The limited belief that is holding back African regulatory development I Medicines for Africa
When it comes to regulatory development of African countries, there is no shortage of ambition amongst the region’s national medicines regulatory agencies (NRAs. The continent of Africa is brimming with it. Though finance is believed to be the biggest impediment to NRA success, it may be a limiting belief that needs to be overcome. Regulatory excellence is more than about having meticulous systems and processes on paper if those are not applied into regulatory practice. Regulatory maturity and excellence is about practice. It results from small incremental steps taken consistently. It takes a painstaking process of critical self-evaluation, course correction and continuous improvement. It is built over time.
When it comes to regulatory development of African countries, there is no shortage of ambition amongst the region’s national medicines regulatory agencies (NRAs. The continent of Africa is brimming with it. African regulatory agencies are hard at work to raise the maturity and performance. Agencies are devoting tremendous energy to their development. This national ambition is a major force that will ultimately make or break the harmonization of medicines regulation across the continent and the potential success of the African Medicines Agency. Many NRAs aspire to raise their regulatory maturity to the World Health Organisation (WHO) maturity level 3 (ML3) or four global bench-mark.
The WHO Global Benchmarking Tool explains that achieveing ML3 means that a regulatory authority has a stable, well- functioning, and integrated regulatory system. Level 4 on the other hand indicate a regulatory system operating at an advanced level of performance and continuous improvement. However, many African countries that aspire to achieve ML3 status struggle to achieve it. Of the 14 or so countries that have achieved ML3 and ML4 globally only six are African that is Zimbabwe, Ghana, South Africa, Nigeria, Tanzania and Egypt are ML3 authorities. Of the country that recently undertook to get ML3 status, Zimbabwe is the only one to have succeeded. The reasons why they fail remains a closely guarded secret known to few such as the NRA that undertakes the benchmarking process, WHO assessors and a few technical expert insiders.
Though finance has is believed to be the biggest impediment to NRA success, it may be a limiting belief that can be overcome. Allow me to explain. Consider one of the most recent NRAs to fail to get ML3 benchmarked by the WHO - Rwanda FDA. It is one of the most, if not the-most-well-funded NRA on the continent. It has many generous donors who have shown willingness to go to extraordinary lengths to help Rwanda achieve ML3 in large part because it is after all the hosting nation for the African Medicines Agency. After its latest efforts in March 2024 failed, Rwanda’s donors have shown willingness to go above and beyond what is considered conventional practice to help it achieve this milestone. They have invested millions of dollars to help Rwanda achieve WHO ML3 status. So far success has proved elusive
Rwanda’s ambition to achieve ML3 status by August 2021 and it has had support from far and wide. Amongst the six European countries - France, Germany, Belgium, Sweden, Austria and Lithuania highlighted at the recently concluded World Health Summit that have been supporting it to get ML3, Rwanda has dedicated donors beyond Europe. Team Europe has provided financial and material support for more than two years and recently announced at the Summit that it will be extending support for six more months possibly more. Whatever has obstructing Rwanda from achieving ML3 status, funding, human resources and technical expertise cannot be one of them. Despite ample financial resources and partners with bottomless pockets who are more than willing to hand-hold Rwanda to success – Rwanda’s efforts have floundered.
Contrast Rwanda FDA’s struggle to achieve ML3 with another regulatory agency that recently achieved WHO ML3 status - the Medicines Control Authority of Zimbabwe. Zimbabwe has succeeded in spite of limited funding offering an interesting perspective. Zimbabwe's achievement is remarkable given the circumstances under which it achieved them. It is the exact opposite of Rwanda in terms of resources at its disposal. It does not have the support of donors or the international institutions the control. If funding were the main determinant of success, then Zimbabwe should have failed to achieve ML3 status in May 2024. That it succeeded highlights that the idea that funding is what makes or breaks ML3 success is more a limiting belief than a genuine obstacle for African NRAs. In fact, MCAZ would have achieved ML3 status in 2023 had the WHO not inexplicably stalled the process leading creating a delay of more than a year. WHO stalling led some African regulatory experts to wonder what was going on with the WHO. Why did WHO seem reluctant to certify one of Africa’s leading regulatory institutions to a ML3 status that many clearly believed was merited and long overdue?
A better indicator of potential success might be considered to be organizational culture, quality of leadership and commitment to institutional excellence as well as a can-do attitude. Zimbabwe did not have donors lining up with money for sundries and whatnot. What it did have was a proven leadership with a dodged commitment to regulatory excellence with a solid track record to show for it. According to Director General Rukwata, MCAZ achieved WHO ML3 without any external support or donor assistance by leveraging its track record in regulatory excellence for which it is globally recognized. Long before its ML3 certification, MCAZ had an impressive track record that included vaccine assessment in 2011. Its medicines laboratory was WHO prequalified in 2014 and it has received several ISO certifications. This is all in addition to being a major catalyst for regulatory excellence on the African continent including through the creation of the African Medicines Agency and for regulatory developments at a global level in the WHO. After all, Zimbabwe produced one of the key architects of the African Medicines Agency – Gugu Mahlangu. Her successor Richard Tendai Rukwata, the current MCAZ’s Director General and his team continue to be part of the effort to steer the creation of the African Medicines Agency and alongside their peers. They continue to be at the heart of African regulatory development.
Funding is important for regulatory institutions. However, Zimbabwe’s and Rwanda’s experiences highlight that on its own, it is not the only ingredient needed for NRAs to achieve regulatory excellence in Africa. There other major contributing factors. Ample resources and support do not necessarily amount to success whilst limited resources and support do not necessarily amount to failure. A country can have adequate funding and still fail. Another can have little and succeed. That is the most important lesson for African NRAs, most of whom face resource constraints. They will be better served by rejecting the limiting belief that unless donors are willing to invest millions in their agency, then they are surely doomed to fail. Such a belief undermines the development aspirations of African NRAs.
Regulatory excellence is more than about having meticulous systems and processes on paper if those are not applied into regulatory practice. Regulatory maturity and excellence is about practice. Small steps taken consistently in a painstaking process of critical self-evaluation, course correction and continuous improvement. It is built over time and anyone can achieve it.
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