore to have fulfilled one of more of the conditions specified in paragraph 2(a).

b) Pre-submission consultation

The company must notify HSA prior to making an application and arrange for a pre-submission consultation to discuss the data submission plan. To request for a pre-submission consultation, please click here

Note: HSA will not accept any request for pre-submission consultation if the prerequisite criteria specified in paragraph 3(a) are not fulfilled. No reply will be given to such indiscriminate requests.

c) Data requirements

The interim authorisation provides flexibility in the level of evidence required for supporting the application and allows data to be submitted on a rolling basis. At the time of application, the company: 

  • may provide initial data that is available to initiate the review process and file information as data is accrued from on-going studies; and

  • must submit a rolling submission plan outlining the sequence and timelines of the subsequent data submission. The rolling dataset that is minimally required to meet the level of evidence for supporting an interim authorisation is listed in Annex A 236 KB.

d) Filing an application & timeline 

A company that has completed the steps specified in paragraph 3 (a), (b), and (c) may proceed to apply for an interim authorisation. For application submission, please click here

The rolling submission will be reviewed based on real-time evaluation of data as and when the information is submitted to HSA. The turnaround time will depend on the rolling submission timelines as proposed by the company.

4.Interim Authorisation

The interim authorisation is valid for such time during the emergency and may be cancelled if any of the following occurs:

  • when evolving quality, safety and efficacy data suggests that the benefits of the emergency therapeutic product no longer outweigh the risks during an emergency;

  • when the emergency has ceased; or

  • when there is adequate quality, safety and efficacy data to support a registration application and transition the emergency therapeutic product to a registered therapeutic product.

5. Contact us

If you wish to apply for an interim authorisation for an emergency therapeutic product, please review the requirements in this guidance document to ensure that you meet the prerequisite criteria.

If you require further clarification, please contact HSA at: HSA_TP_Enquiry@hsa.gov.sg  



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