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CDER Report to the Nation: 2001


Table of Contents

Drug Review (continued)

Index

Over the Counter Drug Review

In 2000, we approved six new drugs and one new use for over-the-counter marketing.

New OTC medicines and new uses

Miconazole nitrate (Monistat 3) is to treat vaginal yeast infections and external itching associated with a vaginal yeast infection. This is not the first OTC approval for this compound.

Miconazole nitrate (Monistat 1). This is a one-day treatment regimen vs. a three-day treatment regimen under Monistat 3 (above) and a seven-day treatment regimen under Monistat 7.

The combination clemastine fumarate, pseudoephedrine hydrochloride and acetaminophen (Tavist A/S/H) treats symptoms of hay fever and other seasonal allergies. This is the first approval for this combination but not the first time for any of these compounds on the OTC market.

Chlorhexidine gluconate and ethyl alcohol (Avagard-CHG) is for use as a surgical hand scrub or hand wash for healthcare personnel. This is not the only chlorhexidine product available OTC.

Aspirin, 500 mg, (Bayer Extra Strength Aspirin for Migraine Pain) is for the treatment of migraine headaches. This represents a new OTC use for aspirin.

A cream with 1 percent butenafine hydrochloride (Lotrimin Ultra) is an Rx-to-OTC switch for the use of this drug product to treat jock itch, athlete's foot and ringworm.

A nasal spray containing cromolyn sodium (Nasalcrom) is now approved for OTC use down to 2 years of age.

Improved labels for OTC medicines

American consumers are benefiting from easy-to-understand labels on drugs they buy without a prescription.

Titled "Drug Facts," the new labels become mandatory in May 2002.

These new labels improve a consumer's ability to use an OTC drug safely and properly and to find and understand its benefits and risks.

Public meeting airs OTC antihistamine issues

A citizen's petition submitted in 1997 asked us to consider switching the antihistamines loratadine, fexofenadine and cetirizine to OTC marketing status.

Last year, our advisory panel of outside experts concluded that these drugs would be a reasonably safe alternative for consumers to treat nasal symptoms of seasonal and nonseasonal allergies.

We and the manufacturers are considering their recommendation.

How we regulate OTC drugs

We publish monographs that establish acceptable ingredients, doses, formulations and consumer labeling for OTC drugs.

Products that conform to a final monograph may be marketed without prior FDA clearance.

Drugs can also be approved for OTC sale through the new drug review process.

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Generic Drug Review

We received 320 submissions and approved 234 generic drug products in 2001, including 40 separate molecules in 55 products that represent the first time a generic drug was available for the brand-name product. The median approval time for generic drugs was 18.1 months.

We are making changes to decrease the overall time to approval of applications. The median statistic for total approval time has hovered at about 18 to 19 months for five years. Planned changes include several efficiencies in the review process and hiring of additional chemistry reviewers.

Generic drug statistics

  • 234 generic drug approvals
  • Median approval time: 18.1 months
  • 320 submissions
  • 73 tentative approvals
  • 13 approvables

Tentative approvals

  • 1995: 15
  • 1996: 25
  • 1997: 40
  • 1998: 40
  • 1999: 56
  • 2000: 61
  • 2001: 73

Generic drug Web site

You can find more information about our generic drug program at http://internet-dev.fda.gov/cder/ogd/index.htm.

Notable 2001 generic drug approvals

Examples of first-time approvals for the brand-name equivalent are:

  • Fluoxetine (Prozac) used to treat depression.
  • Buspirone (BuSpar) used to treat anxiety disorders.
  • Famotidine (Pepcid) used to treat ulcers.
  • Lovastatin (Mevacor) used to control lipid profiles.
  • Omeprazole (Prilosec) used to treat ulcers.

Our approval of generic versions of these drugs last year could save American consumers and the federal government hundreds of millions of dollars each year.

We also issued 73 tentative approvals and 13 approvables last year:

  • Tentative approvals. The only difference between a full approval and a tentative approval is that the final approval of these applications is delayed due to existing patent or exclusivity on the innovator drug product. These and other legal issues continue to be a challenge to the generic drug review program. While tentative approvals represent a full workload for us, they are only displayed in the chart once they are converted to full approvals. For example, some of the 234 approvals in 2001 represent conversions of tentative approvals granted in 2001 or previous years.
  • Approvables. Approvable applications are reviewed and ready for full approval except for a pending labeling issue, generally related to legal matters such as exclusivity. These also represent full workload but are only displayed once they are converted to full approval.

Building consumer confidence in generic drugs

To promote consumer confidence in the safety and effectiveness of generic drugs, we are developing a multimedia education program. The goal will be to educate health care practitioners and consumers about the rigorous review and approval process that generic products undergo before we approve them for sale in this country. We are creating partnerships and a network with other government agencies. The efforts will include:

  • Focus groups to determine what information is needed.
  • Print media public service announcements.
  • Radio public service announcements.
  • Presentations at organizational meetings for health-care professionals.

