Comments on Draft PD Cancer Treatment Guidance

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Genentech says it commends FDA for leveraging scientific and regulatory experience to develop guidance for sponsors on how PK-based criteria can be used to support registration of alternative dosing regimens beyond those studied in dedicated clinical trials. Responding to an agency draft guidance, Pharmacokinetic-Based Criteria for Supporting Alternative Dosing Regimens of Programmed Cell Death Receptor-1 (PD-1) or Programmed Cell Death Ligand 1 (PD-L1) Blocking Antibodies for Treatment of Patients with Cancer, Genentech says it believes that the implementation of PK-based and other MIDD (model-informed drug development) approaches are critical to efficiently develop patient-centric treatment options that minimize risk and burden to patients while preserving the necessary data for doctors and patients to make informed decisions that fit the needs of individual patients.

The letter urges FDA to expand the guidance to other antibody-based therapies. “While we recognize that PD-1/L1 blocking antibodies are relatively well understood,” the company says, “we note that there are many antibody-based therapies with wide therapeutic windows for which the proposed PK-based criteria is highly relevant….”

In its comment, AbbVie says the guidance can apply to other class agents with similar antagonist activity and mechanism of action.

Janssen provides general comments on combination regimens, alternative routes of administration, and reference dosing regimen, and specific line-by-line comments.

The GlaxoSmithKline response suggests adding clarifying text on two issues and gives line-by-line comments.

Finally, Pfizer submits specific line-by-line comments.

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