PANEL QUESTIONS
FOR P020012
ARTECOLL
PMMA/COLLAGEN IMPLANT
1. The
degree of nasolabial fold wrinkle severity 6 months after treatment was
statistically significantly (p < 0.001) better for Artecoll than Control
patients with a difference of 0.77 points on the FFA scale, (unadjusted
results). Please discuss the
effectiveness of Artecoll treatment for wrinkles in the nasolabial fold area of
the face.
2. The
differences in wrinkle severity at 6 months after Artecoll and Control
treatments for glabellar folds (0.02 FFA points), upper lip lines (-0.14 FFA
points) and mouth corners (0.17 FFA
points) were not statistically significant, (unadjusted data). Please comment on the effectiveness of
Artecoll concerning:
a. whether the proposed product indication for use (i.e.,
“Artecoll implant is indicated for the correction of contour deficiencies of
soft tissue”) is appropriate; and
b. whether product approval could be considered for treatment of
wrinkles solely in the nasolabial fold area of the face.
3. Comparing the types and duration of
adverse events for Artecoll treated patients who were followed for 12 months to
the Control group that was followed for only 6 months presents a
challenge. However, considering that
Artecoll benefit is related to an improvement in a patient's aesthetic
appearance and that the majority of adverse events impacted the aesthetic
appearance of a patient, please discuss whether the safety profile of Artecoll
demonstrates an absence of unreasonable risk.
4. Do the data in
P020012 demonstrate that there is reasonable assurance that in a significant
portion of the target population, Artecoll for its intended uses and conditions
of use will provide clinically significant results, when accompanied by
adequate directions for use and warnings against unsafe use?
5. If the Panel
recommends approval of the Artecoll PMMA / collagen implant, please discuss
whether the conditions of approval should include a post-approval study to
collect additional long term safety information. If you believe such a study is appropriate, please provide
recommendations on study duration and the number of patients that should be followed.