CRS Wants Guidance Against ‘Draize’ Tests

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Saying that drug manufacturers too often are ignoring informal FDA communications stating that the agency does not require submission of in vivo rabbit ocular and skin irritation tests (Draize), the Center for Responsible Science (CRS) is asking the agency to issue guidance “communicating broadly that FDA will accept in vitro primary skin and eye irritation data” and that Draize tests are no longer recommended. The CRS petition says that the agency, industry, and CRS share a goal of achieving more efficient drug development, and that FDA can help achieve the goal by clearly communicating to industry through guidance documents when a discrepancy exists.

FDA is aware of the confusion about skin and eye irritation testing, CRS says, but has not developed broad guidance due to a lack of resources. The petition includes draft guidance language developed by CRS.

“Although FDA has stated that Draize test data are not required for primary skin and eye irritation testing,” the petition says, “drug sponsors continue to provide Draize test data. Often, drug sponsors provide Draize data because they believe FDA requires it, despite promising data from other skin and eye irritation methods. As early as 2005, FDA stated Draize data are not required for primary skin and eye irritation. However, of the 137 new molecular entities approved by FDA between the years 2011-2014, 24% were tested for skin and 22% for eye irritancy, and of these, the Draize test was used in 94% of all skin irritation and 60% of all eye irritation tests. Additionally, of these drugs for which the Draize test was conducted, 76% were for systemic, not topical, administration, and thus no irritancy testing of any type was necessary. Unless FDA issues guidance for industry to address this discrepancy, drug developers will not have adequate assurance that FDA does not require Draize data.”

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