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Use of Unapproved Products, Off-Label Use, and Black-Box Warning
Use of Unapproved Products, Off-Label Use, and Black-Box Warning ... A Variation of Newton’s Third Law or the Practical Application of the Rule of Unin- tended Consequences … Considerations in Military Operational Medicine Jerome F. Pierson, RPh, PhD Executive Editors Note: As multiple medical research and development efforts (both in SOF and in conventional research units) offer new drugs and medical equipment to the battlefield, we need to understand the rules of engagement for use, which, are dif- ferent for individual providers versus military heath care systems. ABSTRACT This article discusses the regulatory requirements for the use of unapproved drugs and off-label use of drugs and provides specific examples for military medicine. Additionally, it explains issues associated with standardization by the Service as a designated set, kit, or outfit as opposed to a general guidance. The former situation can be interpreted as a de facto policy whereas the latter is an adaptation of practice of medicine. Recent news stories brought to light the challenges assaulted from many sides to include consumer groups who facing military medicine in an environment where dramatic at times advocate for greater safety and at other times de- life-saving measures have become the expected rather then mand quicker access to therapeutic breakthroughs as well the exception.1,2 However, many of these same life-saving as the pharmaceutical industry which faces demands from measures have the potential to place a practitioner in situa- stockholders for return on investment. Reliance upon re- tions of “damned if you do, damned if you don’t” with re- sults from controlled clinical trials is problematic in that it gard to adherence to various regulatory and legal hurdles. -
Free Executive Summary
Giving Full Measure to Countermeasures: Addressing Problems in the DoD Program to Develop Medical Countermeasures Against Biological Warfare Agents http://www.nap.edu/catalog/10908.html Committee on Accelerating the Research, Development, and Acquisition of Medical Countermeasures Against Biological Warfare Agents Medical Follow-up Agency and Board on Life Sciences Lois M. Joellenbeck, Jane S. Durch, and Leslie Z. Benet, Editors Copyright © National Academy of Sciences. All rights reserved. Giving Full Measure to Countermeasures: Addressing Problems in the DoD Program to Develop Medical Countermeasures Against Biological Warfare Agents http://www.nap.edu/catalog/10908.html THE NATIONAL ACADEMIES PRESS 500 Fifth Street, N.W. Washington, DC 20001 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the Na- tional Academy of Sciences, the National Academy of Engineering, and the Institute of Medi- cine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. Support for this project was provided by Contract No. DAMD17-02-C-0099 between the National Academy of Sciences and the U.S. Army. The views presented in this report are those of the Institute of Medicine and National Research Council Committee on Accelerat- ing the Research, Development, and Acquisition of Medical Countermeasures Against Bio- logical Warfare Agents and are not necessarily those of the funding agencies. Library of Congress Cataloging-in-Publication Data Giving full measure to countermeasures : addressing problems in the DOD program to de- velop medical countermeasures against biological warfare agents / Committee on Acceler- ating the Research, Development, and Acquisition of Medical Countermeasures against Bio- logical Warfare Agents, Medical Follow-up Agency and Board on Life Sciences ; Lois M. -
Medical Management of Biologic Casualties Handbook
