Comments on Draft Indications and Usage Labeling Guidance

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The Biotechnology Innovation Organization (BIO) applauds an FDA draft guidance with recommendations on general principles to consider when drafting an indication and how to write, organize, and format the information in the Indications and Use section of labeling. The BIO letter particularly commends the agency for recognizing that an indication for a broader population than the population studied in controlled trials may be appropriate after careful consideration of the generalizability of the evidence, consistencies in the disease process across different groups, and the drug’s overall benefits and risks. It suggests ways in which the section on identification of outcomes, endpoints, and benefits the drug conveys could be strengthened, and says the agency should ensure that labeling preserves the intent of accelerated approval to hasten availability of treatments for patients with serious or life-threatening diseases and limited or no treatment options.

In its letter, Pharmaceutical Research and Manufacturers of America says the draft guidance gives sponsors general information to draft informative labeling for drug and biological products, but could use clarification on how FDA plans to apply the draft’s principles in specific circumstances. It offers comments on the guidance scope, the approval process for and requirement to revise labeling, and the process for limitations of use.

Sarepta Therapeutics says it “agrees with many of the recommendations and general principles contained in the draft guidance and believes it will lead to greater alignment and transparency across labeling practices overall.” It gives suggestions for revisions in terms of age groups in indications and accelerated approval.

Pfizer submitted specific line-by-line comments.

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