Students Suggest Ways to Improve FDA Draft Antisense Oligonucleotide Guidance

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Three students in the Duke Science Regulation Lab, an interdisciplinary course offered through the Duke University law and graduate schools, recommend several steps FDA could take to improve a draft guidance, Investigational New Drug Submissions for Individualized Antisense Oligonucleotide Drug Products: Administrative and Procedural Recommendations. The comment letter says that while the draft “provides an excellent framework for sponsors to develop individualized antisense oligonucleotides, the agency should further improve it by: 

  •          clarifying what constitutes “convincing proof of data” for pre-IND meeting requests and IND application submissions;
  •          helping sponsors with preclinical and clinical trial design; and
  • ·        flagging and communicating unique bioethical considerations for individualized antisense oligonucleotide therapies for patients with rare diseases, including the importance of family involvement in the medical decision-making process, unique privacy concerns, and the high cost of treatment after the investigational stage.

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