FOOD AND DRUG ADMINISTRATION

CENTER FOR DRUG EVALUATION AND RESEARCH (CDER)

Q

Joint Meeting of the

Non-Prescription Drugs and Dermatologic and Opthalmic Drugs Advisory Committee

May 6-7, 2004

 

uestionsIssues for the Committee for NDAC/DODAC

May 6-7, 2004

 

Clinical Efficacy

 

1)FDA presented information on the types of studies that have been conducted to support NDAs for an indication of tinea pedis.  Most studies employed a design where a single concentration and dose regimen were compared to a vehicle control. The efficacy endpoints included complete cure[1], effective treatment[2] and mycological cure[3].  Recently, the primary endpoint in many trials has been complete cure. 

a.Please discuss the merits of the current endpoints and discuss which endpoint is most relevant to assessing the efficacy of a product.

1)      What, if anyPlease comment on what, is the lowest acceptable rate of cure that is clinically meaningful for a topical OTC drug product for the treatment of tinea pedis, using complete clinical and mycological clearance as definition of “cure”?  Please discuss your rationale.

 

2)      Dose response studies are not conducted in the development programs of antifungal products for the treatment of tinea pedis.  Given the efficacy of products currently marketed, Sshould topical antifungal drug development programs for tinea pedis evaluate safety and efficacy at different concentrations, dosing durations, and dosing frequencies?   

F

3)      FDA has received numerous reports of lack of effect for topical antifungal products.  It is not clear if this is a reflection on the actual efficacy of the products or a reflection of consumer expectations regarding cure of tinea pedis. 

a.      Should FDA consider adding information to labeling on the following:

                                                               i.      Cure rate (e.g. complete cure) or effective treatment

                                                             ii.      Expectation of symptom relief

                                                            iii.      Delay in response relative to the end of treatment

b.      Are there claims on the current labeling that may mislead consumers to have greater expectations of benefit than are merited by the efficacy data available?

 

Clinical Microbiology

 

4)                  Given the efficacy rates observed in the clinical trials, should antifungal drug resistance be a concern?

4)                  Should antifungal minimum inhibitory concentrations, (MICs) be determined for clinical isolates during drug development and submitted with the NDA?

5)                   

 

Safety

 

4)                  Expectation of symptom relief

4)                  When to discontinue drug use (especially in a setting where symptoms may persist beyond the recommended duration of treatment)

4)                  Please discuss your view of whether the phrase “cures most” is informative and accurate in OTC consumer labeling?

6)                  Should antifungal drug resistance be a concern given the cure rates observed in the clinical trials? Is the risk of secondary infections (e.g., bacterial cellulitis), related to inadequately treated tinea pedis, of sufficient frequency and severity as to merit communication in OTC consumer labeling? 

a.      Are there specific subpopulations at risk for secondary infections that should be identified on the label?Should the potential for resistance be crafted into OTC labeling?

 Should antifungal MICs be determined for clinical isolates during drug development and submitted with the NDA?

 Is the risk of secondary infections (e.g., bacterial cellulitis), related to inadequately treated tinea pedis, of sufficient frequency and severity as to merit communication in OTC consumer labeling?  If so, what message should be crafted into OTC labeling?

 



[1] Complete cure = negative culture plus no signs or symptoms

[2] Effective Treatment = negative culture and mild or no signs and symptoms

[3] Mycological cure = negative culture