The road to market implantable drug delivery systems: a review on US FDA’s regulatory framework and quality control requirements

Abstract

The scope of Implantable Drug Delivery Systems (IDDSs) comprehends a variety of sterile therapeutic implements placed inside the body to exert a certain therapeutic action for extended duration. They are classified under different categories from pharmaceutical science and regulatory perspectives. The novelty and variety of IDDSs prevent the application of a uniform regulation for all IDDS products; therefore, sponsors face regulatory challenges to register and market their products. This review investigates pharmaceutical science literature and the United States Food and Drug Administration (US FDA) regulatory guidance to find how any IDDS is classified, regulated, and introduced in the market. The regulatory classification of any IDDS, as a ‘drug’, ‘medical device’ or a ‘combination product’, is the cornerstone in determining the regulatory pathway, which decides the quality control requirements preceding the marketing approval. IDDSs are generally recognized as combination products as they consist of two or more regulated components (drugs, medical devices or biological products) combined prior to use to function as a single entity. Although robust and defined US FDA regulatory pathways exist for each component independent of one another, the regulatory pathways for combination products are less formalized.     

Decision rules and associated sample size planning for regional approval utilizing multiregional clinical trials

Multiregional clinical trials provide the potential to make safe and effective medical products simultaneously available to patients globally. As regulatory decisions are always made in a local context, this poses huge regulatory challenges. In this article we propose two conditional decision rules that can be used for medical product approval by local regulatory agencies based on the results of a multiregional clinical trial. We also illustrate sample size planning for such trials.     

美国医疗器械上市前审批制度介绍及其对我国的启示

目的：通过介绍美国高风险医疗器械产品的上市前审批(PMA)制度，希望对我国医疗器械审评审批制度的完善提供参考。方法：从申报方式、审评流程、沟通交流渠道等方面对美国高风险医疗器械产品的PMA制度进行介绍，并就事前沟通机制、模块化PMA申报路径和缴费流程前置等提出优化建议。结果与结论：美国PMA制度是医疗器械上市申报方式中最为严格的制度。其中，模块化PMA申报路径、多种交流渠道和缴费前置的申报流程均对我国医疗器械审评审批制度有较大参考价值。建议我国监管机构能够借鉴美国医疗器械PMA制度的有益做法，对我国监管体系进行不断优化和完善。     

Impact of pharmacometrics on drug approval and labeling decisions: A survey of 42 new drug applications

The value of quantitative thinking in drug development and regulatory review is increasingly being appreciated. Modeling and simulation of data pertaining to pharmacokinetic, pharmacodynamic, and disease progression is often referred to as the pharmacometrics analyses. The objective of the current report is to assess the role of pharmacometrics at the US Food and Drug Administration (FDA) in making drug approval and labeling decisions. The New Drug Applications (NDAs) submitted between 2000 and 2004 to the Cardio-renal, Oncology, and Neuropharmacology drug products divisions were surveyed. For those NDA reviews that included a pharmacometrics consultation, the clinical pharmacology scientists ranked the impact on the regulatory decision(s). Of about a total of 244 NDAs, 42 included a pharmacometrics component. Review of NDAs involved independent, quantitative evaluation by FDA pharmacometricians, even when such analysis was not conducted by the sponsor. Pharmacometric analyses were pivotal in regulatory decision making in more than half of the 42 NDAs. Of the 14 reviews that were pivotal to approval related decisions, 5 identified the need for additional trials, whereas 6 reduced the burden of conducting additional trials. Collaboration among the FDA clinical pharmacology, medical, and statistical reviewers and effective communication with the sponsors was critical for the impact to occur. The survey and the case studies emphasize the need for early interaction between the FDA and sponsors to plan the development more efficiently by appreciating the regulatory expectations better.     

Nanomedicines: From Bench to Bedside and Beyond

Advancing nanomedicines from concept to clinic requires integration of new science with traditional pharmaceutical development. The medical and commercial success of nanomedicines is greatly facilitated when those charged with developing nanomedicines are cognizant of the unique opportunities and technical challenges that these products present. These individuals must also be knowledgeable about the processes of clinical and product development, including regulatory considerations, to maximize the odds for successful product registration. This article outlines these topics with a goal to accelerate the combination of academic innovation with collaborative industrial scientists who understand pharmaceutical development and regulatory approval requirements—only together can they realize the full potential of nanomedicines for patients.     

