Comments on FDA Immunogenicity Information Guidance

Commenting on an FDA draft guidance on immunogenicity information in human prescription therapeutic protein and select drug product labeling content and format, AstraZeneca says some clarification is needed on methodology adequacy, data sufficiency, and definitions of anti-drug antibody incidence versus prevalence. The company letter also says the change to having a dedicated Immunogenicity section under Clinical Pharmacology is a “much-needed improvement to consistently report immunogenicity information as part of Prescribing Information.”

Janssen says the draft “provides a helpful framework to ensure the inclusion of clinically relevant immunogenicity information in product labeling. Presenting immunogenicity information in a consistent manner will enable healthcare practitioners to access the relevant data on immunogenicity and any clinically relevant effects on pharmacokinetics, safety, or effectiveness to inform their prescribing decisions.”

Both responses also contain line-by-line specific comments.

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