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Evaluating a New Diagnostic Assay: Industry Perspective. Jim Koziarz Abbott Laboratories. Presentation Outline. The challenge presented by SARS Industry recommendations Implications to product evaluation and approval. The Challenge.
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Evaluating a New Diagnostic Assay:Industry Perspective Jim Koziarz Abbott Laboratories
Presentation Outline • The challenge presented by SARS • Industry recommendations • Implications to product evaluation and approval
The Challenge • Sporadic outbreaks of SARS in diverse geographic locations • Syndromic patient management • Pathogenesis not characterized • Patient sampling and sample handling not standardized • Limited opportunity for prospective clinical trials
The Challenge • Not a “traditional” test development task • Can be a model for response to bioterrorist attack • Requires close cooperation between industry and government agencies to expedite response • Safety, efficacy, and compliance must be addressed
Industry Recommendations • Meeting held with representatives of industry and governmental agencies on May 29, 2003 • Participants: • FDA, CDC, HHS • AdvaMed Abbott Laboratories • Becton Dickinson bioMerieux • GenProbe OrthoClinical Diagnostics • Quidel Corporation Roche Diagnostics • Thermo-BioStar Immunetics
Industry Recommendations • General Objectives • A strong public-private partnership that expedites research, development and approval of diagnostics for emerging pathogens. The interaction between industry, FDA and CDC on the development of a West Nile Virus test provides a good template for the type of partnership and interaction that is needed. • Build on the core competencies of the FDA (approval of safety and effectiveness), the CDC (epidemiology, lab consultation and specimen repository), and industry (Quality Tests and Good Manufacturing Practices).
Industry Recommendations • Policy Recommendations • Convene a public meeting on SARS • Integrate CDC communications into quarterly FDA/Industry Roundtable • Develop guidelines for clinical study and FDA approval standards • Agreement on key elements that must be addressed and on risk mitigation • Expedited approval process allowing postmarket surveillance • Identify points of contact at FDA and CDC • CDC to serve as clearinghouse for samples of emerging pathogens
Industry Recommendations • Issues with Rapid Development of Tests for Emerging Pathogens • R&D funding • Intellectual property • Sample acquisition and characterization • Regulatory requirements for test approval • Reimbursement for new tests
Implications • Goals of clinical validation of new test method • Demonstration of medical benefit • Indication based on test result to diagnosis and patient management • Linkage to patient history, symptoms • Experience of product in intended use population • Product performance with sample type • Sensitivity and specificity
Implications • Product life cycle model • Risk management and mitigation • FMEA • Component reuse where appropriate • Feedback loop to product labeling • Enhance product performance and labeling as more data becomes available
Proposed PMA Plan for SARS Test • Intended Use • Limit to detection of coronavirus • Supplement patient diagnosis with CDC guidelines • Data Set • Submit data gathered to date from sources around the world • Labeling • Provide sensitivity and specificity by sample type • Clearly state test limitations • Post Approval • Repeat studies at multiple sites • Well-documented and characterized samples • Supplement PMA as required
Example of SARS Clinical Studies • Toronto • 22 post-mortem lung tissue samples from 11 SARS patients • Singapore • 1153 samples comprising stool, blood, swab, sputum, urine, and others • Germany • 338 pools comprised of 96 single donations each (32,448 donations) • Toronto • 250-300 specimens representing the following sample types: stool, urine, sputum, and swabs • Paris • Evaluation of samples of acute phase SARS outbreak in Vietnam
Proposed PMA Plan for SARS Test • Feedback Mechanisms • Post approval meetings with agencies to review product performance • Quality system data (internal and external) used to monitor test performance and identify improvement/enhancement opportunities under Design Control • Scientific feedback on virology and pathogenesis to suggest next generation products • Collection of clinically relevant samples for Quality Control and validation of next generation tests
Summary • SARS presents a case for the rapid development and deployment diagnostic tests • Sample acquisition limits our ability to perform extensive product validation studies • There are opportunities for the diagnostic industry to respond to threats like SARS in a rapid, safe, and compliant manner • Close cooperation and communication between industry and government agencies is key to accomplishing this