Category Archives: medical report

EMA Publish ICH, E2F Guideline, on Development Safety Update Reporting

EMA Publish ICH, E2F Guideline, on Development Safety Update Reporting.

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The Development Safety Update Report (DSUR) proposed in this guideline is intended to be a common standard for periodic reporting on drugs under development (including marketed drugs that are under further study) among the ICH regions. US and EU regulators consider that the DSUR, submitted annually, would meet national and regional requirements currently met by the US IND Annual Report and the EU Annual Safety Report, respectively, and can therefore take the place of these existing reports.1 This guideline defines the recommended content and format of a DSUR and provides an outline of points to be considered in its preparation and submission.

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“Please note that the pages on this website are designed to provide you with general information only. We make no warranties, representations or undertakings about any of its content. This includes the completeness, accuracy and fitness for any particular purpose, or the content of any third party site referred to or accessed through it. You are personally responsible for ensuring that the information is correct and we will not be held liable or accountable for any mistakes that occur.”

EMEA Publishes Comments Received on Development of Guidance for Products for Treating Smoking

EMEA Publishes Comments Received on Development of Guidance for Products for Treating Smoking

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Interested party (Organisations or individuals) that commented on the draft Guideline as released for consultation

Stakeholder No.                Name of Organisation or individual
1 Society for Research on Nicotine and Tobacco (SRNT)
2 Royal College of Physicians
3 Smoking Prevention Group of the Spanish Respiratory Society (SEPAR)
4 National Association of Women Pharmacists (UK)
5 EFPIA
6 Merck Sharp & Dohme (Europe) Inc.
7 Johnson & Johnson Consumer Group (JJCG)
8 Dr. Peter Hajek

If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

Damien Bové works as a drug development consultant (pharmaceutical or biotechnology) and regulatory consultant, we work with our clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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This guideline ap
recombinant vaccines for the prevention and treatment of infectious disease, and provides guidance on quality, non-clinical and clinical aspects.
ida consultants freestrategyconsultation 515x64 EMEA Publishes Comments Received on Development of Guidance for Products for Treating Smoking

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“Please note that the pages on this website are designed to provide you with general information only. We make no warranties, representations or undertakings about any of its content. This includes the completeness, accuracy and fitness for any particular purpose, or the content of any third party site referred to or accessed through it. You are personally responsible for ensuring that the information is correct and we will not be held liable or accountable for any mistakes that occur.”

Drug Regulators Publish Q&A on ICH M2 – Common Technical Document for the Registration of Pharmaceuticals for Human Use

Drug Regulators EMEA Publish Q&A on ICH M2 – Common Technical Document for the Registration of Pharmaceuticals for Human Use

This question and answer document is a summary of questions reviewed by the eCTD Implementation Working Group (IWG) on the eCTD Specification.  The questions answered here relate to common questions that relate to the eCTD in all three ICH regions.  Many of the questions received on the Step 2 specification were addressed in Step 4 and do not appear in the list.   Questions concerning the timeframe for implementation of region-specific application types, module 1 implementation, lifecycle management and those questions that relate to items in the specification that direct the reader to each region are answered in guidance documents published for each region.

Questions related to the table of contents for the Common Technical Document (CTD) should be directed to the CTD question and answer section of the ICH Website.

Some of the questions posed so far address change requests to the eCTD Specification.  The change request section of this document addresses all those items received by the eCTD IWG and indicates their status.

This document will be updated as the specification undergoes change control or as new questions are submitted to the eCTD IWG.

It is available on the EMEA website, or email me asking for 082003en and I will send you a copy.

If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

Damien Bové works as a drug development consultant (pharmaceutical or biotechnology) and regulatory consultant, we work with our clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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ida consultants freestrategyconsultation 515x64 Drug Regulators Publish Q&A on ICH M2   Common Technical Document for the Registration of Pharmaceuticals for Human Use

EMEA re-posts Points to Consider on Missing Data

The EMEA has re-posted points to consider on missing data, this points to consider was formally adopted in 2001, however the EMEA has chosen to re post this on the website. It does not appear to have changed since its last posting.