USAMRIID’s MEDICAL MANAGEMENT OF BIOLOGICAL CASUALTIES HANDBOOK Fourth Edition February 2001 U.S. ARMY MEDICAL RESEARCH INSTITUTE OF INFECTIOUS DISEASES ¨ FORT DETRICK FREDERICK, MARYLAND 1 Sources of information: National Response Center 1-800-424-8802 or (for chem/bio hazards & terrorist events) 1-202-267-2675 National Domestic Preparedness Office: 1-202-324-9025 (for civilian use) Domestic Preparedness Chem/Bio Help line: 1-410-436-4484 or (Edgewood Ops Center - for military use) DSN 584-4484 USAMRIID Emergency Response Line: 1-888-872-7443 CDC'S Bioterrorism Preparedness and Response Center: 1-770-488-7100 John's Hopkins Center for Civilian Biodefense: 1-410-223-1667 (Civilian Biodefense Studies) An Adobe Acrobat Reader (pdf file) version and a Palm OS Electronic version of this Handbook can both be downloaded from the Internet at: http://www.usamriid.army.mil/education/bluebook.html 2 USAMRIID’s MEDICAL MANAGEMENT OF BIOLOGICAL CASUALTIES HANDBOOK Fourth Edition February 2001 Editors: LTC Mark Kortepeter LTC George Christopher COL Ted Cieslak CDR Randall Culpepper CDR Robert Darling MAJ Julie Pavlin LTC John Rowe COL Kelly McKee, Jr. COL Edward Eitzen, Jr. Comments and suggestions are appreciated and should be addressed to: Operational Medicine Department Attn: MCMR-UIM-O U.S. Army Medical Research Institute of Infectious Diseases (USAMRIID) Fort Detrick, Maryland 21702-5011 3 PREFACE TO THE FOURTH EDITION The Medical Management of Biological Casualties Handbook, which has become affectionately known as the "Blue Book," has been enormously successful - far beyond our expectations. Since the first edition in 1993, the awareness of biological weapons in the United States has increased dramatically. -
These Highlights Do Not Include All the Information Needed to Use ANTHIM Safely and Effectively. See Full Prescribing Information for ANTHIM
ANTHIM - obiltoxaximab solution Elusys Therapeutics, Inc. ---------- HIGHLIGHTS OF PRESCRIBING INFORMATION These highlights do not include all the information needed to use ANTHIM safely and effectively. See full prescribing information for ANTHIM. ANTHIM® (obiltoxaximab) injection, for intravenous use Initial U.S. Approval: 2016 WARNING: HYPERSENSITIVITY and ANAPHYLAXIS See full prescribing information for complete boxed warning. Hypersensitivity reactions, including anaphylaxis, have been reported during ANTHIM infusion (5.1) ANTHIM should be administered in monitored settings by personnel trained and equipped to manage anaphylaxis (1.2, 2.4, 5.1) Stop ANTHIM infusion immediately and treat appropriately if hypersensitivity or anaphylaxis occurs (2.4, 5.1) INDICATIONS AND USAGE ANTHIM® is a monoclonal antibody directed against the protective antigen of Bacillus anthracis. It is indicated in adult and pediatric patients for treatment of inhalational anthrax due to B. anthracis in combination with appropriate antibacterial drugs and, for prophylaxis of inhalational anthrax when alternative therapies are not available or are not appropriate. (1.1) Limitations of Use ANTHIM should only be used for prophylaxis when its benefit for prevention of inhalational anthrax outweighs the risk of hypersensitivity and anaphylaxis. (1.2, 5.1) The effectiveness of ANTHIM is based solely on efficacy studies in animal models of inhalational anthrax. (1.2, 14) There have been no studies of the safety or pharmacokinetics (PK) of ANTHIM in the pediatric population. Dosing in pediatric patients was derived using a population PK approach. (1.2, 8.4) ANTHIM does not have direct antibacterial activity. ANTHIM should be used in combination with appropriate antibacterial drugs. (1.2) ANTHIM is not expected to cross the blood-brain barrier and does not prevent or treat meningitis. -
The President
3 1999 Compilation and Parts 100±102 Revised as of January 1, 2000 The President Published by: Office of the Federal Register National Archives and Records Administration A Special Edition of the Federal Register VerDate 11-MAY-2000 08:53 Aug 11, 2000 Jkt 190004 PO 00000 Frm 00001 Fmt 8091 Sfmt 8091 Y:\SGML\190004F.XXX pfrm07 PsN: 190004F U.S. GOVERNMENT PRINTING OFFICE WASHINGTON: 2000 For sale by U.S. Government Printing Office Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402±9328 ii VerDate 11-MAY-2000 08:53 Aug 11, 2000 Jkt 190004 PO 00000 Frm 00002 Fmt 8092 Sfmt 8092 Y:\SGML\190004F.XXX pfrm07 PsN: 190004F Table of Contents Page List of Title 3 Compilations ....................................................................... iv Explanation of the Code of Federal Regulations ........................................... v Explanation of This Title ........................................................................... ix How To Cite This Title ............................................................................... xi Title 3 ......................................................................................................... xiii 1999 CompilationÐPresidential Documents .................................... 1 Chapter IÐExecutive Office of the President .................................. 325 Title 3 Finding Aids .................................................................................... 335 Tables ............................................................................................. -
