Comments on Immune-Mediated Adverse Reaction Guidance
Responding to an FDA draft guidance on characterizing, collecting, and reporting immune-mediated adverse reactions in cancer immunotherapeutic clinical trials, Bristol-Myers Squibb says it is expected that as new traditions and times of therapy are developed, a better understanding within the healthcare community and the sponsor’s database/experience continue to expand. “Collecting and reporting of immune-mediated adverse reactions are expected to evolve over time,” the company letter says. “Therefore, BMS proposes that this guidance provide recommendations to sponsors on their expectations to collecting and reporting immune-mediated adverse reactions beyond the first approval.”
In its comment, Pfizer recommends that FDA consider transitioning away from the classification of adverse events as immune-mediated adverse reactions given the challenges in making such a determination in many cases. The company also includes specific line-by-line comments.
Boehringer Ingelheim provides line-by-line comments.