The EMEA a considered missing data as a potential source of bias when analysing clinical trials, interpretation of the results of a trial is always problematic when the number of missing values is substantial. There are many possible sources of missing data, affecting either complete subjects or specific items, missing data violate the strict Intend To Treat principals: measurement of patient outcomes regardless of protocol adherence and analysis performed by treatment assigned, regardless of which treatment patients actually received.  If missing values are handled simply by excluding any patients with missing outcomes from analysis, the following problems may affect the interpretation of the trial results.

The sample size and variability of outcomes affects the power of the clinical trial, power is greater the larger sample size and smaller variability. The reduction in the number of cases available for analysis, completeness of data add ot the resulting reduction of the statistical power.

Bias is the most important concern resulting from the missing data may affect: Designation of the treatment effect, The comparability of the treatment groups, The representativeness of the study sample in relation to the target population. Bias occurs in the estimation of the treatment effect when the relationship between missing this treatment outcomes exists. In most cases it is difficult or impossible to elucidate whether the relationship between missing values and unobserved outcome variable is completely absent. Thus it is sensible to adopt a conservative approach, considering missing values as potential sources of bias.

A possible way of handling incomplete data is to ignore them and perform statistical analysis with complete data only. However, complete case analysis violates intention-to-treat principal. More importantly it is subject to bias, and thus cannot become recommended as the primary analysis confirmatory trial.

The statistical analysis of the clinical trial requires imputation of values to those data that have not been recorded. Many techniques have been used for the imputation of missing data, but none of them can be considered as the gold standard in every situation. The guidance goes on to discuss the many options available:

To cope with situations where response collection is interrupted at one point, the widely used method is last observation carried forward. This method is likely to be acceptable if measurements are expected to be relatively consistent over time.

Best worst case imputation, assigning the worst possible value of the outcome to dropouts are a negative reason (treatment failed) and the best possible value to positive dropouts (kills), is another approach that can be considered, provided it is applied conservatively.

Another simple approach of inputting missing data is to replace the unobserved measurements by values derived from other sources. Possible sources include information from the same subject, from other subject of similar baseline characteristics, the predictive value from an empirically developed model, historical data, etc.

Most methods faced the risk of bias in the standard error downwards by estimating central value and ignoring its uncertainty. This risk can be avoided by some techniques based upon maximum likelihood methodology and with multiple imputation methods. Maximum likelihood methodologies have been proposed that imputation of missing values, as have multiple imputation methods. Maximum likelihood method strategies fit the model by an iterative process. Multiple input methods generate multiple copies of the original dataset replacing missing values by randomly generated values, and analysing is complete sets.

Unfortunately, there is no universally accepted methodological approach and the missing values.the best process of all is the avoidance of missing data in the first place.

If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

Damien Bové works as a drug development consultant (pharmaceutical or biotechnology) and regulatory consultant, we work with our clients to define a drug  development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

ida consultants freestrategyconsultation 515x64 EMEA re posts Points to Consider on Missing Data

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FDA Guidance for Industry – Intergrated Summaries of Effectivenss and Safety: Location within the Common Technical Document

Yes even more FDA guidance this week, Guidance for Industry  Intergrated Summaries of Effectivenss and Safety: Location within the Common Technical Document.

This new guidance focuses on where to place ISE and ISS documents within the structure of the CTD or eCTD. It does not outline in detail the content for the ISE and ISS. The content will be addressed in separate guidance’s.

This guidance is intended to clarify for industry where to include the integrated summary of effectiveness (ISE) and integrated summary of safety (ISS) when submitting applications in the common technical document (CTD) format. The guidance applies to applicants submitting new drug applications (NDAs) or biologic license applications (BLAs) to the Food and Drug Administration (FDA) in the CTD or the electronic common technical document (eCTD) format.

The ISE and ISS are not summaries but rather detailed integrated analyses of all relevant data from the clinical study reports that belong in Module 5. The FDA consider the ISE and ISS critical components of the clinical efficacy and safety portions of a marketing or licensing application.  However there are other modules that need this data and the FDA is providing guidance where this information should be used.

the CDT/eCDT Module 2 contains several clinical sections that are summaries, these should in general follow the outline of the ISE and ISS. It should be noted that the model 2 section is limited to 400 pates and the typical ISS alone us often substantially larger, which in itself necessitates the need for editing. The section include:

  • 2.5 Clinical Overview (aropund 30 pages)
    • 2.5.4 Overview of efficacy
    • 2.5.5 Overview of safety
  • 2.7 Clinical Summary (50 to 400 pages)
    • 2.7.3 Summary of Clinical Efficacy
    • 2.7.4 Summary of Clinical Safety
  • 5.3 Clinical Study Reports
    • 5.3.5.3 Reports of Analyses of Data from More than One Study (including Any Formal Integrated Analysis, Meta Analysis and Bridging Analyses

Sections 2.7.3 and 2.7.4 should contain summarized information from the full ISE and ISS, only in unusual cases should the narrative parts of the full ISE or ISS and the summaries in sections 2.7.3 and 2.7.4 be the same.

