Sequencing Regulatory Pathway ‘Helpful’: Comment
The Critical Path to TB Drug Regimens says that an FDA draft guidance on infectious disease next generation sequencing laying out a regulatory pathway that better defines the regulatory requirements for next generation sequencing (NGS) will be helpful to those developing diagnostic devices for antimicrobial resistance, and tuberculosis in particular. Commenting on the draft guidance, the group says the regulatory-grade reference database requirements for microbial identification and antimicrobial resistance are undefined and quite different. “It would be helpful to separate these two concepts,” it says, “regarding the regulatory-grade reference database.” The letter also asks for clarification of whether the guidance would also apply to a device that can detect multiple microbial pathogens, and asks for a section devoted to targeted sequencing.
Roche’s response appreciates the “innovative and flexible regulatory framework that FDA has outlined for the regulation of NGS devices” in this guidance and other forums. The company suggests that the approaches the agency is following for the regulation of NGS devices could and should be applied to other in vitro diagnostic technologies. And it says that FDA should follow precedent and expressed policy focused on NGS tests rather than taking a systems approach to review.
In its comment, AstraZeneca says that the guidance’s definition and clarity on the “one system” approach are very welcome and provide clarity on the scope of what needs to be regulated. “This appears consistent with other guidance but will prove burdensome,” it declares. “Are there any opportunities to consider ‘modular’ approvals in order to facilitate a ‘mix and match’ approach? For example, could the specimen collection module be approved and applied to other relevant processes without duplicating the review? Could this be applied to other modules such as sample preparation or sequencing chemistry/data collection? If so, how could the approval of such modules be shared so as to avoid unnecessary duplication of experimental work and FDA review activity?”