Medical Management of Biological Casualties Handbook
USAMRIID’s MEDICAL MANAGEMENT OF BIOLOGICAL CASUALTIES HANDBOOK Sixth Edition April 2005 U.S. ARMY MEDICAL RESEARCH INSTITUTE OF INFECTIOUS DISEASES FORT DETRICK FREDERICK, MARYLAND Emergency Response Numbers National Response Center: 1-800-424-8802 or (for chem/bio hazards & terrorist events) 1-202-267-2675 National Domestic Preparedness Office: 1-202-324-9025 (for civilian use) Domestic Preparedness Chem/Bio Helpline: 1-410-436-4484 or (Edgewood Ops Center – for military use) DSN 584-4484 USAMRIID’s Emergency Response Line: 1-888-872-7443 CDC'S Emergency Response Line: 1-770-488-7100 Handbook Download Site An Adobe Acrobat Reader (pdf file) version of this handbook can be downloaded from the internet at the following url: http://www.usamriid.army.mil USAMRIID’s MEDICAL MANAGEMENT OF BIOLOGICAL CASUALTIES HANDBOOK Sixth Edition April 2005 Lead Editor Lt Col Jon B. Woods, MC, USAF Contributing Editors CAPT Robert G. Darling, MC, USN LTC Zygmunt F. Dembek, MS, USAR Lt Col Bridget K. Carr, MSC, USAF COL Ted J. Cieslak, MC, USA LCDR James V. Lawler, MC, USN MAJ Anthony C. Littrell, MC, USA LTC Mark G. Kortepeter, MC, USA LTC Nelson W. Rebert, MS, USA LTC Scott A. Stanek, MC, USA COL James W. Martin, MC, USA Comments and suggestions are appreciated and should be addressed to: Operational Medicine Department Attn: MCMR-UIM-O U.S. Army Medical Research Institute of Infectious Diseases (USAMRIID) Fort Detrick, Maryland 21702-5011 PREFACE TO THE SIXTH EDITION The Medical Management of Biological Casualties Handbook, which has become affectionately known as the "Blue Book," has been enormously successful - far beyond our expectations. -
Executive Order 13139—Improving Health Protection of Military
Administration of William J. Clinton, 1999 / Sept. 30 1875 (7) Department of Transportation; continue to serve after the expiration of their (8) Environmental Protection Agency; term until a successor is appointed. A mem- (9) Office of Management and Budget; ber appointed to fill an unexpired term will (10) National Security Council; be appointed for the remainder of such (11) Office of National Drug Control Pol- term.'' icy; Sec. 9. This order shall be effective Sep- (12) Council on Environmental Quality; tember 30, 1999. (13) Office of Cabinet Affairs; William J. Clinton (14) National Economic Council; (15) Domestic Policy Council; and The White House, (16) United States Coast Guard.'' September 30, 1999. Sec. 7. Executive Order 12367, as amend- ed, is further amended as follows: [Filed with the Office of the Federal Register, (a) in section 1, the text ``the director of 9:23 a.m., October 1, 1999] the International Communication Agency,'' NOTE: This Executive order was published in the is deleted; Federal Register on October 4. (b) in section 2, delete the first sentence and insert in lieu thereof ``The Committee shall advise, provide recommendations to, Executive Order 13139ÐImproving and assist the President, the National En- Health Protection of Military dowment of the Arts, the National Endow- Personnel Participating in Particular ment for the Humanities, and the Institute Military Operations of Museum and Library Services on matters September 30, 1999 relating to the arts and the humanities. The Committee shall initiate and assist -
Pulmonary Delivery of Biological Drugs