Regulatory Decision‐Making in the United States Based on a Single Pivotal Clinical Study: Principles and Precedents

The concept of regulatory approval in the United States based on substantial evidence from a single adequate and well‐controlled clinical study is not a new or radical concept. Appropriate discussions and developmental milestone meetings between sponsors and U.S. Food and Drug Administration (FDA) have provided a means to reach a shared understanding of specific situations where a single adequate and well‐controlled study may yield substantial evidence to enable a regulatory approval in the United States. FDA's issuance of its final guidance document on evidence of clinical effectiveness brought additional attention to this topic. The basis in US law, regulations, and guidance for regulatory decision making based on a single adequate and well‐controlled trial is reviewed. Further, to illustrate practical implementation of these provisions, this paper summarizes a number of examples of situations in which a single clinical study was the basis for approval by FDA. These examples were grouped into categories for the purpose of illuminating the patterns of established regulatory precedents. Sufficient examples were available to show logical groupings of experiences to demonstrate circumstances in drug development where there are reasonable precedents for use of a single adequate and well‐controlled trial for regulatory decision making. Regulatory decision‐making based on a single adequate and well‐controlled trial appears to be a well‐accepted approach to attaining approval for 1) use of a product for a new indication where patients attain a significant reduction in morbidity or mortality (or both) with treatment with a drug that was previously approved for a related indication, 2) a new dosage regimen for a previously approved product, and 3) a Supplemental Application seeking traditional approval of a product based on confirmatory evidence of clinical efficacy for a product subject to accelerated approval. Not surprisingly, reliance on a single adequate and well‐controlled trial as the basis for approval of an original NDA or BLA for a new chemical entity or new biologic has been infrequent and typically limited to special situations where patients are refractory to other available therapies or where no alternative therapy exists. The examples presented here illustrate a range of practical experiences where a single adequate and well‐controlled trial has successfully provided the primary basis for regulatory approval in the United States. This information should assist developers of drugs and biologics in their consideration of alternative approaches to development and registration of new products and new indications.     

Predictors of orphan drug approval in the European Union

Objective To encourage the development of drugs for rare diseases, orphan drug legislation has been introduced in the USA (1983) and in the EU (2000). Recent literature discusses factors that may influence the development of new orphan medicinal products in the EU. This study aims to identify predictors for successful marketing authorisation of potential orphan drugs in the EU. Methods A comparison between randomly selected authorised and a matched sample of not-yet-authorised orphan drug designations has been performed. Determinants in the study included characteristics of the indication, of the product and of the sponsor. Data were collected from the public domain only. Results Orphan drug approval was strongly associated with previous experience of the sponsor in obtaining approval for another orphan drug (OR = 17.3, 95% CI = 5.6–53.1). Furthermore, existing synthetic entities compared to biotechnology products tended to have a higher likelihood of reaching approval status (OR = 3.9, 95% CI = 0.9–16.6). Conclusion This study showed that experience of a company in developing orphan drugs is an important predictor for subsequent authorisation of other orphan drugs. The same applies for existing (synthetic) molecules, for which much knowledge is available. Further research should be directed towards studying the quality of the clinical development program of those designated orphan medicinal products not reaching approval status.     

英国脱欧后药品医疗器械监管体制机制探究

目的： 了解脱欧后英国在药品和医疗器械监管的最新进展,为开展双边贸易合作和监管科学研究提供有益参考。方法：查阅英国药品与健康产品管理局网站信息和其发布的药品医疗器械监管指南文件,搜集英国脱欧后药品医疗器械监管体制机制主要改革情况及现状,包括其机构职责、组织架构、法律依据、监管机制等。结果与结论：英国脱欧后,确立了新的中央层面的药品医疗器械监管机构,相应的监管法律法规、监管机制也进行了适应脱欧的调整。然而,研究发现,作为脱欧协议一项重要内容, 《北爱尔兰议定书》的实施,使得北爱尔兰地区的药品医疗器械监管不同于大不列颠,仍适用于欧盟法规。另一方面,一系列药品、医疗器械监管制度的改革体现了英国科学、灵活的监管理念,例如引入欧盟审批程序的认可模式、境外多中心数据互认和协作审批,提高了审评审批效率和质量,值得学习和借鉴。     