Generic drug electronic submissions

The electronic submissions initiative is a continuing priority. We developed and issued a draft guidance on a standardized format for application submission that will be compatible for both new drug and generic applications. This should promote industry participation in the program.

How we approve generic drugs

Generics are not required to repeat the extensive clinical trials used in the development of the original, brand-name drug. Instead, they must show bioequivalence to the brand-name reference listed drug.

Scientists measure the amount of the generic drug that reaches the bloodstream and how long it takes to get there. This rate and extent of absorption is called bioavailability. The bioavailability of the generic drug is then compared to that of the brand-name reference listed drug.

The generic version must deliver the same amount of active ingredients into a patient's bloodstream and in the same time as the brand-name reference listed drug. Brand-name drugs are subject to the same bioequivalency tests as generics when their manufacturers reformulate them.

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User Fee Program

We met all of the demanding review goals of the Prescription Drug User Fee Act for applications submitted in fiscal year 2000, the latest year for which there are meaningful review statistics. We are on track for meeting them in fiscal year 2001.

The law, first enacted in 1992, was renewed for an additional five years in 1997. Under the law, the drug industry pays user fees for new drug applications, efficacy supplements and some other activities. User fees helped us hire additional scientists to perform reviews. As a result, we are able to respond more rapidly to new drug applications without compromising review quality. That means more quality drug products are reaching American practitioners and consumers more quickly.

We agreed in 1992 to specific performance goals for the prompt review of four categories of submissions: original new drug applications, resubmissions of original NDAs, efficacy supplements to already approved marketing applications and manufacturing supplements to already approved new drug marketing applications.

With the 1997 reauthorization, known as PDUFA II, we committed to additional goals intended to improve our responsiveness to and communication with industry sponsors during the early years of drug development. These goals specify timeframes for activities such as scheduling meetings and responding to various sponsor requests. While the intent of the 1992 law was to speed up the review process, the intent of PDUFA II is to speed up the entire drug development process.

We have encountered challenges in trying to meet the PDUFA II goals. The fees we collected have been significantly less than expected due to a reduced number of new drug applications and an increased proportion of submissions whose fees were exempted or waived. At the same time, the number of goal-driven tasks for which we collect no fees increased substantially under PDUFA II. So far we have been able to meet most of our performance goals.

Our efforts to meet the PDUFA II goals may have had an unintended impact on approval times of standard new drug applications. These approval times have begun to increase because more applications require multiple review cycles to reach approval. This may be due to the fact that reviewers have been pressed to meet the additional PDUFA II goals for drug development, such as meeting management, special protocol assessments and responses to clinical holds. Reviewers have had less time for resolving last-minute problems with these standard applications before the action goal date. Such applications must undergo an additional review cycle with its attendant timeframes and goals. Statistics on this trend are preliminary, and we are watching it closely.

User fee report

Our full report to Congress on our user fee performance is at http://www.fda.gov/oc/pdufa/report2001/pdufareport.html.

User fee review goals

Under PDUFA II, our review goals continued to shorten. By fiscal year 2002, the goals called for us to review and act on 90 percent of:

  • Priority new drug applications and efficacy supplements (those for products providing significant therapeutic gains) within six months.
  • Standard new drug applications and efficacy supplements within 10 months.
  • Manufacturing supplements not requiring prior approval within six months, and those requiring prior approval within four months.
  • Class 1 resubmissions of original applications (those involving minor changes) within two months, and Class 2 resubmissions of original applications (those involving changes not specifically identified in the user fee goals document) within 6 months.

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Manufacturing Supplement Review

We review many types of changes in the manufacturing of drugs and their packaging, including location, machinery, processes and suppliers of raw materials. We do this so that American consumers can trust the high quality of FDA-approved medicines. Manufacturers notify us in advance of certain manufacturing changes. These are known as "manufacturing supplements" to new drug or generic drug applications. In many cases, they represent the industry's efforts to modernize plants and equipment or to make manufacturing more efficient

New drug manufacturing supplements

  • 1,394 approvals
  • Median FDA review time: 4.4 months
  • Median total approval time: 4.5 months

Generic drug manufacturing supplements

  • 2,333 approvals
  • 2,453 receipts

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Antimicrobial Resistance

The emergence of drug-resistant bacteria is considered to be a major threat to the public health. We play an active role in the federal government's efforts to address this growing problem and its effects on drug development and regulation.

We are developing approaches to provide education and information on the appropriate use of antibiotics to health care professionals and consumers.

Details of our efforts and other resources are at http://www.fda.gov/cder/drug/antimicrobial/default.htm.

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Electronic Submissions

Currently, the entire archival copy of the new drug application, postmarketing safety reports and advertising and promotional material can be submitted in electronic format without paper. We find submissions provided electronically as described in our guidance documents both easier to process and more efficient to review.

While the number of electronic submissions continues to increase each year, only 15 percent of supplements and amendments are submitted in electronic format. Over the next year, we look to industry to increase the number of electronic-only submissions.

