Naloxone Expanded Access: OTC status Considerations for a Nonprescription Drug Development Program

Similar documents
Documents Regarding Drug Abuse Assessments

CSS Perspective - Opioid Risk Management

Can a system like the U.S. OTC monographs work for ENDS?

Guidance for Industry DRAFT GUIDANCE. This guidance document is being distributed for comment purposes only.

Test Bank for Basic Pharmacology for Nurses 14th edition by Clayton, Stock and Harroun

Over-the-Counter Pediatric Liquid Drug Products Containing Acetaminophen

TOBACCO PRODUCT OR MEDICAL PRODUCT?

Heng-Jung Lien 衛生福利部食品藥物管理署. Section Chief. Food and Drug Administration, Ministry of Health and Welfare

Thailand s experience in developing the Reclassification guideline

Y. W. Francis Lam, Pharm.D. FCCP University of North Texas Health Science Center Grand Round Rx to OTC Switch: Potentials, Challenges, and Initiatives

Dispensing and administration of emergency opioid antagonist without a

Chapter 1: Fundamentals of Pharmacology Test Bank

Prepublication Requirements

Political Economy of the Medical Products Industry

Food Additives Program

(---~~ 11 U.S. FOOD & DRUG \<~l- ADM I NI STRATIO N OEC

DEPARTMENT OF HEALTH & HUMAN SERVICES Food and Drug Apini$r$iy -tq 5-f

Guidance for Industry

Non-Prescription Medicinal Products Containing Codeine: Guidance for Pharmacists on Safe Supply to Patients

DISPENSING OR SELLING NALOXONE. Guidance for pharmacy professionals when dispensing or selling naloxone as a Schedule II drug.

Which was the greatest problem with patent medicines in early America that lead to drug legislation?

Fundamentals of Pharmacology

Changes to the Eighth Edition

Review of Controlled Drugs and Substances Act

4/26/2013. Libia Lugo Drug Specialist San Juan District Office Investigations Branch

Performance of North Carolina's System for Monitoring Prescription Drug Abuse. Session Law , Section 12F.16.(q)

Fundamentals of Pharmacology for Veterinary Technicians Chapter 1

ULTRAPROCT OINTMENT ULTRAPROCT SUPPOSITORIES

Sub. S.B. 119 As Passed by the Senate

SUBSYS National Drug Code Directory

February 27, Human Use. Dear Sir or Madam: new data and. responded to. United States. the United products.

Responding to the Prescription Opioid and Heroin Crisis: An Epidemic of Addiction

Harmonization effort for OTC monograph in Taiwan. Ms. Hsueh-Yung (Mary) Tai Deputy Director, Division of Medical Product, Taiwan FDA

APPROVED DRUG PRODUCTS with THERAPEUTIC EQUIVALENCE EVALUATIONS

Coventry Health Care of Georgia, Inc.

Review of Medicines Act 1968: informal consultation on issues relating to the PLR regime and homeopathy

Food and Drug Law. Fall Syllabus. Professor Jesson. Hamline University School of Law

Good Samaritan and Naloxone Bill Status Report Carryover 2015 and Special Sessions

RE: Permits under the Arizona Pharmacy Act should not be required for dietary supplements

NDA MF REMS ASSESSMENT ACKNOWLEDGMENT

Rule Governing the Prescribing of Opioids for Pain

Background. Historical Context

Over the Counter Hearing Aids:

Listing of Color Additives Exempt from Certification; Synthetic Iron Oxide

Safety Evaluation for Substances Directly Added to Food

Dear DEA. Howard A. Heit, MD, FACP, FASAM,* Edward Covington, MD, and Patricia M. Good

Substance use and misuse

Public Policy Statement on the Regulation of Office-Based Opioid Treatment

Teva Pharmaceuticals USA Attention: Scott D. Tomsky Vice President, US Generics Regulatory Affairs 425 Privet Road Horsham, PA 19044

OTC Drug Monograph Reform FDLI Annual Conference May 4, 2018

ANDA Arthur P. Bedrosian, President Armenpharm, Ltd. 49 South Ridge Road P.O. Box D1400 Pomona, NY December 3, 2015

