FDA Denies Petition Seeking ‘Optimal’ Naloxone Dose

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FDA has denied a citizen petition from Adapt, the manufacturer of Narcan (naloxone) Nasal Spray, 4 mg, indicated for treating opioid overdose, asking that it publish a guidance for all naloxone products to identify the “optimal fixed initial dose for each route of administration as well as the required exposure levels to achieve an efficacious onset of action and duration of effect.” In the petition, the company argued that there has been “an acceleration of expanded naloxone access to new potential witnesses and more potent and faster onset opioids (e.g., fentanyl) being implicated in a growing proportion of opioid overdose deaths. These provide an urgent need to ensure that new naloxone formulations intended for emergency treatment in all settings, (including non-medical settings), by anyone (including non-medically trained individuals), deliver a consistently efficacious fixed initial dose that achieves optimal exposures to naloxone (i.e. plasma levels) and can be easily and rapidly administered.”

The petition says that before approving new naloxone, the agency should define the required pharmacokinetic exposure levels for naloxone that are required to be achieved from the recommended optimal dose of naloxone, including time to onset and duration of effect. And it requests that FDA require “naloxone products from an applicant to utilize a product formulation and device that allows for an individual, (including a non-medically trained individual) in all settings, (including non-medical settings), to readily and rapidly administer a fixed initial dose.”

In denying the petition, FDA disagreed with the company’s contentions that an optimal fixed dose of naloxone for each route of administration should be specified. “Two naloxone products with the same nominal dose but different formulations could produce substantially different naloxone exposure levels depending on how quickly and how much of the naloxone is absorbed,” the agency said. “Those rates may be significantly affected by the specific formulation, including the nature and amounts of inactive ingredients. In addition, each application will be evaluated will be evaluated taking into account the relevant standards for approval.”

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