Application of Pharmacokinetics and Pharmacodynamics in Product Life Cycle Management. A Case Study with a Carbidopa-Levodopa Extended-Release Formulation

Increasing costs in discovering and developing new molecular entities and the continuing debate on limited company pipelines mean that pharmaceutical companies are under significant pressure to maximize the value of approved products. Life cycle management in the context of drug development comprises activities to maximize the effective life of a product. Life cycle approaches can involve new formulations, new routes of delivery, new indications or expansion of the population for whom the product is indicated, or development of combination products. Life cycle management may provide an opportunity to improve upon the current product through enhanced efficacy or reduced side effects and could expand the therapeutic market for the product. Successful life cycle management may include the potential for superior efficacy, improved tolerability, or a better prescriber or patient acceptance. Unlike generic products where bioequivalence to an innovator product may be sufficient for drug approval, life cycle management typically requires a series of studies to characterize the value of the product. This review summarizes key considerations in identifying product candidates that may be suitable for life cycle management and discusses the application of pharmacokinetics and pharmacodynamics in developing new products using a life cycle management approach. Examples and a case study to illustrate how pharmacokinetics and pharmacodynamics contributed to the selection of dosing regimens, demonstration of an improved therapeutic effect, or regulatory approval of an improved product label are presented.     

The classification of antiseptic products to be administered to wounds--another borderline case between medicinal products and medical devices?

The importance of a correct demarcation between a Medicinal Product (MP) and a Medical Device (MD) is undisputedly one of the major topics related to the development and launch of a new healthcare product. However, for some products the correct demarcation between MPs and MDs can turn out to be somewhat complicated. This article aims to provide an overview on the existing legislation and its adequate application based on a suitable example at hand. Article 2 (2) of the European Directive 2001/83/EC as amended by Directive 2004/27/EC on the Community code relating to medicinal products for human use stipulates that the respective Medicinal Products Legislation must be applied whenever a product can be covered by both the definitions for MPs and for products regulated by other legal provisions enacted by the European Community, e.g. Cosmetic Products (CPs) or MDs. This basic principle implies that the decision to base the risk-benefit assessment of the product in question on the Medical Device Directive (MDD) would contradict the aforementioned constitutional principle, pursuant to which the stricter of the regulatory procedures theoretically possible is to apply in cases of doubt. In contrast to the approval procedure established for MPs, the MDD requires a Conformity Assessment Procedure to be performed by the manufacturer himself and a "Notified Body". Thus, in the majority of cases the responsibility for the risk assessment of MDs lies solely with the manufacturer and is prior to launch not subject to further scrutiny by regulators. Only in specific cases, i.e. for the Conformity Assessment Procedure of Class III MDs which contain an Active Pharmaceutical Ingredient one of the Member States competent authorities designated in accordance with Directive 65/ 65/EEC has to be involved before taking a decision. It is therefore important that the classification of the product is carried out carefully in full compliance with existing legal provisions, also taking into account the related guidance documents issued by the European Commission. The adequate application of these rules is explained using the example of the antiseptic compound polihexanide, which is used both in approved medicinal products (wound antiseptics) and wound irrigation solutions labelled as medical devices.     

Defining the Scope of Gcp's

Abstract

A survey of drug product removal from the market was conducted for the years of 1980–1984 covering 24 firms and 95 products. The questionnaires were mailed to 46 firms and covered 200 products, 152 single entities and 48 combination products. Useable responses included 71 single entities and 24 combination products. The percentages of mode of product approval for the final sample were NDA 50%; ANDA, 16%, and grandfather clause, 34%. The mean life span was 20.4 years. The primary reasons for removal of the products were economic, 65%; regulatory, 27% and other, 8%. There was a significant difference in the approval modes and a marginally significant difference for the reasons of product removal from the market for the two product types. The reason for product removal was different for products approved under the three modes of approval, but this was only marginally significant statistically. The X2 test was used for these determinations. More drug products were removed from the market than were added during this time period.     

