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ARIZONA
CENTER
Innovation Center
The Arizona Center for Innovation (AzCI) assists
technology companies turning their innovative ideas
into successful businesses through:
• Focused programs
• World-class expertise
• High-quality facilities
Access:
• Other technology
entrepreneurs
• Collaborative,
creative
environment
• Advantage of
hands-on support
• Successful
business leaders
Arizona Center for Innovation
AzCI
Startup and emerging technology companies
• Community and UA spin-outs
Technology
• Aligned with UA Tech Parks and UA
International
• Softlandings
Who
AzCI
Technology Areas:
• Security and Defense
• Mining
• Agriculture and Water
• Biotechnology
• Intelligent Transportation and Vehicles
• Renewable Energy
Informatics/Big Data/Advanced Manufacturing/
Imaging/Optics/Photonics
Focus
“How to Navigate to Biotech Regulatory Process”
20 September 2011
Marlene E. Haffner, MD, MPH
Haffner Associates, LLC
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
 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
 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
 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
 8000 + dedicated and talented employees across the US
 ~ 50% in the Washington, DC area
 MDs, pharmacists, statisticians, nurses, dentists, policy
analysts, PhDs, 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
 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)
 Often a stumbling block
 Acute and short term toxicity in animals – one
rodent and one non- rodent
◦ Genetic
◦ Reproductive
◦ Carcinogenicity
 How is the drug absorbed, distributed, metabolized
and excreted in animals
 Apply to FDA to allow human exposure to the
experimental drug – Go to FDA website
 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
 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
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)
 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
 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
 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 completelysafe
 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
 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
Preclinical 3 – 6 years
Phase 1 1 – 2 years
Phase 2 2 – 3 years
Phase 3 3 – 4 years
________________________________________
9 – 15 years
FDA review 1 year
?Marlene E. Haffner, MD, MPH
301 984 5729
www.mhaffner.com
mhaffner3@verizon.net
https://techparks.arizona.edu/azci

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AzCI presents: FDA Drug Development 101

  • 1.
  • 3. Innovation Center The Arizona Center for Innovation (AzCI) assists technology companies turning their innovative ideas into successful businesses through: • Focused programs • World-class expertise • High-quality facilities Access: • Other technology entrepreneurs • Collaborative, creative environment • Advantage of hands-on support • Successful business leaders Arizona Center for Innovation
  • 4. AzCI Startup and emerging technology companies • Community and UA spin-outs Technology • Aligned with UA Tech Parks and UA International • Softlandings Who
  • 5. AzCI Technology Areas: • Security and Defense • Mining • Agriculture and Water • Biotechnology • Intelligent Transportation and Vehicles • Renewable Energy Informatics/Big Data/Advanced Manufacturing/ Imaging/Optics/Photonics Focus
  • 6. “How to Navigate to Biotech Regulatory Process” 20 September 2011 Marlene E. Haffner, MD, MPH Haffner Associates, LLC
  • 7. 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
  • 8.  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
  • 9.  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
  • 10.  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
  • 11.  8000 + dedicated and talented employees across the US  ~ 50% in the Washington, DC area  MDs, pharmacists, statisticians, nurses, dentists, policy analysts, PhDs, 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
  • 12.  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)
  • 13.  Often a stumbling block  Acute and short term toxicity in animals – one rodent and one non- rodent ◦ Genetic ◦ Reproductive ◦ Carcinogenicity  How is the drug absorbed, distributed, metabolized and excreted in animals
  • 14.  Apply to FDA to allow human exposure to the experimental drug – Go to FDA website  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
  • 15.  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
  • 16. 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)
  • 17.  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
  • 18.  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
  • 19.  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 completelysafe
  • 20.  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
  • 21.  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
  • 22. Preclinical 3 – 6 years Phase 1 1 – 2 years Phase 2 2 – 3 years Phase 3 3 – 4 years ________________________________________ 9 – 15 years FDA review 1 year
  • 23. ?Marlene E. Haffner, MD, MPH 301 984 5729 www.mhaffner.com mhaffner3@verizon.net