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- History
- Overview of Drug Development
- Applications:
- IND: Investigational New Drug
(Application)
- NDA: New Drug Application
- Example of Post-marketing Action
- FDA/CDER Web Resources
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- 6 CENTERS
- CDER: Center for DRUGS
- CBER: Center for BIOLOGICS
- CDRH: Center for DEVICES
- CVM: Center for VETERINARY
Medicine
- CFSAN: Center for FOODS
- NCTR: National Center of Toxicology Research
- “Headquarters” and Field Offices
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- Office of New Drugs (OND)
- Grouped Based on Clinical Expertise
- Clinicians, pharm/tox, microbiologists
- Office of Pharmcoepidemiology and Statistical Sciences (OpaSS)
- Biostatistics and Drug Safety including post-marketing
- Office of Pharmaceutical Sciences (OPS)
- Chemistry, clinical pharmacology & biopharmaceutics, generic drugs,
testing & research
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- CDER assures that safe and effective drugs are available to the
American people
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- How Has Our Mission Changed Over Time?
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- Safety alone
- Safety & Efficacy
- Safety & Efficacy & Expanded Access
- (1938) Food, Drug & Cosmetic
Act
- (1962) Kefauver-Harris Amendment
- (1983) Orphan Drug Act
- (1984) Generics (Waxman-Hatch)
- Accelerated Approval (late 1980s, AIDS and other life threatening)
- Pediatric Initiatives (mid-90’s)
- Institute Review Timelines (mid-90’s: PDUFA, FDAMA)
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- IND is not a marketing application
- IND is a request for exemption from the federal statute which prohibits
transport of unapproved drugs in interstate commerce
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- IND contains:
- sufficient Chemistry, Manufacturing, and Control
- pre-clinical safety information and describes the proposed human trial
(Phase 1)
- Multi-disciplinary Review Team
- 30-Day Deadline for Decision
- Team Decision
- Yes? “Okay to Proceed” No? Clinical HOLD
- Communication to sponsor: What work must sponsor do to get HOLD lifted?
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- NDA is an application for marketing
- NDAs are submitted for:
- New molecular entity
- New formulation of previously approved drug
- New combination of two or more drugs
- New indication (claim) for already marketed drug
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- Clinicians
- Statisticians
- Clinical Pharmacologists
- Chemists
- Pharmacologists /Toxicologists
- Microbiologists
- Project Managers
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- Efficacy
- Appropriate Route? Schedule? Dose(s)?
- Onset-of-Action and Duration
- Endpoints (1o and 2o)
- Populations (geriatric, gender, pediatric, etc.)
- Safety
- Major toxicities identified? AE
profile
- Risk/Benefit determines Approval
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- Approval Letter: States that the drug is approved and includes the label
- Approvable Letter: Signals that the drug can be approved, after
correction of deficiencies, sometimes limited to labeling
- Not Approvable Letter: Lists the deficiencies and explains reasons for
non-approval
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- Communicates to the physician the information learned during drug
development
- Proposed by sponsor, reviewed and amended as necessary by FDA
- Dynamic document
- Sponsor may decide to include label in PDR
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- Clinical trial safety database too small to detect rare events (< 1 :
1,000)
- Sponsors are required to report postmarketing adverse events to FDA’s
Adverse Events Reporting System (AERS)
- Adverse events may also be reported directly to FDA’s Medwatch program
by health care professionals or consumers
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- Safety evaluators and epidemiologists in OPaSS monitor AERS for signals
of AEs not identified during clinical trials
- Drug reviewing divisions may institute labeling changes and other modes
of risk communication
- Dear Health Professional Letter
- Medguides
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- Terfenadine (SELDANE®) Antihistamine
- “NME” or New Molecular Entity
- US Approval (1985)
- Safety and efficacy data from clinical trials including several
thousand patients
- Supported by 4 yrs European experience
- 2nd generation: “Nonsedating”
claim was novel
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- 1983--First non-US cases of cardiac rhythm disturbances reported
- 1987--First US cases reported
- Rhythm “torsades-de-pointes” was unusual
- “Typical” patient was young (mid-30’s), female, and otherwise healthy
- 1989--Contribution of co-administered drugs (drug-drug interactions)
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- 1987 Label changed to include
cardiac arrhythmia (irregular heart beat), syncope (loss of
consciousness), and hypotension (low blood pressure) under AE’s
- 1989 More label changes to include potential drug interactions under
Warnings
- 1990 & 1996 Manufacturer required to send “Dear Doctor” letter to
all potential prescribers
- 1992 “Black Box” Warning added to label
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- 1996--Survey commissioned by Agency showed continued co-prescription of
contra-indicated medications
- 1998--Seldane voluntarily withdrawn from the Market
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- Is there something to be learned?
- Avoidable risk and unavoidable risk
- Scientific advances over time can lead to safer and more efficacious
drugs
- BUT--Limitations of pre-approval studies of drugs make post-marketing
surveillance important. For
reasons of public health:
- Medical professionals should read the label
- Medical professionals should report problems to FDA and/or
manufacturer
- Risk/Benefit balance
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- General Web Address:
- Approved Human Drug Information: www.fda.gov/cder/index
- Biologics/Vaccines:
- Adverse Event Reporting:
www.fda.gov/medwatch
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