Suggestions for FDA Draft Guidance on Some Oncology Studies
Pharmaceutical Research and Manufacturers of America (PhRMA) says it commends FDA for publishing a draft guidance on streamlining nonclinical safety studies for some oncology pharmaceuticals, particularly biologics and conjugated products. The association’s comment letter says issuance of the draft is a significant step toward implementing FDA’s Roadmap to Reducing Animal Testing in Preclinical Safety Studies. PhRMA says that while it strongly supports the draft guidance, maximizing its impact will depend on (1) preserving the flexibility inherent in existing FDA and International Council for Harmonization guidances; (2) providing sufficient regulatory predictability for sponsors making early development decisions; and (3) ensuring consistent implementation across review divisions. PhRMA submits recommendations it says will support the three objectives.
The American Association for Cancer Research (AACR) says it strongly supports FDA’s efforts to modernize nonclinical safety assessment and makes recommendations in these areas it says will further strengthen the draft:
- expand the discussion of weight-of-evidence assessments;
- expand product-specific recommendations; and
- clarify that the weight-of-evidence assessments are iterative.
“AACR applauds FDA’s continued leadership in advancing modern, science-based approaches to oncology drug development and believes this draft guidance represents an important step toward more efficient, evidence-based nonclinical safety assessment for oncology therapeutics,” the letter concludes.
The Critical Path Institute encourages FDA to continue fostering flexibility in the application of the guidance across therapeutic areas and product types while recognizing the importance of context-specific scientific justification.
Finally, the American Association of Pharmaceutical Scientists provides specific line-by-line comments.