The Institute of Medicine (IOM) issued a strong report last September urging major changes in Food and Drug Administration
operations to better balance the agency's assessment of risks with benefits. FDA commissioner Andrew von Eschenbach responded
a few weeks ago with a detailed plan for improving how the agency detects and assesses safety problems for drugs and biologics.
The report on "The Future of Drug Safety" describes initiatives for developing safety "report cards" on important new products,
publishing an online drug safety newsletter, and accessing more health system databanks to detect safety signals more quickly.
FDA also is clarifying conflict-of-interest policies for advisory committees and establishing a new advisory committee on
communication to provide more outside expertise on conveying risk information. The agency plans a formal assessment of Risk
Management Plans (RiskMAPS) to see if they really address serious safety problems and is expanding scientific efforts for
testing and developing safer medical products.
Steven Galson, director of the Center for Drug Evaluation and Research (CDER), promised to address the tension between pre-and
post-approval staffs by engineering a "true culture change" at CDER that gives more authority to safety analysts. The Center
for Biologics Evaluation and Research (CBER) has established an integrated risk–benefit analysis program, with cross-cutting
product safety teams to deal with safety issues involving vaccines, blood, and cellular products. CBER also is collaborating
with the Centers for Disease Control and Prevention (CDC) to expand the use of databases for monitoring and analyzing flu
The unstated goal of these actions is to head off legislation requiring more significant FDA organizational changes and added
mandates for manufacturers and regulators. FDA intentionally does not address IOM proposals that require Congressional action,
such as providing authority to levy fines on pharma marketers that fail to complete promised post-approval studies. The FDA
announcement covered those activities that the agency can implement on its own, provided Congress provides added resources
from user fees and appropriated funds. But, if FDA and industry want Congress to reauthorize the Prescription Drug User Fee
Act (PDUFA) by fall, they probably will have to agree to some new requirements for ensuring drug safety.
EMPHASIS ON SCIENCE
An underlying theme of FDA's drug safety program is that new discoveries in biomedical science can detect risk issues earlier
in clinical development. Janet Woodcock, FDA deputy commissioner and chief medical officer, is leading a broad spectrum of
activities to accelerate risk assessment by manufacturers and government scientists, many launched under the Critical Path
For example, FDA is collaborating with industry and academia to validate new tests for organ toxicity and for cardiovascular
risk of drugs. A consortium of manufacturers, FDA, and the National Institutes of Health (NIH) is assessing biomarkers that
can spur development of new treatments, beginning with lung cancer and lymphoma. And a new Serious Adverse Event Consortia
plans to identify and validate genetic variants that may help predict the risk of drug-induced reactions.
These efforts to reduce development time and cost were described in FDA's Critical Path Opportunities List, which was issued
in March 2006 and updated in a January 2007 report on collaborations and research activities undertaken in 2006. The aim is
to "build safety into products" by better understanding the genetic basis of adverse events, explained Woodcock. These approaches
can detect toxic compounds early and identify patients most likely to have adverse events—or to respond well—to a test medicine.
FDA, she said, wants to "make products safer from the get-go."
One part of this campaign to improve R&D success rates is to "move manufacturing into the 21st century" by developing standards for laboratory and production analytical methods. To encourage adoption of Process Analytical
Technology (PAT), for example, FDA is partnering with pharmaceutical manufacturers and instrument producers to test validation
reference systems for imaging methods, such as near-infrared, mid-infrared, Raman chemical imaging (RCI), and terahertz technologies.