The Role of the FDA Thomas Abrams, R.Ph., M.B.A. Division of Drug Marketing, Advertising, and Communications Food and Drug Administration October 26, 2004.

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Presentation transcript:

The Role of the FDA Thomas Abrams, R.Ph., M.B.A. Division of Drug Marketing, Advertising, and Communications Food and Drug Administration October 26, 2004

Examples of Violations Minimization of risk information Unsubstantiated claims of efficacy or safety Unsubstantiated comparative claims Promotion of unapproved uses of drugs

Diovan Warning Letter Sales aid Unsubstantiated effectiveness claim Diovan delays progression to end stage renal disease (ESRD) in type 2 diabetic patients with hypertension No substantial evidence; other drugs have substantial evidence for this claim

Diovan WL (cont.) Data on reducing urine albumin excretion; returning patients to normoalbuminuria Not correlated with preventing ESRD Presented with statements re: recommendations for using ARBs in hypertensive diabetics; diabetes and hypertension being the two leading causes of ESRD, etc.

Cubicin Warning Letter Journal advertisement and website Broadens the indication treatment of all infections caused by Staph aureus PI states it is not indicated for pneumonia In Phase 3 studies of community-acquired pneumonia, death rate was higher

Xeloda Warning Letter Sales aid Promotion of unapproved uses Failed to convey specific indications Mechanism of action claims

Xeloda Warning Letter Mechanism of action claims Prominently featured bar graph depicting distribution of TP and listing of various tissues types Claim above graph Because TP activity is higher in most tumor tissue than in normal tissue, final conversion of drug to 5-FU occurs preferentially in the tumor Relationship of mechanism of action to efficacy and safety outcomes has not been demonstrated

Pravachol Warning Letter DTC ads and labeling pieces Healthcare professional directed labeling pieces Promotion of unapproved uses

Pravachol: Promotion of Unapproved Uses Not indicated to reduce risk of strokes in patients who do not have clinically evident CHD Claims WORRIED ABOUT HAVING A HEART ATTACK? WORRIED ABOUT HAVING A STROKE? PRAVACHOL IS THE ONLY CHOLESTEROL LOWERING DRUG PROVEN TO HELP PROTECT 1ST AND 2ND HEART ATTACKS AND STROKE

DDMAC Information Web addresses: Warning and untitled letters : Posted on Guidances: Posted on Phone numbers: (301) or (301)