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FDA Perspective on Review of Innovative Systems for Drug Delivery. Perspective from CDER’s Division of Reproductive and Urologic Drug Products (DRUDP). Experience and Lessons Learned from Contraceptive and other Drug /Device Therapeutic Systems. Dan Shames MD Director, FDA/CDER/DRUDP.
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FDA Perspective on Review of Innovative Systems for Drug Delivery Perspective from CDER’s Division of Reproductive and Urologic Drug Products (DRUDP)
Experience and Lessons Learned from Contraceptive and other Drug /Device Therapeutic Systems Dan Shames MD Director, FDA/CDER/DRUDP
Innovative Drug/Device Systems for Contraception • Norplant I,II, Jadelle (1990, 96, 01) • six and two rod systems • systemic levonorgestrel (LNG) • 5 year efficacy • 1000+ women-years preapproval experience • interactions mostly with CDER technical experts (chemists, clinical pharmacology, toxicology, microbiology)
Innovative Drug/Device Systems for Contraception • Lunelle (2000) • Injectable E + P, systemic • Prefilled syringe or vial: both single dose only • Every month • 1000+ women-years preapproval experience • interactions mostly with CDER technical experts
Innovative Drug/Device Systems for Contraception • Mirena (2000) • Intrauterine System • releases LNG locally • 5 year efficacy • 1000+ women-year preapproval experience • interactions with CDRH and CDER technical experts
Innovative Drug/Device Systems for Contraception • Nuvaring (2001) • intravaginal ring • E+P systemically • insert for 21; remove for 7 days • 1000+ women-year preapproval experience • interactions mostly with CDER technical experts
Innovative Drug/Device Systems for Contraception • Ortho-Evra (2001) • transdermal system • E+P systemic • apply every 7 days (3 out of 4 weeks) • 1000+ women-year preapproval experience • interactions mostly with CDER technicalexperts
Lessons Learned by DRUDP • The Good News (mostly it goes well) • we can work with device technical experts (from CDER and CDRH) in a productive and efficient manner to review innovative drug delivery systems • there were few clinical trial design conflicts when sponsor met CDER standards for evidence • development went well when sponsor knew of CDER’s evidence requirements “a priori”
Lessons Learned by DRUDP • The Other News (when it doesn’t go well) • sometimes the systems are really “out of the box” • who is “in charge” CDRH versus CDER (turf ?) • Culture Clashes • the pointy headed bureaucrats whose main goal is to keep things off the market because they have no regard for the entrepreneurial spirit and “good ole American ingenuity” versus • those people who will approve anything that doesn’t blow up when they plug it in, regardless of consequence to patient safety
Lessons Learned by DRUDP • Culture Clashes (continued) • the engineers versus the doctors • reasonable versus substantial evidence • big Pharma versus small firms
Lessons Learned by DRUDP • Good News Again (the future) • Office of Combination Products is helping to “bridge the gap” and improve the processes • improved understanding between CDER, CDRH reviewers regarding the processes and regulations • getting the message out that development plans should be worked out early • most staff at CDER, CDRH enjoy working on innovative products and are well motivated to assist the sponsors and improve our internal processes