Don’t Approve Amryt’s Filsuvez NDA: Petition

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An 11/7 petition filed by Lassman Law & Policy on behalf of an unnamed client asks FDA not to approve a pending NDA for Amryt Pharma’s Filsuvez (oleogel-S10) to treat cutaneous manifestations of junctional and dystrophic epidermolysis bullosa (EB) without additional clinical data demonstrating it is safe and effective for the indication. The petition specifically asks that FDA:

  • refrain from approving Filsuvez to treat EB unless and until Amryt provides “substantial evidence” of effectiveness consisting of, at a minimum, at least one successful and well-controlled pivotal clinical trial that uses the detailed procedures and endpoints described in an FDA 2006 wound guidance;
  • consider the potential consequences for patient health if Filsuvez were to be approved without meeting the guidance standards;
  • deny any Amryt requests to deviate from the wound guidance; and
  • refrain from approving Filsuvez to treat EB unless and until appropriate carcinogenicity studies have been completed and support a finding that it is safe for its intended use.

The petition notes that FDA recently approved Krystal Biotech’s Vyjuvek (beremagene geperpavec-svdt) to treat EB. It says approval of Filsuvez based on an inadequate data set could “not only expose patients suffering from EB to an unproven and potentially unsafe and ineffective treatment, but also could impede many eligible DEB (dystrophic EB) patients from using Vyjuvek…. Because of the serious and progressive nature of DEB, even minor delays in effective treatment pose a serious public health concern.”

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