505(b)(2) Sponsors ‘May Need Less Safety Data”
Camargo consultant William Stoltman says that a recent CDER/CBER guidance on the extent of safety data collection needed in late-stage premarket and post-approval clinical investigations may provide a significant reduction in safety data collection for NDA sponsors, and especially for those using the 505(b)(2) regulatory pathway. Writing in a 505(b)(2) Blog post, Stoltman says that the guidance lists several conditions that may make selective safety data collection appropriate. It also lists the types of clinical investigations that may be considered for selective safety data collection, and the types of safety data that are candidates for selective safety data collection.
“The lynchpin to the possibility of selective safety data collection appears to be the existence of a robust safety database for the product in question,” Stoltman writes. “That is often the case with a product being developed using the 505(b)(2) regulatory pathway. By definition, an application pursuant to Section 505(b)(2) frequently relies on extensive, pre-existing safety data.”
The guidance also includes further details and conditions, the post says, the most important of which is the requirement to develop a plan and reach agreement on the specifics of a selective safety data collection with the relevant FDA review division or divisions, such as at the end-of-Phase 2 meeting before starting a Phase 3 study.