pharmaceutics Review Pulmonary Delivery of Biological Drugs Wanling Liang 1,*, Harry W. Pan 1 , Driton Vllasaliu 2 and Jenny K. W. Lam 1 1 Department of Pharmacology and Pharmacy, Li Ka Shing Faculty of Medicine, The University of Hong Kong, 21 Sassoon Road, Pokfulam, Hong Kong, China; [email protected] (H.W.P.); [email protected] (J.K.W.L.) 2 School of Cancer and Pharmaceutical Sciences, King’s College London, 150 Stamford Street, London SE1 9NH, UK; [email protected] * Correspondence: [email protected]; Tel.: +852-3917-9024 Received: 15 September 2020; Accepted: 20 October 2020; Published: 26 October 2020 Abstract: In the last decade, biological drugs have rapidly proliferated and have now become an important therapeutic modality. This is because of their high potency, high specificity and desirable safety profile. The majority of biological drugs are peptide- and protein-based therapeutics with poor oral bioavailability. They are normally administered by parenteral injection (with a very few exceptions). Pulmonary delivery is an attractive non-invasive alternative route of administration for local and systemic delivery of biologics with immense potential to treat various diseases, including diabetes, cystic fibrosis, respiratory viral infection and asthma, etc. The massive surface area and extensive vascularisation in the lungs enable rapid absorption and fast onset of action. Despite the benefits of pulmonary delivery, development of inhalable biological drug is a challenging task. There are various anatomical, physiological and immunological barriers that affect the therapeutic efficacy of inhaled formulations. This review assesses the characteristics of biological drugs and the barriers to pulmonary drug delivery. -
125509Orig1s000
CENTER FOR DRUG EVALUATION AND RESEARCH APPLICATION NUMBER: 125509Orig1s000 ADMINISTRATIVE and CORRESPONDENCE DOCUMENTS ACTION PACKAGE CHECKLIST APPLICATION INFORMATION1 If NDA, Efficacy Supplement Type: BLA #125509 BLA Supplement # (an action package is not required for SE8 or SE9 supplements) Proprietary Name: Anthim Applicant: Elusys Therapeutics, Inc. Established/Proper Name: obiltoxaximab Agent for Applicant (if applicable): Dosage Form: injection RPM: Jane A. Dean, RN, MSN Division: Division of Anti-Infective Products For ALL 505(b)(2) applications, two months prior to EVERY action: NDA Application Type: 505(b)(1) 505(b)(2) Efficacy Supplement: 505(b)(1) 505(b)(2) Review the information in the 505(b)(2) Assessment and submit the draft2 to CDER OND IO for clearance. BLA Application Type: 351(k) 351(a) Check Orange Book for newly listed patents and/or Efficacy Supplement: 351(k) 351(a) exclusivity (including pediatric exclusivity) No changes New patent/exclusivity (notify CDER OND IO) Date of check: Note: If pediatric exclusivity has been granted or the pediatric information in the labeling of the listed drug changed, determine whether pediatric information needs to be added to or deleted from the labeling of this drug. Actions Proposed action AP TA CR User Fee Goal Date is 3/20/16 Previous actions (specify type and date for each action taken) None If accelerated approval or approval based on efficacy studies in animals, were promotional materials received? Note: Promotional materials to be used within 120 days after approval must have been Received submitted (for exceptions, see http://www fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guida nces/ucm069965.pdf). -
(HE) Technologies in the Military Be Ethically Assessed? Philip Andrew Taraska
Duquesne University Duquesne Scholarship Collection Electronic Theses and Dissertations Spring 1-1-2017 How Can the Use of Human Enhancement (HE) Technologies in the Military Be Ethically Assessed? Philip Andrew Taraska Follow this and additional works at: https://dsc.duq.edu/etd Recommended Citation Taraska, P. A. (2017). How Can the Use of Human Enhancement (HE) Technologies in the Military Be Ethically Assessed? (Doctoral dissertation, Duquesne University). Retrieved from https://dsc.duq.edu/etd/148 This One-year Embargo is brought to you for free and open access by Duquesne Scholarship Collection. It has been accepted for inclusion in Electronic Theses and Dissertations by an authorized administrator of Duquesne Scholarship Collection. For more information, please contact [email protected]. HOW CAN THE USE OF HUMAN ENHANCEMENT (HE) TECHNOLOGIES IN THE MILITARY BE ETHICALLY ASSESSED? A Dissertation Submitted to the McAnulty College and Graduate School of Liberal Arts Duquesne University In partial fulfillment for the requirements for the degree of Doctor of Philosophy By Philip Andrew Taraska May 2017 Copyright by Philip Andrew Taraska 2017 HOW CAN THE USE OF HUMAN ENHANCEMENT (HE) TECHNOLOGIES IN THE MILITARY BE ETHICALLY ASSESSED? By Philip Andrew Taraska Approved April 5, 2017 ________________________ ________________________ Henk ten Have, MD, PhD Gerard Magill, PhD Director, Center for Healthcare Ethics The Vernon F. Gallagher Chair Professor of Healthcare Ethics Professor of Healthcare Ethics (Committee Chair) (Committee Member) -
