Praise for Pediatric Study Plan Guidance Revision
Pharmaceutical Research and Manufacturers of America and the Biotechnology Industry Organization say they share FDA’s goal of ensuring adequate study of and labeling for use of drug and biological products in children. In a comment to an agency draft guidance on the content and process for submitting initial pediatric study plans and amended plans, the two groups commend FDA for revising a 2013 draft guidance by incorporating stakeholder feedback and reissuing the draft guidance for further comment. The two groups also submit specific comments on various sections of the draft.
In its comment, Novo Nordisk says the revised guidance “provides helpful clarifications regarding provisions in the 2013 draft guidance, an updated Study Plan Template, and several new sections. These changes have added to the overall quality of the guidance and will facilitate alignment between the sponsor and FDA.”
Similar praise for FDA’s incorporation of public comments leading to changes in the guidance comes from Pfizer in its comment letter.
A response from the International Consortium for Innovation and Quality in Pharmaceutical Development notes that very limited guidance is provided on how to effectively align the initial pediatric study plan with the European Union’s counterpart plan.
Finally, specific line-by-line comments were submitted by Quintiles and Regeneron.