Suggestions to Improve Rare Disease Guidance

Share

Three stakeholders say FDA could improve its draft guidance on a collaborative approach for drug development to be used in pediatric rare diseases that uses Gaucher disease as a model. The National Organization for Rare Diseases (NORD) says that much of the draft guidance is very specific to Gaucher disease and may be difficult to easily extrapolate to other diseases. “While FDA outlines the structure of this collaborative model within Gaucher disease,” it says, “it does not specify which characteristics of this model could also apply to other disease areas. Given the regulatory caution and restraint of many biotechnology and pharmaceutical companies, we can imagine many companies choosing not to pursue this model as they would be unsure of what translates to their specific disease or development pathway.”

NORD also says that FDA does not discuss the many hurdles to collaborative drug development that would prevent the model from gaining popularity, especially obstacles involving intellectual property, patent, and proprietary barriers. Finally, it says the agency does not address how to incorporate patient organizations, which it says are often the unifying participant in drug development.

The Biotechnology Innovation Organization (BIO)  raises three main issues: (1) the guidance lacks detail on applicability across a broad range of rare diseases; (2) the draft outlines use of multi-arm, multi-company clinical studies but does not provide procedural information on how to address challenges of this approach; and (3) the guidance fails to address other possible methodologies that would help reduce the total number of children required for enrollment in clinical trials. BIO expands on these three points and supplies additional comments and line edits.

Pharmaceutical Research and Manufacturers of America (PhRMA) also raises the concern about applicability of the guidance for pediatric rare disease drug development programs other than for Gaucher disease. It recommends revising the document to provide a more general guidance and offer Gaucher disease-specific recommendations in an appendix. PhRMA also calls for further guidance on how analytical methodologies could enhance a collaborative approach to pediatric drug development in other rare diseases.

Read more