FDA Regulatory Processes and Standards for Review and Approval of Opioid Analgesics: An Educational Primer and Conversation February 10, 2009 Hilton Washington DC/Rockville Rockville, Maryland 20852
FDA’s Involvement in Preventing Opioid Abuse presented by Michael Klein, PhD, Director Controlled Substance Staff, FDA/CDER
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Controlled Substance Staff (CSS) •
Located in the FDA/CDER Office of the Center Director (2000)
• •
Comprised of scientists, physicians & pharmacists Recommends scheduling and risk management, based upon NDA review of pharmacology, clinical effects, public health risks, and abuse/ misuse/ safety concerns
• Advises sponsors on abuse potential potential assessment (part of safety review) • Responds to citizens petitions •
Provides an annual estimate of medical need of C-II drugs
•
Reviews research protocols for C-I drugs
•
Works with SAMHSA, NIH/NIDA, CDC, ASH
•
Works with the DHHS & DOS on international issues related to United Nations activities 2
Food Drug & Cosmetics Act (FD&CA 1938) • FDA - Public Health Mission ensure that Americans have to access to safe and effective drug products
– Safe and Effective under Labeled Conditions of Use
NDA Requirements Under FD&C Act If potential for abuse exists, the following must be included in the NDA: ∙
All data pertinent to abuse of the drug ∙ Proposal for scheduling under the Controlled Substances Act ∙
Data on overdose
21 CFR § 314.50 (5) (vii) 4
Controlled Substances Act (CSA) 1970 • Purpose – to combat drug trafficking, comply with international treaties, and assure availability of controlled substances for legitimate medical use • Establishes legal procedures and DHHS role – Recommend scheduling – Review and advise on Schedule I research protocols – Provide an annual estimate of U.S. medical needs for Schedule I and II substances
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Interactions with Review Groups • Office of New Drug Evaluation – Division of Anesthesia, Analgesia, and Rheumatology Rheumatology Products – Division of Neurology Products – Products – Division Division of of Psychiatry Endocrine and Metabolic Products – Division of Reproductive and Urologic Products Gastroenterol Gastroenterology ogy Products – – Division Division of of Cardiovascular and Renal Products – Division of Nonprescription Products
and Epidemiology •• Office CenterofforSurveillance Veterinary Medicine 6
Identifying the problem
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Pre-Market Product Review New Drug Review – Investigational New Drug (IND) • Process by which a sponsor advances to next stage in drug development (clinical trials) – Animal Pharmacology – Animal Pharmacology and Toxicology Toxicology Studies Studies – Manufacturing ng Information Clinical Protocols and Investigator Information – Manufacturi
– New Drug Application (NDA) • Formal application for approval of a new drug 8
Abuse Potential Assessment Data in NDA ∙
Ability of a psychic CNS-active drug to produce a reinforcing or positive effect relative to a control ∙ Data correlates
with and predictive of the risk of
addiction −
CSA Scheduling Proposal
−
Chemistry
−
Pre-clinical and Human Pharmacology
−
Clinical Trial Data
− −
Data on Overdose Epidemiology Data (** If available)
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Drug Abuse Assessment Data on the drug’s abuse potential can be obtained at critical times in the drug development process Phase 1 Spontaneous Reports Performance Measures Physiology
Preclinical Biochemistry Global Pharmacology Animal Behaviors Structure
Phase 2-3 Subjective Effects Discontinuation Drug Seeking Behavior
Phase 4 Post Marketing Adverse Effects Epidemiology Actual Abuse 10
Drug Scheduling
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DHHS & DEA Roles in Scheduling • DHHS scientific-medical recommendation is binding on DEA with respect to scientific and medical determinations and whether a substance should not be controlled • FDA evaluates the abuse potential of the drug and prepares a scheduling recommendation based on scientifically verified data – Seeks the advice of NIDA/NIH; interacts with SAMHSA – After FDA approves approves the NDA, DEA finalizes scheduling – Final decision making authority is delegated to DEA 12
Five Levels of Drug Control in CSA Schedule I:
•
•
• Not approved in the U.S. • High abuse potential (most restrictive) • Lack of safety for use • Special DEA license for research Schedules II-V:
• Approved medical use in the U.S. • High (C-II) to limited (C-IV/V) physical or psychological dependence liability 13
Schedule II Drugs OPIATES BARBITURATES Fentanyl 100-250 µg/2mL 2.5-10 mg/patches
Schedule V Codeine (comb.) Dihydrocodeine Diphenoxylate
Zaleplon Gamma hydroxybutyrate (GHB) Dronabinol
Zolpidem Eszopiclone Sibutramine
OPIATES
Modafinil
DEPRESSANTS STIMULANTS
Alprazolam Diazepam
BENZODIAZEPINES
Midazolam Quazepam
OTHER
Anabolic Steroids
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Managing the Risk of Abuse
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Drug Scheduling Under CSA • Scheduling under the CSA does not manage all risks of misuse, abuse, and overdose of drugs • Drug scheduling alone cannot address many challenges related to the modern health care system −
Current patterns of medical practice of access to information and drugs − Ease
• CSA Regulations Require Registration and Vary with Schedules 17
Schedule I
Schedule II
Schedule III
Schedule IV
Schedule V
Registration
Required
Required
Required
Required
Required
Recordkeeping
Separate
Separate
Readily Retrievable
Readily Retrievable
Readily Retrievable
Distribution Restrictions
Order Forms
Order Forms
Records Required
Records Required
Records Required
Dispensing Limits
Research use only
Rx: written No Refills
Rx: written or oral Refills with MD's authorization
Rx: written or oral Refills with MD's authorization
OTC (Rx drugs limited to MD's order
Vault/Safe
Vault/Safe
Secure Storage
Secure Storage
Secure Storage
No
No
No
Yes
Yes
(Some drugs limited by Schedule II)
(Some drugs limited by Schedule II)
(Some drugs limited by Schedule II)
Manufacturing Security Manufacturing Quotas
Permit to import,
Import/Export Narcotic
Reports to DEA Mfr.& Distributor
Permit
Permit
Permit
Permit
declaration to export
Yes
Yes
Yes
Mfr. only
Mfr. Only
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CSA-Regulated Entities 1. Drug Source
2. Distributor
(Manufactu (Manufacturer rer or Importer
3. Health care provider
4. Patient 19
Risk Management • Risk management is an extension of the product label • Goals: Safe Use – Prevention of accidental overdose – Prevention of unintended exposure – Proper patient selection, – Prevention of misuse and abuse
• Risk management tools – To be discussed in detail in the following presentation
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When is risk management considered for a drug with abuse potential? C S S A C o on t r r o oll s
La b b e e ll ii ng C l l i in i c c a a ll B e e ne f f ii t t s
I nhe rr e e nt R ii sk s
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When necessary to maintain a positive risk : benefit balance
m e n t e g a n a M M s k R i s s o l s r o t r C SA SA C C o n g n i n l i
L a b e s s t t i i f e B e n C l ii n n i c c a l l
s k s s i R R t n e r e h n I
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Conclusion • The evaluation of new drugs (NDAs) for abuse potential is based upon a comprehensive comprehensive interdisciplinary scientific review • Abuse potential potential evaluation a and nd drug schedu scheduling ling are a shared responsibility responsibility by DHHS and DEA • If a drug has potential for abuse, appropriate abuse abuse-related data must be included in the NDA for review • Regulatory tools to prevent abuse include CSA scheduling and risk management programs – See Food and Drug Administration Amendment Amendments s Act of 2007 (FDAAA) 23