新型冠状病毒肺炎疫情应对视角下建立药械紧急授权使用制度研究

从新型冠状病毒肺炎疫情爆发后药械紧急研发和审批的迫切需求为切入点,分析我国药械特别审批制度存在的问题,指出紧急授权使用制度缺乏上位法依据,应当建立超越常规上市许可的紧急授权使用路径,建议在《药品管理法实施条例》《医疗器械监督管理条例》中引入紧急授权使用条款.由国务院药品监督管理部门制定《药品紧急授权管理办法》《医疗器械紧急授权管理办法》,对紧急授权的产品范围、审评部门、审评程序、申请资料、责任豁免等作出规定.     

The Use of Clinical Utility Assessments in Early Clinical Development

A quickly realizable benefit of model-based drug development is in reducing uncertainty in risk/benefit, comprising individually of safety and effectiveness, two key attributes of a product evaluated for regulatory approval, marketing, and use. In this review, we investigate gaps and opportunities in using fundamental decision analytic principles in drug development and present a quantitative clinical pharmacology framework for the application of such aids for early clinical development decision making. We anticipate that implementation of such emerging tools will enable sufficient scientific understanding of the two attributes to facilitate the early termination of compounds with less than desirable risk/benefit profiles and continuance of compounds with acceptable risk/benefit profiles.     

美国FDA医疗器械监管科学研究项目简介(第二部分:有源医疗器械和计算机模拟)

目的： 通过介绍美国FDA开展的医疗器械监管科学研究项目,为我国医疗器械监管科学研究提供参考。方法：通过翻译和整理美国FDA发布的各类文件资料和研究项目,介绍其正在开展的监管科学研究项目。结果与结论：美国FDA与科研机构、临床机构、其他政府机构及产业界合作开展医疗器械监管科学研究,取得的研究成果用于确保医疗器械的安全性和有效性,并促进医疗器械企业创新和高质量发展。在有源医疗器械领域,开展的研究项目有关于产品性能的研究,如电磁兼容性、磁共振成像安全、无线共存等;有计算机模拟和人工智能方面的研究,如人机交互、数字病理学评估、虚拟影像临床试验等;也有针对先进技术的研究,如患者生理信号监控技术、个性化心脏疗法等。     

Assessment strategies and decision criteria for pesticides with endocrine disrupting properties relevant to humans

There is growing concern that environmental substances with a potential to modulate the hormonal system may have harmful effects on human health. Consequently, a new EU regulation names endocrine disrupting properties as one of the cut-off criteria for the approval of plant protection products, although it currently fails to provide specific science-based measures for the assessment of substances with such properties. Since specific measures are to be presented by the European Commission in 2013 the development of assessment and decision criteria is a key challenge concerning the implementation of this new EU regulation. Proposals of such decision criteria for substances with potential endocrine disrupting properties in human health risk assessment were developed by the German Federal Institute for Risk Assessment (BfR) and discussed at an expert workshop in November 2009. Under consideration of the requirements laid down within the new plant protection product legislation and the scientific discussions during the workshop, a conceptual framework on evaluation of substances for endocrine disrupting properties in a regulatory context is presented in this paper. Central aspects of the framework include assessment of adversity of effects, establishment of a mode/mechanism of action in animals, considerations concerning the relevance of effects to humans and two options for a regulatory decision.     

欧美第三类医疗器械的监管现状及对我国的启示

目的:为我国对第三类医疗器械的合理监管提出建议。方法:通过文献调研法和归纳法,从医疗器械上市前、后两个方面总结欧美对第三类医疗器械的监管模式,并分析我国医疗器械的监管状况,对比我国与欧美的监管差异,从而得出我国第三类医疗器械监管模式。结果与结论:我国应从明确的界定品种、加强监督的技术手段以及积极建立上市后监管体系三个方面加强对第三类医疗器械的监管。     

Global regulatory registration requirements for collagen-based combination products: points to consider

Collagen-based medical products provide an ideal and unique matrix for the delivery of drugs, biologics and other therapeutic agents. Collagen has a long history of safety and effectiveness. Collagen is biodegradable with minimal tissue reaction. Regulatory requirements for approval of collagen-based combination products are changing as more high technology combinations are developed. There are special considerations that need to be addressed for collagen products. Products of animal origin must meet specific requirements in regards to safety factors regarding Transmissable Spongiform Encephalopathies. Global regulatory registration requirements and special controls are presented.     

