FDA Safety Assessment, Reporting Guidance Analyzed
Five King & Spalding attorneys say an FDA draft guidance on safety event analysis and reporting for IND and bioavailability/bioequivalence studies signals the agency’s “current attention on the IND sponsor’s analysis of adverse events that may require expedited reporting to FDA and to all participating investigators.” In an online analysis, the attorneys say the draft particularly emphasizes the agency’s current focus on an aggregate analysis of safety events, including a comparison of the incidence of the event in the investigational drug group and the control group for the determination of a possible causal relationship between the investigational drug and the event.
Although the analysis of a possible causal relationship may require unblinding, the attorneys say, the draft extensively discusses the risk of the unblinding of safety data on the trial’s integrity and potential safeguards to mitigate the risk. “Sponsors may wish to carefully review the recommendations related to aggregate safety data analyses and crosswalk FDA’s recommendations to current processes within the company for safety surveillance, including unblinding for analysis of safety events, in IND investigations,” they write.
FDA also proposes that sponsors develop a formal written prospective plan for safety surveillance that is specific to the premarket development program for the investigational drug and subject to FDA inspection.