Tag Archives: conditional approval

Pfizer Gets Paid for Running a Phase 3 Programme – we can all do this

Pfizer Gets Paid for Running a Phase 3 Programme – we can all do this.

I have just been reading a press release from the FDA that contains a really valuable insight-

Pfizer Inc. today announced the voluntary withdrawal from the U.S. market of the drug Mylotarg (gemtuzumab ozogamicin) for patients with acute myeloid leukemia (AML), a bone marrow cancer. The company took the action at the request of the U.S. Food and Drug Administration after results from a recent clinical trial raised new concerns about the product’s safety and the drug failed to demonstrate clinical benefit to patients enrolled in trials.

Mylotarg was approved in May 2000 under the FDA’s accelerated approval program. This program allows the agency to approve a drug to treat serious diseases with an unmet medical need based on a surrogate endpoint – a laboratory measurement or a physical sign used as a substitute for a clinically meaningful endpoint that directly measures how a patient feels, functions, or survives.

Whilst most products that fail in phase 3 cost their sponsor allot of money, this one had a very powerful damage limitation programme in place, in that during the 10 years that the phase 3 was ongoing, Pfizer were selling this product, it was on the market using accelerated approval (conditional approval in Europe), its a powerful regulatory pathway that is great for all concerned.

For More information on this regulatory pathway drop me an email at action@damienbove.com

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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my 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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European Commission 2006 Guidance Reminder – Conditional Approval

European Commission 2006 Guidance Reminder- Conditional Approval

In the case of certain categories of medicinal products,however, in order to meet unmet medical needs of patients and in the interests of public health, it may be necessary to grant marketing authorisations on the basis of less complete data than is normally the case and subject to specific obligations, hereinafter ‘conditional marketing authorisations’

The categories concerned:

  1. medicinal products which aim at the treatment, prevention or medical diagnosis of seriously debilitating or life-threatening diseases,
  2. medicinal products to be used in emergency situations, in response to public health threats duly recognised either by the World Health Organisation or by the Community in the framework of Decision No 2119/98/EC;
  3. medicinal products designated as orphan medicinal products in accordance with Article 3 of Regulation (EC) No 141/2000.

All the following need to be met:

  1. the risk-benefit balance of the medicinal product, as defined  in Article 1(28a) of Directive 2001/83/EC, is positive;
  2. it is likely that the applicant will be in a position to provide the comprehensive clinical data;
  3. unmet medical needs will be fulfilled
  4. the benefit to public health of the immediate availability on the market of the medicinal product concerned outweighs the risk inherent in the fact that additional data are still required.

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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“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.”

Conditional Approval – An important short cut to the market

The EMEA (European Medicines Agency) can recommend a product is given Conditional Approval, the CHMP (Committee for Medicinal Products for Human Use) bases a positive opinion on the data available. Usually this data is not sufficient to award a full approval, but is of such a positive nature and the drug of such obvious benefit to a group with high unmet medical need that they will allow it to go to market whilst the clinical data is strengthened.

The FDA has a similar approval process.

The CHMP make this recommendation on the understanding that the company will undertake an agreed programme of works aimed at strengthening the data package. The company are under an obligation to fulfill this programme of work. In order to ensure that they do the conditional approval is reviewed annually until full approval is granted.

This can be an important regulatory avenue for companies that have relatively well known drugs that are being targeted at a new indication, as long as there is considerable unmet medical need, and very strong indication of safety, and a good indication of ethicacy. Because you can in effect go to market after phase 2, and the revenues raised can help fund your phase 3 programme, it can accelerate your development and maintain your equity standing.

If conditional approaval in pursued in an orphan indication you could be in the market place with a very limited number of patients and perhaps a single clinical trial.

During our work as development consultants we have pursued this path for clients and it is an effective tool for maximising the outcomes of R&D spending but also improtant in ensuring patients with a despirate need for drugs can get access as quickly as possible.

If you would like to know more about this please feel free to get in touch.

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