Sections 5.3.5.3, should contain more detailed in-depth analysis, and unlike Module 2, Module 5 has no space limitations, Module 5 is the appropriate CTD / eCTD section for analyses containing large appendices of tables, figures and data sets typically found in an ISE and ISS.

More detail is provided in the Guidance and this should be reviewed before starting these sections in your CTD or eCTD.

If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

Damien Bové works as a drug development consultant (pharmaceutical or biotechnology) and regulatory consultant, we work with our clients to define a drug  development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

ida consultants freestrategyconsultation 515x64 FDA Guidance for Industry   Intergrated Summaries of Effectivenss and Safety: Location within the Common Technical Document

Leukaemia – 60 years of progress – its what we work for.

I have just returned from most engaging presentation being held at the Nowgen centre in Manchester, the meeting entitled Leukaemia 60 years of Progress was a look a the progress we have made in treating Leukaemia in the past 60 years and I found it a massive boost to my moral and why I was attracted to working in this industry in the first place.

The Presentation was made by Dr Emm Barnes and Professor Tony Whetton, as part of the Our Kid Medical Manchester celebrations.

The story starts with a staggering fact, in 1948 the survival time from diagnosis to death was 3 days. But in 1948 a Dr Sydney Farber reported the first ever remissions from drug therapy in in the New England Journal Of Medicine, this is considered the birth of modern anti-cancer drug therapy.

The Medical Research Council were quick to support British Researchers such as Henry Basil Marsden from Manchester, in taking up and researching these new technologies, and Edith Paterson so set up the worlds first cancer registry a lead that remains in place today.

Childhood Leukaemia has always being a disease that has attracted alot of attention, the reason for this is clear, following on from the nuclear bombs benign dropped on Nagasaki and Hiroshima, there saw a massive increase in the incidence of Leukaemia in the local child population that survived the initial attacks. There was general fear that the increased use of Nuclear power and weapons discharging radiation into the atmosphere that there would be a huge upsurge in Childhood Leukaemia globally.  Also at this time there was an upsurge in diagnosis of the condition, following improvements in Antibiotic therapies meaning that children were surviving infections and the underlying condition was then being diagnosed.

In the 1960′s and 1970′s the first specialist services for children with cancer were rolled out in the NHS, after a decade of research demonstrated that children who were in specialist centers survived 2.5 times longer.

In the 1970′s the survival in childhood leukaemia stopped being reported in time and started being recorded in percentages, this was a significant milestone in the treatment of this disease, as 50%  has a chance of survival. Issues of long term care started to become important, such as social stigma, employment and insurance problems.

1980′s there was still no standard treatment, (there is still no standard today) but all patients were treated in what is basicaly an ongoing clinical trial, with enrolment being at 80 to 90%, we are currentley at stages 14 of this ongoing programme.

1990′s there were leaps forward in survival and masses of progress in reduced side effects. Gleevec was discovered and developed.

2000′s it has now being discovered that there are 100 different genetic mutations that cause leukaemia, so it is 1 disease of 100 diseases with common symptoms, these are the questions that are facing researchers now and the progress of personalised medicine is starting to define how research will move forward in the future. Gleevec was also launched in 2001, this drug revolutionised therapy, however it is not a cure but a treatment and as with antibiotic therapy we are now starting to see patients develop gleevec resistant leukaemia.

In summary in 60 years of medical research we have gone from a survival time of three days to stage where patients are held in remission almost indefinitely, in this most complex genetic disease.

Damien Bové works as a drug development consultant (pharmaceutical or biotechnology), we work with our clients to define a development target, define a development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch using the contact form or email Damien at damien.bove@idaconsultants.com