Download presentation
Presentation is loading. Please wait.
Published byRoger White Modified over 9 years ago
1
U of Arizona Innovation Conference 20 September 2011 Marlene E. Haffner, MD, MPH Haffner Associates, LLC
2
1800’s – US Customs Laboratories were established to administer the Import Drugs Act of 1848 --Mission – US should not be a dumping ground – purity and potency standards of the USP
3
Opium, morphine, heroin, and cocaine – no restrictions Cows weren’t tested for TB Victories over infectious diseases just beginning – Robert Koch; Louis Pasteur Agricultural to industrial economy
4
Prohibited Interstate Commerce of misbranded and adulterated foods and drugs and poisonous patent medicines Specific labeling – morphine, cannabis, chloral hydrate, … Did not address ◦ Food or drug standards Enforced by Division of Chemistry of the Department of Agriculture
5
1938 – Food, Drug, and Cosmetic Act ◦ Elixir of sulfanilamide ◦ Safety ◦ Safe tolerances 1962 Kefauver-Harris ◦ Thalidomide ◦ Efficacy and safety before marketing ◦ Adverse events Further improvements to safety in subsequent years Each added to the better and more costly products
6
8000 + dedicated and talented employees across the US ~ 50% in the Washington, DC area MDs, pharmacists, statisticians, nurses, dentists, policy analysts, PhDs, engineers, and more No one in the agency bites! They really wish to be helpful They are short staffed for the responsibilities they have Listen carefully to what you are told in meetings
7
Discovery Screening – including product characterization, formulation, PK, and drug disposition Pre-Clinical Toxicology testing IND Application Phases 1, 2, 3 – clinical trials New Drug Application (NDA)/ Biologics Licensing Agreement (BLA) Post marketing commitments (REMS – risk evaluation and mitigation strategy)
8
Often a stumbling block Acute and long term toxicity in animals – one rodent and one non- rodent ◦ Genetic ◦ Reproductive ◦ Carcinogenicity How is the drug absorbed, distributed, metabolized and excreted in animals
9
Apply to FDA to allow human exposure to the experimental drug – Go to FDA website http://www.FDA.gov/cder/guidance/index.htm http://www.FDA.gov/cder/guidance/index.htm Qualification Process for Drug Development tools (DDT) IND describes for what the product is being developed, safety issues as known, studies to be undertaken – assures safety for first in humans
10
Chances are you are not going to “cure” the disease How will you show efficacy? Is your endpoint a clinical endpoint, or a surrogate endpoint? Discuss with FDA. If you and FDA do not agree, why? Further discussion with FDA
11
MEET WITH FDA REVIEW DIVISION – EARLY AND OFTEN Phases 1, 2, 3 Phase 1 – ◦ usually healthy volunteers ◦ 10 – 80 – determine safety of dosage (12 – 18 mos) Phase 2 – ◦ 100 – 300 patients volunteers (24 mos) ◦ Dosage, adverse events (AEs), early efficacy Phase 3 – ◦ 1000 – 3000 patient volunteers ◦ confirm efficacy, ◦ monitor AEs (30 – 40 mos )
12
Begin 30 days following submission of IND providing no “clinical hold” 20 – 80 volunteers Duration: 1 year Determine bioavailability and safety Determine adverse events associated with increasing doses Gain early evidence of efficacy
13
Consult with FDA – often Assess efficacy in the disease or condition Monitor safety and AEs 100 – 300 patient volunteers Duration: 2 years Less than 33% of INDs survive Phase 2
14
Consult with FDA 1,000 – 3,000 patient volunteers Multiple testing sites Duration 3 – 4 years Confirm safety and efficacy – no drug is ever confirmed as completely safe
15
Formal proposal to FDA for approval of a new drug to be marketed in the US Must provide sufficient evidence for the FDA to determine: ◦ Benefits outweigh the risk of the product ◦ Drug is safe and effective for its intended use ◦ Proposed labeling is appropriate ◦ Manufacturing methods and controls maintain drug identity, strength, quality, purity and stability
16
Must assure continued safe and stable production Must continue to monitor AEs FDA may determine need for REMS – especially if study done on small number of patients Must report significant Adverse Events to FDA Adverse events may not be known for many years – e.g. VIOXX
17
Preclinical 3 – 6 years Phase 11 – 2 years Phase 22 – 3 years Phase 3 3 – 4 years ________________________________________ 9 – 15 years FDA review1 year
18
? Marlene E. Haffner, MD, MPH 301 984 5729 www.mhaffner.com mhaffner3@verizon.net
Similar presentations
© 2024 SlidePlayer.com. Inc.
All rights reserved.