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Letter
    P e o p l e               •          S c i e n c e         •       R e g u l a t i o n




    Volume XLVII • Issue #9            www.pda.org/pdaletter                     October 2011




    Personalized Medicines: The
    Next Big Thing in Healthcare
                                             18




6     Vote for 2012 Officers      12 More Development Means        34 EMA/U.S. FDA to
      and Directors                  Less Filings with ICH Q 11       Continue Collaborations
of Pre-Filled
         rse
                                       Device Usability: Getting It Right from the Start

                         Sy
   ve




                           ring
Uni




                               es
T he




                                       Andy Fry, Team Consulting

                                     Recently there     to integrate human factors engineering         burden of delivering a dose. This process
        In
                         ice        has been a          from the outset and throughout prod-           should also be satisfactory from the regula-
                         s
       &




           je c
                ti o n D e v      huge increase in      uct development. At each stage of the          tory point of view as you can demonstrate
                               interest within the      process—concept generation, prototyp-          that patient usability has been central to
                           pharmaceutical and drug      ing and final embodiment—the device            the development and that it has been cor-
       delivery community around “human fac-            must be placed in the hands of users,          rectly and thoroughly assessed.
       tors” (HF), or usability. Interest is not be-    then they must be watched and their ac-        As well as the focus on observation at the
       ing driven by new regulations; instead, it       tions analyzed.                                beginning, middle and end of develop-
       is a change in the behavior of regulators.                                                      ment, the best advice is to follow the us-
                                                        It is worth highlighting at this point that
       Regulators increasingly are concerned            usability research is not only about sta-      ability engineering process with passion
       about inadequate device safety and are           tistical data, the U.S. FDA places a great     and creativity, which involves under-
       placing greater emphasis on seeing proof         deal of importance on observational            standing the FDA guidance, ISO/IEC
       that misuse of devices will not impact           analysis that has been unpicked, chal-         62366  and  ASNI/AAMI  HE75:2009 
       patient safety. As a result, devices are                                                        documentation from cover to cover. Yes,
                                                        lenged and discussed qualitatively; after
       being rejected at the point of approval                                                         they are regulatory necessity, but they
                                                        all, the causes of misuse might be down
       and either require in-depth user analy-                                                         also offer exceptionally useful best prac-
                                                        to a range of factors such as the user’s
       sis studies to prove their safety or, in the                                                    tice guides for integrating human factors
                                                        psychology, the design of the device or
       worst case, expensive redesigns to actu-                                                        principles throughout development and
                                                        the instructions.
       ally address issues.                                                                            greatly increasing your chances of get-
                                                        Observing patients or caregivers using         ting your therapy and device through
       As far as the regulators are concerned,          prototypes or the final product can pro-       the regulators and into the market.
       “usability” is primarily focused on user         vide some invaluable insight especially
       safety: The patient must be able to use                                                         About the Author
                                                        when successfully combined with ana-
       the device correctly and without risk,           lytical and empirical HF techniques. By        Andy Fry is a member of the PDA and is the
       and the company must be able to prove                                                           founder of Team Consulting Ltd, a UK-based
                                                        doing this at all stages you can adapt the
       that this is the case.                                                                          medical device developer. Andy will be
                                                        design and functionality of the device as      speaking at the forthcoming PDA Universe
       To reduce the risk of a product being re-        it evolves and in the end help achieve the     of Pre-filled Syringes and Injection Devices
       jected by the regulator (at least on the         objective of safe and appealing devices that   Conference (see p. 46) on the topic of trends
       basis of safety), companies should strive        minimise the core physical and cognitive       in parenteral drug delivery.


       Personalized Medicines continued from page 22

       medicine has the potential to improve            folio as opposed to a major blockbuster        treat disease and cure patients through the
       health outcomes and bend the cost curve          drug, according to an article in Bloomberg     promise of highly efficacious medicines as
       by making the health system more effi-           Businessweek. (7)The author says, “There’s     well as regenerative options. Targeted with
       cient. According to a Personalized Medi-         no certainty … as the markets for specific     the greater goal of more effective disease
       cine Coalition press release, Castellani’s       drugs shrink, that drug companies will be      treatment tailored to specific patient needs,
       speech “emphasized the biopharmaceu-             able to make up for the size of their lost     this effort appears to allow better ways of
       tical sector’s commitment to personal-           blockbusters by developing enough new          improving quality of life for patients.
       ized medicine amid the complexities of           products to treat the same population          References
       applying insights from recent discoveries        their drugs previously treated.” However,
                                                                                                       1.  Miesowicz, Fred, “ApplicationNote:
       in genetics and molecular biology to re-         the same article states: “The hope is that
                                                                                                           Dendritic Cell-Based Immunothera-
       search and development.”                         increased safety and quality assurance—
                                                                                                           peutics: An Automated Solution to
       Future of Success or of Failure for Industry?    and the possibility of moving drugs up             Manufacturing Personalized Medi-
       As more personalized medicines reach             into earlier phases of treatment—could             cines,” Genetic Engineering & Bio-
       commercial scale, pharma companies               bolster sales and help make up for nar-            technology  News,  November  2007, 
       will need to find innovative ways to raise       rower markets for each drug.” (7)                  www.genengnews.com/gen-articles/
       funds, since they will be relying on a small-    A paradigm shift is beginning in the world         applicationnote-dendritic-cell-based-
       er market of drugs in their product port-        of medicines based on this better way to           immunotherapeutics/2274/
                                                                                                                     continued at bottom of page 52
30            Letter •  October 2011

