Drug Approval: Requirements & FDA Authority

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Questions and Answers

Why was the Pure Food and Drug Act of 1906 considered ineffective?

  • It was immediately repealed due to public outcry.
  • It focused solely on preventing the import of foreign drugs.
  • It only applied to food products, not drugs.
  • It lacked enforcement mechanisms to hold violators accountable. (correct)

What critical requirement for drugs was introduced by the Food, Drug, and Cosmetic Act that didn't exist before?

  • Drugs had to be tested on animals before human trials.
  • Drugs had to be manufactured domestically.
  • Drugs had to be proven effective before marketing.
  • Drugs had to be proven safe before marketing. (correct)

What event significantly influenced the passage of the Food, Drug, and Cosmetic Act?

  • A mass poisoning incident involving a drug that used antifreeze as a solvent. (correct)
  • A widespread outbreak of foodborne illness caused by contaminated produce.
  • The discovery of a new antibiotic with severe side effects.
  • The publication of a report exposing unsanitary conditions in meatpacking plants.

What was the primary focus of the Kefauver-Harris Amendments of 1962?

<p>To introduce regulations regarding drug promotion and efficacy. (A)</p> Signup and view all the answers

What key aspect does the Modernization Act of 1997 address concerning pharmaceutical companies?

<p>The act allows pharmaceutical companies to communicate about products before launch. (D)</p> Signup and view all the answers

During the NDA process, what is the FDA's initial step upon receiving a submission?

<p>Checking to confirm receipt of all the documents. (C)</p> Signup and view all the answers

What type of information about a new drug application becomes publicly available during the FDA review process?

<p>Notification that a submission has occurred. (D)</p> Signup and view all the answers

What is a Subpart H approval, and under what circumstances might it be granted?

<p>A conditional approval based on surrogate markers, requiring FDA review of promotional materials. (B)</p> Signup and view all the answers

How does the patient population in Phase 3 clinical trials affect the scope of a drug's approval?

<p>A narrower patient population may lead to a narrower indication. (A)</p> Signup and view all the answers

What type of data is submitted to the FDA as part of a New Drug Application (NDA)?

<p>Pre-clinical data, pharmacokinetic data, and clinical information. (B)</p> Signup and view all the answers

Why is patent information included in a New Drug Application (NDA)?

<p>To allow attorneys to address any potential patent disputes. (A)</p> Signup and view all the answers

Based on Katie Lyons' experiences, what motivated her to transition into the regulatory field?

<p>She wanted to understand the reasons behind regulatory limitations. (A)</p> Signup and view all the answers

What was Kelly Hogan's initial area of focus within the pharmaceutical industry?

<p>Phase III clinical trial work. (B)</p> Signup and view all the answers

What is the significance of the proposed drug labeling that is submitted as part of the NDA?

<p>It serves as a key source of information for physicians about the drug. (B)</p> Signup and view all the answers

How did the Sulfanilamide crisis in Europe impact drug regulation in the United States?

<p>It raised concerns about drug safety and efficacy, influencing stricter regulations. (D)</p> Signup and view all the answers

Prior to the Food Drug and Cosmetic Act, what was a major deficiency in drug regulation?

<p>Drugs did not need to be proven safe before being marketed. (A)</p> Signup and view all the answers

What is the FDA's role regarding promotional materials for drugs that receive Subpart H approval?

<p>The FDA must approve promotional materials before they are disseminated. (C)</p> Signup and view all the answers

What is typically the timeframe for the FDA to acknowledge receipt of a New Drug Application (NDA)?

<p>Within 60 days of submission. (D)</p> Signup and view all the answers

What does it mean when the FDA communicates that an NDA has been 'filed'?

<p>The FDA confirms that all required components of the submission are present. (C)</p> Signup and view all the answers

Why did the speaker transition from a medical role to regulatory affairs?