A Survey of Drug Products Removed from the Market

Abstract

A survey of drug product removal from the market was conducted for the years of 1980-1984 covering 24 firms and 95 products. the questionnaires were mailed to 46 firms and covered 200 products, 152 single entities and 48 combination products. Useable responses included 71 single entities and 24 combination products. the percentages of mode of product approval for the final sample were NDA 50%; ANDA, 16%, and grandfather clause, 34%. the mean life span was 20.4 years. the primary reasons for removal of the products were economic, 65%; regulatory, 27%, and other, 8%. There was a significant difference in the approval modes and a marginally significant difference for the reasons of product removal from the market for the two product types. the reason for product removal was different for products approved under the three modes of approval, but this was only marginally significant statistically. the X² test was used for these determinations. More drug products were removed from the market than were added during this time period.

A mail survey of 46 firms covering 200 products yielded responses from 24 firms (52%) and 95 (48%) products. Most of the products removed from the market had been approved under the NDA process (50%) and a lesser number under the ANDA process (16%) and grandfather clause (34%). More combination products were approved under the grandfather clause. the range of life span for the products was 2-49 years with a mean of 20.4 years. Proportionally, more combination products were removed from the market for regulatory reasons and more products approved under the ANDA or grandfather clause were removed for economic reasons. Firms are reluctant to remove products from the market even after they cease to be profitable.     

Impact of pharmacometric analyses on new drug approval and labelling decisions: a review of 198 submissions between 2000 and 2008

Pharmacometric analyses have become an increasingly important component of New Drug Application (NDA) and Biological License Application (BLA) submissions to the US FDA to support drug approval, labelling and trial design decisions. Pharmacometrics is defined as a science that quantifies drug, disease and trial information to aid drug development, therapeutic decisions and/or regulatory decisions. In this report, we present the results of a survey evaluating the impact of pharmacometric analyses on regulatory decisions for 198 submissions during the period from 2000 to 2008. Pharmacometric review of NDAs included independent, quantitative analyses by FDA pharmacometricians, even when such analysis was not conducted by the sponsor, as well as evaluation of the sponsor's report. During 2000-2008, the number of reviews with pharmacometric analyses increased dramatically and the number of reviews with an impact on approval and labelling also increased in a similar fashion. We also present the impact of pharmacometric analyses on selection of paediatric dosing regimens, approval of regimens that had not been directly studied in clinical trials and provision of evidence of effectiveness to support a single pivotal trial. Case studies are presented to better illustrate the role of pharmacometric analyses in regulatory decision making.     

Misunderstanding <Emphasis Type="Italic">Design Space</Emphasis>: a Robust Drug Product Control Strategy Is the Key to Quality Assurance

ICH guidelines Q8/11, Q9, and Q10 introduced risk-based approaches and enhanced scientific understanding as an opportunity to encourage continuous process improvement for pharmaceutical manufacturing. Conceptually, Quality by Design (QbD) promised to improve confidence in quality through the lifecycle of pharmaceutical products. A primary incentive for industry is the prospect of global regulatory concordance for new applications and post approval changes. Unfortunately, during the last decade, the industry has experienced regulatory divergence regarding the interpretation of ICH guidelines across geographic regions. Rather than truly harmonized regulatory expectations, localized interpretations of ICH guidance have resulted in different technical requirements posing significant challenges for a global industry. As a result, the increased complexity of manufacturing supply chains and the regulatory burden associated with maintaining compliance with these diverse regulatory expectations serves as a barrier to continual improvement and innovation. The QbD paradigm has effectively demonstrated a risk-based link between a product’s control strategy and patient needs that has prompted meaningful improvement in the industry’s approach to product quality assurance. Divergent interpretations of the concepts and definitions used in the modern QbD approach to product development and manufacturing, however, has led to challenges in achieving a common implementation of design space, control strategy, prior knowledge, proven acceptable range, and normal operating range. While the concept of design space remains an appealing focal point for demonstrating process understanding, the authors suggest that Control Strategy is the most important QbD concept, and one that assures product quality for patients. A focus by both regulators and manufacturers on the significance of Control Strategy could facilitate management of post approval changes to improve manufacturing processes and enhance product quality while also engendering regulatory harmonization.