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Device Usability: Getting It Right from the Start

  • 1. Letter P e o p l e • S c i e n c e • R e g u l a t i o n Volume XLVII • Issue #9 www.pda.org/pdaletter October 2011 Personalized Medicines: The Next Big Thing in Healthcare 18 6 Vote for 2012 Officers 12 More Development Means 34 EMA/U.S. FDA to and Directors Less Filings with ICH Q 11 Continue Collaborations
  • 2. of Pre-Filled rse Device Usability: Getting It Right from the Start Sy ve ring Uni es T he Andy Fry, Team Consulting Recently there to integrate human factors engineering burden of delivering a dose. This process In ice has been a from the outset and throughout prod- should also be satisfactory from the regula- s & je c ti o n D e v huge increase in uct development. At each stage of the tory point of view as you can demonstrate interest within the process—concept generation, prototyp- that patient usability has been central to pharmaceutical and drug ing and final embodiment—the device the development and that it has been cor- delivery community around “human fac- must be placed in the hands of users, rectly and thoroughly assessed. tors” (HF), or usability. Interest is not be- then they must be watched and their ac- As well as the focus on observation at the ing driven by new regulations; instead, it tions analyzed. beginning, middle and end of develop- is a change in the behavior of regulators. ment, the best advice is to follow the us- It is worth highlighting at this point that Regulators increasingly are concerned usability research is not only about sta- ability engineering process with passion about inadequate device safety and are tistical data, the U.S. FDA places a great and creativity, which involves under- placing greater emphasis on seeing proof deal of importance on observational standing the FDA guidance, ISO/IEC that misuse of devices will not impact analysis that has been unpicked, chal- 62366  and  ASNI/AAMI  HE75:2009  patient safety. As a result, devices are documentation from cover to cover. Yes, lenged and discussed qualitatively; after being rejected at the point of approval they are regulatory necessity, but they all, the causes of misuse might be down and either require in-depth user analy- also offer exceptionally useful best prac- to a range of factors such as the user’s sis studies to prove their safety or, in the tice guides for integrating human factors psychology, the design of the device or worst case, expensive redesigns to actu- principles throughout development and the instructions. ally address issues. greatly increasing your chances of get- Observing patients or caregivers using ting your therapy and device through As far as the regulators are concerned, prototypes or the final product can pro- the regulators and into the market. “usability” is primarily focused on user vide some invaluable insight especially safety: The patient must be able to use About the Author when successfully combined with ana- the device correctly and without risk, lytical and empirical HF techniques. By Andy Fry is a member of the PDA and is the and the company must be able to prove founder of Team Consulting Ltd, a UK-based doing this at all stages you can adapt the that this is the case. medical device developer. Andy will be design and functionality of the device as speaking at the forthcoming PDA Universe To reduce the risk of a product being re- it evolves and in the end help achieve the of Pre-filled Syringes and Injection Devices jected by the regulator (at least on the objective of safe and appealing devices that Conference (see p. 46) on the topic of trends basis of safety), companies should strive minimise the core physical and cognitive in parenteral drug delivery. Personalized Medicines continued from page 22 medicine has the potential to improve folio as opposed to a major blockbuster treat disease and cure patients through the health outcomes and bend the cost curve drug, according to an article in Bloomberg promise of highly efficacious medicines as by making the health system more effi- Businessweek. (7)The author says, “There’s well as regenerative options. Targeted with cient. According to a Personalized Medi- no certainty … as the markets for specific the greater goal of more effective disease cine Coalition press release, Castellani’s drugs shrink, that drug companies will be treatment tailored to specific patient needs, speech “emphasized the biopharmaceu- able to make up for the size of their lost this effort appears to allow better ways of tical sector’s commitment to personal- blockbusters by developing enough new improving quality of life for patients. ized medicine amid the complexities of products to treat the same population References applying insights from recent discoveries their drugs previously treated.” However, 1.  Miesowicz, Fred, “ApplicationNote: in genetics and molecular biology to re- the same article states: “The hope is that Dendritic Cell-Based Immunothera- search and development.” increased safety and quality assurance— peutics: An Automated Solution to Future of Success or of Failure for Industry? and the possibility of moving drugs up Manufacturing Personalized Medi- As more personalized medicines reach into earlier phases of treatment—could cines,” Genetic Engineering & Bio- commercial scale, pharma companies bolster sales and help make up for nar- technology  News,  November  2007,  will need to find innovative ways to raise rower markets for each drug.” (7) www.genengnews.com/gen-articles/ funds, since they will be relying on a small- A paradigm shift is beginning in the world applicationnote-dendritic-cell-based- er market of drugs in their product port- of medicines based on this better way to immunotherapeutics/2274/ continued at bottom of page 52 30 Letter •  October 2011