Don’t Approve Vasostrict Dosing Changes: Petition
Attorney Scott Lassman has petitioned FDA to refuse to approve proposed dosing modifications sought by Par Sterile Products for its Vasostrict (vasopressin injection) based on patient genotype. The 1/29 petition says the Par request should be denied “in the absence of rigorous and convincing clinical evidence, including evidence from one or more adequate and well-controlled clinical studies, demonstrating that the proposed labeling changes are appropriate and necessary to support the safe and effective use of Vasostrict.”
The petition says it appears that Par submitted its sNDA not because there is a real clinical need to improve the safe or effective use of vasopressin in the hospital setting, but rather as an anti-competitive, “evergreening” tactic to delay or block impending generic competition. It says the evidence supporting the change appears to be an ad hoc analysis of a small pharmacokinetic (PK) study in 41 healthy volunteers without any scientific evidence demonstrating that the PK results, even if valid, have any clinical significance.
Specifically, the petition asks that FDA:
- refuse to approve changes to the dosing instructions for Vasostrict based on pharmacogenomic information in the absence of:
o a clearly defined clinical need for such dosing modifications;
o rigorous scientific evidence demonstrating that there are statistically significant differences in vasopressin clearance and steady-state concentration based on a patient’s leucyl/cystinyl aminopeptidase rs4869371 genotype;
o rigorous scientific evidence, including evidence from one or more prospective, randomized controlled trials demonstrating that the above-described PK differences, if any, are clinically significant; and
o a demonstration that the proposed labeling changes based on genotype differences have clinical relevance and utility and are actionable by healthcare professionals in the acute care setting in which Vasostrict is administered; and
- provide the petition to CDER reviewers responsible for assessing, providing recommendations on, and/or taking action on Par’s sNDA.