<p>To gain a comprehensive understanding of the rationale behind drug regulations. (A)</p> Signup and view all the answers

According to the speaker, what is a significant challenge associated with lengthy drug labels?

<p>Difficulty for physicians to thoroughly review and analyze the information. (D)</p> Signup and view all the answers

Which of the following is NOT a typical component of a New Drug Application (NDA)?

<p>Market analysis and sales projections. (A)</p> Signup and view all the answers

In the context of drug approvals, what does the use of a 'surrogate marker' imply?

<p>The approval is based on an indirect measure of clinical benefit. (A)</p> Signup and view all the answers

What prompted changes in promotional regulations following the 1962 Kefauver-Harris Amendments?

<p>Concerns regarding safety and efficacy raised by the thalidomide tragedy, emphasizing truthfulness and balance in the content of promotional materials. (D)</p> Signup and view all the answers

Which step comes first?

<p>receipt (B)</p> Signup and view all the answers

Flashcards

Food Drug Cosmetic Act

Requires drugs to be safe before marketing.

Modernization Act of 1997

Deals with pharmaceutical companies communicating about products before launch

NDA Submission Info

A notification that a submission has occurred will be made public, but not anything after the fact until it actually occurs.

NDA contents

Data on pre-clinical studies, pharmacokinetics, clinical information, patents and proposed labeling

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Kefauver-Harris Amendments of 1962

Drug must be proven both safe and effective.

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FDA's NDA Review Stages

NDA is submitted, FDA checks receipt, reviews main components, and confirms if it is acceptable for filing

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Pure Food and Drug Act (1906)

Aim was to prevent snake oils from going into interstate commerce, lacked enforcement.

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Drug Approval Parameters

Approval based on phase three population and study design.

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Study Notes

Introductions

  • Katie Lyons has been in the pharmaceutical industry since 2000, with a background as a clinical pharmacist and experience in field work, in-house medical strategy, global publication plans, and regulatory roles.
  • Katie's regulatory experience focuses on regulations around commercialization, working closely with commercial colleagues, and she was always asking questions.
  • Kelly Hogan has a pharmacy background and has been in the industry since around 1999/2000, with a career focused on phase three clinical trial work.

Drug Approval Requirements

  • Approval is based on the Phase 3 population studied
    • Narrow patient population leads to narrow indication
  • Evaluating a surrogate marker instead of a clinical marker may lead to a subpart H approval
    • Subpart H approval requires FDA to approve and review all materials before promotion
  • Adequate manufacturing and appropriate labels are necessary for approval
  • Study design impacts approval

FDA Authority

  • 1906 Pure Food and Drug Act
    • Designed to prevent snake oils from going into interstate commerce
    • Lacked enforcement mechanisms
  • 1937: 107 children died due to the use of antifreeze as a solvent in medication
  • Food Drug Cosmetic Act
    • First time a drug had to be proven safe before marketing
    • Established the FDA
  • 1962 Kefauver-Harris Amendments
    • Prompted by Sulfanilamide causing birth defects in Europe
    • Drugs must be proven both effective and safe
    • Led to regulations for promotion
  • 1997 Modernization Act
    • Addressed communication about products before launch

New Drug Application (NDA)

  • Meeting held with the FDA to present the NDA package a month in advance
  • Includes clinical data, preclinical data, and statistics
  • FDA has three stages
    • Receipt: Acknowledges receipt of the submission
    • Filing: Confirms all main components are present within 60 days
    • Refusal to File: Occurs if key components are missing
  • Contents
    • Preclinical data
    • Pharmacokinetics
    • Clinical information
    • Patents
    • Proposed drug labeling
  • Press releases regarding submissions are made public
  • Notification that a submission has occurred is public knowledge
  • Information on the review process remains confidential until it's completed
  • Proposed label submitted to the FDA can be extensive, such as 51 pages long
    • This is a primary resource for physicians, but may be too long to analyze effectively
  • Physician drug labeling changes occurred about ten years ago

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