Avenue’s 2nd ‘Complete Response’ on Pain NDA
FDA has issued Avenue Therapeutics a second complete response letter on its NDA for an intravenous formulation of tramadol, indicated for treating patients in acute pain who require an opioid. The letter said that the delayed and unpredictable onset of analgesia with IV tramadol does not support its benefit as a monotherapy to treat patients in acute pain, and there is insufficient information to support the company’s claim that IV tramadol in combination with other analgesics is safe and effective for the intended patient population. The agency did not identify any chemistry, manufacturing and control issues, the company says.
The first complete response letter was issued 10/2020 due to safety concerns. The FDA letter told the company that while its Phase 3 clinical trials demonstrated statistically significant outcomes for all of the primary and many secondary endpoints, the agency had determined that it could not approve the application in its present form because the drug was not safe for the intended patient population, Avenue said at the time. “Specifically, if a patient requires an analgesic between the first dose of IV tramadol and the onset of analgesia, a rescue analgesic would be needed,” it says. “The likely choice would be another opioid, which would result in opioid ‘stacking’ and increases the likelihood of opioid-related adverse effects.” Additionally, FDA said it will require an adequate terminal sterilization validation prior to NDA approval.
Avenue says it disagrees with FDA’s current interpretation of the data in the NDA and intends to continue to pursue regulatory approval.