Over the past year, we have worked on and begun evaluating electronic submission projects that will:

  • Provide a Web-based tool for companies to register establishments and list products.
  • Make use of standardized study data submissions to improve the review process.
  • Improve the way we process and review labeling changes.

We also are working on the ability to accept the following documents in electronic format:

  • Abbreviated new drug applications for generic drugs.
  • Annual reports for marketing applications.
  • Investigational new drug applications for premarket clinical studies.
  • Individual case safety reports for marketed drugs.

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Pregnancy labeling

We have reviewed the current system of labeling drugs for use by pregnant women and are developing an improved, more comprehensive and clinically meaningful approach.

We are consulting with multiple government agencies, medical experts, consumer groups and the pharmaceutical industry to develop this new labeling format.

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Assessing Data Quality, Research Risks

To protect the rights and welfare of volunteers and verify the quality and integrity of data submitted for our review, we perform on-site inspections of clinical trial study sites, institutional review boards, sponsors, study monitors and contract research organizations. Our programs to protect volunteers are challenged by increases in the number of clinical trials; the types and complexity of products undergoing testing; and the increased number of trials performed in countries with less experience and limited or no standards for conducting clinical research.

When obtaining data about the safety and effectiveness of drugs, sponsors rely on human volunteers to take part in clinical studies. Protecting volunteers from research risks is a critical responsibility for us and all involved in clinical trials, including manufacturers, institutional review boards, study sponsors, clinical investigators and their staffs, monitors, contract research organizations, hospitals and other institutions.

Sponsors and clinical investigators protect volunteers by ensuring that:

  • Clinical trials are appropriately designed and conducted according to good clinical practices.
  • Research is reviewed and approved by an institutional review board.
  • Informed consent is obtained from participants.
  • Ongoing clinical trials are actively monitored.

Special attention is given to protecting vulnerable populations, such as children, the mentally impaired or prisoners.

We require sponsors to disclose financial interests of clinical investigators who conduct studies for them. This helps identify potential sources of bias in the design, conduct, reporting and analysis of clinical studies.

Inspections of clinical research in 2001

We conducted a total of 463 inspections of clinical research:

  • 258 U.S. clinical investigators
  • 38 foreign clinical investigators
  • 139 institutional review boards
  • 28 sponsors, monitors or contract research organizations

International inspections of clinical research

We have conducted 457 inspections of clinical research in 47 countries from 1980 to 2001.

We participate in international efforts to strengthen protections for human volunteers worldwide and encourage clinical investigators to conduct studies according to the highest ethical principles.

These efforts include our work with the International Conference on Harmonization and the Declaration of Helsinki.

Top 5 deficiency categories for clinical investigator inspections

  • Failure to follow the protocol
  • Failure to keep adequate and accurate records
  • Problems with the informed consent form
  • Failure to report adverse events
  • Failure to account for the disposition of study drugs

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Drug Review Team

We use project teams to perform drug reviews. Team members apply their individual special technical expertise to review applications:

  • Chemists focus on how the drug is manufactured. They make sure the manufacturing controls, quality control testing and packaging are adequate to preserve the drug product's identity, strength, potency, purity and stability.
  • Pharmacologists and toxicologists evaluate the effects of the drug on laboratory animals in short-term and long-term studies, including the potential based on animal studies for drugs to induce birth defects or cancer in humans.
  • Physicians evaluate the results of the clinical trials, including the drug's adverse and therapeutic effects, and determine if the product's benefits outweigh its known risks at the doses proposed.
  • Project managers orchestrate and coordinate the drug review team's interactions, efforts and reviews. They also serve as the review team's primary contact for the drug industry.
  • Statisticians evaluate the designs and results for each important clinical study.
  • Microbiologists evaluate the effects of anti-infective drugs on germs. These medicines-antibiotics, antivirals and antifungals-differ from others because they are intended to affect the germs instead of patients. Another group of microbiologists evaluates the manufacturing processes and tests for sterile products, such as those used intravenously.
  • Biopharmaceutists evaluate the rate and extent to which a drug's active ingredient is made available to the body and the way it is distributed, metabolized and eliminated. They also check for interactions with other drugs.
  • Clinical pharmacologists evaluate factors that influence the relationship between the body's response and the drug dose. They assist physician members of the team in assessing the clinical significance of changes in the body's response to drugs through the use of exposure-response relationships.

Scientific training for reviewers

Our systematic, internal training program in science, policy and job-related skills for reviewers is based on core competencies, learning pathways and individual development plans.

  • The program grew from seven courses offered in 1997 to more than 20 currently offered. Existing courses were also revised.
  • Reviewer participants increased six-fold, from about 250 in 1997 to 1,500 currently.
  • Last year, we brought in 44 visiting professors to talk directly to individual review divisions about critical, new drug-related research and techniques.
  • We collaborate with five local universities to present special courses. Last year we examined the effects of drug therapy on the heart.

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