Ride'n Drive on Government Waste
NEWS Table 1 Anthrax countermeasures in development Company Product Stage of development BARDA contract Human Genome Sciences ABthrax (raxibacumab), a human mAb against anthrax protective Biologic license $151 million antigen (PA) application Emergent BioSolutions AV-7909, a combination of BioThrax (aluminum-adsorbed cell- Phase 2 $447.6 million free filtrates of unencapsulated Bacillus anthracis) and Coley Pharmaceutical’s VaxImmune (an unmethylated CpG-motif oligonucleotide that acts as an agonist of Toll-like receptor 9) Anthrax immune globulin (AIGIV), polyclonal antibodies raised Phase 1/2 $13 million against BioThrax Elusys Therapeutics Anthim (ETI-204), a humanized mAb against PA Phase 1 Up to $143 million PharmAthene SparVax, an injectable rPA absorbed on to hydrogel Phase 2 $3.9 million NIAID DynPort Vaccine Anthrax vaccine, an injectable rPA vaccine Phase 1 NA Medarex, a subsidiary of Valortim (MDX-1303), a fully human mAb against PA Phase 1 $1 million from the US Department Bristol-Myers Squibb of Defense (DoD) payable to partner PHarmAthene Advanced Life Sciences Restanza, a once-daily oral ketolide cethromycin that inhibits Preclinical $3.8 million from DoD B. anthracis protein synthesis Sources: Sagient Research, BiomedTracker and BARDA. NA, Not available. Even with government support, PharmAthene For the US government, anthrax treatment procurement contract with the Centers for and other companies working under biodefense remains a critical element in its biodefense Disease Control and Prevention of Atlanta, contracts face the stark reality of drug develop- strategies. Emergent Solutions currently Georgia, to manufacture and deliver 14.5 ment: 30% of all candidates that reach phase manufactures the only approved vaccine for million doses of BioThrax for the strategic 3 clinical trials within the eight-year BARDA anthrax based on protective antigen (PA). -
JOHN DOE #1, Et Al, ) ) Plaintiffs, ) ) V
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _________________________________ ) JOHN DOE #1, et al, ) ) Plaintiffs, ) ) v. ) Civil Action No. 03-707 (EGS) ) DONALD H. RUMSFELD, et al ) ) Defendants. ) _________________________________) MEMORANDUM OPINION Plaintiffs, members of the active duty and selected National Guardsmen components of the Armed Forces as well as civilian contract employees of the Department of Defense ("DoD") who have submitted or have been instructed to submit to anthrax vaccinations without their consent pursuant to the Anthrax Vaccine Immunization Program ("AVIP"), commenced this action against the Secretary of Defense (Donald Rumsfeld), the Secretary of Health and Human Services (Tommy Thompson), and the Commissioner of the Food and Drug Administration (Mark McClellan). Because plaintiffs maintain that Anthrax Vaccine Adsorbed ("AVA") is an experimental drug unlicensed for its present use and that the AVIP violates federal law (10 U.S.C. § 1107), a Presidential Executive Order (Executive Order 13139), and the 1 DoD's own regulations (DoD Directive 6200.2), plaintiffs ask that in the absence of a presidential waiver the Court enjoin the DoD from inoculating them without their informed consent. Plaintiffs allege three causes of action against defendants: (1) violation of the Administrative Procedure Act ("APA") by defendant DoD based on the DoD's failure to follow federal law, a presidential executive order, and DoD directive with respect to its AVIP; (2) violation of the APA by defendant DoD for its intent to inoculate plaintiffs with an unlicensed drug that is unapproved for its intended use; and (3) violation of the APA by the defendants' alteration of the licensed Federal Drug Administration ("FDA")- approved schedule of vaccination which rendered AVA a drug unapproved for its intended use.1 Defendants DoD and FDA maintain that the issues plaintiffs present are non-justiciable and that plaintiffs fail to present an evidentiary basis sufficient to support standing at the preliminary injunction stage.