Goals & Objectives Drug Development & the FDA Be able to describe Pharmacy 309 the major regulatory events in the drug development process the concepts of “safety” and “effectiveness” Tom Hazlet, Pharm.D., Dr.P.H. the importance of scientific methods in drug 616-2732 development thazlet@u...
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Outline An History of Disasters
History of FDA Regulations -- really fast; see Vaccine Act 1813 FDA web site fraudulent smallpox vaccines Drug Approval Process Food & Drugs Act 1906 Upton Sinclair, The Jungle Safety & Effectiveness truthful label (strength & purity) International Conference on Harmonisation Food, Drug & Cosmetic Act 1938 Questions any time “elixir” of sulfanilamide safety, IND, NDA, 60-day review
3 4 History (2) History (3)
Durham-Humphrey Amendment 1951 Orphan Drug Act 1983 collateral measures necessary for “safe” use rare diseases “Caution: Federal law prohibits …” tax break; patent protection Rx to OTC switch ANDA 1984 Kefauver-Harris Amendment 1962 bioequivalence for generic drugs thalidomide; Bay of Pigs Expedited Approval, Serious & Life-Threatening effectiveness; 180 day NDA review Diseases (AIDS) 1994 [“Subpart E”] Phase 4
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History (4) History Summary
1992 Prescription Drug User Fee Act 1994 Dietary Supplement Health And Education Act truthful label (strength & purity) 1997 Food And Drug Administration Modernization Act safety under conditions of intended use reauthorizes PDUFA, advertising of unapproved uses of approved drugs and devices, and regulate health claims for effectiveness under conditions of intended foods, compounding use 2000 Washington Legal Foundation [65 Federal Register 14286] adequate directions for use 2002 Supreme Court ruling on First Amendment violations in FDAMA 2003 PDUFA 3 authorizes Phase 4 studies for certain drugs
7 8 Other “Interesting” Web Sites for more information see http://www.fda.gov/fdac/special/newdrug/ndd_toc.html FDA -- www.fda.gov PhRMA -- www.phrma.org Public Citizen -- www.citizen.org FDA Consumer From Test Tube To Patient: New Drug Development in the United States Second Edition January 1995
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Idea Drug Development Phases objective: synthesis, isolation of active idea compound “preclinical” modes of discovery “combinatorial” chemistry, Investigational New Drug Application (IND) Affymax “traditional sources” -- Phase 1 Shaman Pharmaceuticals Phase 2 human genome project and “antisence” drugs Phase 3 targeted discovery New Drug Application (NDA) dumb luck Phase 4
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types of studies objective: pharmacology & toxicology in animals purification types of studies identification of impurities acute toxicity computer simulations sub-acute toxicity ( <3 months) validation, validation, validation chronic toxicity (6-18 time: years months) reproductive, teratology, survival: 500,000 →5,000 mutagenicity
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Pre-Clinical (2) Phase 1
LD50 Tissue culture methods objective: safety, dose ranging, pk/pd in ADME “normals” Absorption, Distribution, Metabolism, Excretion types of studies study size: hundreds of animals first exposure in humans time: 6.5 years single dose tolerability survival: of 5000 pre-clinical → 5 INDs multiple dose tolerability dose-ranging based on animal doses
15 16 Phase 1 (2) Phase 1 Failures
study size: 20-80 pre-clinical animal models ≠ behavior in humans time: 2-3 years inadequate preclincal data change in drug formulation between time of pre- survival clinical and clinical testing 80% proceed to Phase 2 pk/pd relationships 5 → 4 poorly designed clinical studies drug too toxic in humans
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Phase 2 Clinical Studies Phase 3 Clinical Studies
objective: testing an hypothesis of no difference; objectives: testing an hypothesis of no safety difference; safety targeted patients types of studies: small controlled trials in “well controlled” studies patients placebo-controlled dose ranging double blinded multi-centered (bias) study size: 100-300 size: 100’s - 1000’s time: months - 2 years time: 1-4 years survival: 2 go on to Phase 3 survival: 1 19 20 Phase 2 & 3 Failures
infrequent adverse reactions observed; but New Drug Application (CDER, CBER) ... manufacturing facility approval included in drug-drug interactions application review drug-disease interactions in ill patients Product License Application (CBER) facility approval separate from PLA genetic – pharmacogenomics Biologics License Application – “well characterized effectiveness insufficient (20%) biologicals” economic (24%)
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Phase 4 NDA | PLA
FDA has 180 days for review post marketing surveillance FDA judges both benefit (efficacy) and risks negotiation (safety) accelerated approval for therapies for serious and one specific indication is approved life-threatening diseases (Subpart E) Average drug approval story targeted studies for cause 1:350,000 approved other stages of diseases, other sub-populations, cost ~ $500 million drug-drug interactions, “off-label” uses time ~ 15 years new mandates under PDUFA3
23 24 International Conference on Safety & Efficacy Harmonisation
Under conditions of intended use US, European Union & Japan limitations of “well controlled” studies efficacy (human clinical trials) relevance of clinical trial information to alternate safety (animal pharmacology / toxicology) (“off label”) uses quality (manufacturing) “promotion” of off label uses regulatory communication domestic (dis)incentives to conduct studies of alternate uses
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Is Something Missing? Summing Up
Drug price where was the science? phases of drug development major regulatory events questions
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