Clarification Sought in Oncology Trial Inclusion Guidance
The Biotechnology Industry Organization (BIO) is asking FDA to clarify how its draft guidance on considerations for inclusion of adolescent patients in adult oncology clinical trials relates to provisions in the Pediatric Research Equity Act (PREA) and the FDA Reauthorization Act of 2017. The association’s comment letter says that if a sponsor enrolls adolescents in an adult trial according to the principles in the draft guidance, the guidance should be revised to describe whether and when the PREA requirements for the adolescent age have been satisfied.
BIO also asks FDA to consider including case examples in the final guidance demonstrating circumstances when adolescents have different physiology and/or psychology, relative to adults.
In its letter, Pharmaceutical Research and Manufacturers of America (PhRMA) says it supports the draft guidance and believes that additional adolescent representation in adult oncology clinical trials “will support more robust drug development and help promote public health.” The association also notes that it is important to consider finding ways to encourage inclusion of adolescents in drug development across other therapeutic areas. “The recommendations in this draft guidance could help provide a pragmatic solution for numerous other medical conditions across the therapeutic spectrum, particularly where the relevant disease is severe and life-threatening,” PhRMA says. “With appropriate input from interested stakeholders, FDA could consider extending these recommendations beyond oncology.”
In its letter, AstraZeneca says it is not clear from the guidance if the early enrollment of adolescents will mean that a sponsor has met the agency’s pediatric study requirements under PREA. The company also asks for more guidance on how the draft will interplay with European pediatric regulation, and asks for more information on the minimal number of adolescents that may be required and any learnings that the agency has applied from other therapeutic areas that already include adolescents in adult trials.
Finally, GlaxoSmithKline says it generally agrees with the comments submitted by BIO and PhRMA and then offers some line-by-line specific comments of its own.