Objections, Support for FDA Drug Regulatory Modernization
Public Citizen says an FDA proposal to use and publicly post, upon approval of an NDA or BLA, an abbreviated integrated review document in place of the more detailed individual medical, chemistry, pharmacology, statistical, clinical pharmacology, biopharmaceutics, and risk assessment and risk mitigation reviews, among others, that have been prepared and regularly posted on the agency Web site for many years “is one of the most dangerous proposals by FDA in years and must not be permitted.” In comments to an agency docket on improving approval package documentation and communication as part of modernization of the new drugs regulatory program, the advocacy group says the “ill-conceived proposal would, at the least, be a major step backwards in agency transparency with respect to the data that the agency relies on when approving new drugs or biologics and the agency’s assessment of these data.”
Beyond the issue of review transparency, Public Citizen writes, it is unclear from the agency proposal whether individual reviewers in each discipline would even continue to write separate review documents, as currently occurs. The letter says eliminating production of review documents by the individual disciplines “could lead to dangerous groupthink and inhibit the expression of important minority views, further undermining FDA’s review and approval process for drugs and biologics and threatening public health.”
Taking a contrasting position, Pharmaceutical Research and Manufacturers of America (PhRMA) comments that it “strongly supports a vision of a future new drug regulatory program paradigm that is optimized for early identification and resolution of key issues, promoting efficiencies and effectiveness in drug development, and conducive to highly productive and timely interactions between FDA and sponsors during drug development.
PhRMA says it believes that the new integrated review documents will provide the most meaningful information to stakeholders and encourages the agency to formalize use of integrated review documents to communicate the basis of regulatory approval decisions to the public as a comprehensive and more effective approach to providing clarity on FDA decisions on regulatory approvals. The response also includes specific comments on several issues.