Agency Information Collection Activities; Submission for Office of Management and

NEW MEXICO DEPARTMENT OF HEALTH Administrative Manual ADMINISTRATION

TGA: the current regulatory reform agenda

Cold, Cough, Allergy, Bronchodilator, and Antiasthmatic Drug Products for. Over-the-Counter Human Use; Amendment of Monograph for OTC Nasal

FDA s Response to the Opioid Crisis and the FDA Safe Use Initiative

Appearance before House of Commons Standing Committee on Health as part of its Study on the Government s Role in Addressing Prescription Drug Abuse

GENERAL ASSEMBLY OF NORTH CAROLINA SESSION HOUSE BILL DRH20012-MGfa-35H* (01/26)

Readopt with amendment Med 502, effective (Document #11090), to read as follows:

Withdrawal of Proposed Rule on Supplemental Applications Proposing Labeling Changes for

Compare Results. 153 Replacements 26 Insertions 344 Deletions. Total Changes. Styling and. Content. 0 Annotations. Old File: New File:

Strategies for Federal Agencies

Update on the revision of the new package leaflet (PL) template. An agency of the European Union

ISSUING AGENCY: Regulation and Licensing Department - Board of Pharmacy, Albuquerque, NM. [ NMAC - N, ; A, ]

Prescription Medication Guidelines for Medical Providers in CorVel s CorCare and Care IQ Networks

FDB FOOD AND DRUGS BOARD G H A N A GUIDELINES FOR CONDUCTING BIOEQUIVALENCE STUDIES

rj.;!i U.S. FOOD & DRUG - ADMIN ISTRATION

[Docket No. FDA-1977-N-0013] (formerly Docket No. 1977N-0094L)

SIXTY-FOURTH LEGISLATURE OF THE STATE OF WYOMING 2017 GENERAL SESSION

A. The burden of untreated pain. The importance of opioid therapy Potential pitfalls of opioid therapy

National Drug Code Directory

UTAH S CONTROLLED SUBSTANCE DATABASE PROGRAM (CSDB)

Submitted to the House Energy and Commerce Committee. Federal Efforts to Combat the Opioid Crisis

SENATE FILE NO. SF0042. Sponsored by: Joint Judiciary Interim Committee A BILL. for. AN ACT relating to public health and safety; creating the

MARKETING STANDARDS FOR MEMBERSHIP

2014 FDA/JIFSAN Food & Nutrition Webinar

Mitch Zeller, Director, Center for Tobacco Products, FDA September 19, 2013 Kansas Public Health Association

January 19, Cannabis Legalization and Regulation Secretariat Address locator 0602E Health Canada Ottawa, Ontario K1A 0K9

6/7/2017 CHANGES IN PHARMA REGULATIONS HOW IT AFFECTS THE OR NURSE DISCLOSURE OBJECTIVES

Clinical Studies in BE Evaluation of Generic Products. Brenda S. Gierhart, M.D. Medical Officer, Division of Clinical Review, Office of Generic Drugs

HAVRIX National Drug Code Directory

SOMNUS VITM Supplement for sleep and wellness

FDA Oversight of Nanotechnology Applications in Foods, Food Packaging, and Nutrient Delivery

Pharmaceutical Management Medicaid 2019

DEXAMETHASONE SODIUM PHOSPHATE National Drug Code Directory

Mark M. Yacura. Partner

CDC s Approach to Addressing the Opioid Overdose Epidemic

Building capacity for a CHC response to Ontario's Opioid Crisis

ANDA Submissions Refuse to Receive for Lack of Proper Justification of Impurity Limits Guidance for Industry

A Family Medicine Cabinet

Decentralised Procedure. Public Assessment Report. ALGOTRA 37.5 mg/325 mg überzogene Tabletten Tramadol/Paracetamol DE/H/3688/001/DC

MARYLAND BOARD OF PHARMACY

Theoriginalhcgdrops.com 11/28/11

GDUFA: 2 ½ years later Impact & Importance

Guide to Interchangeable Medicines

Introduction to Product Regulation Under the Family Smoking Prevention & Tobacco Control Act

LIDOCAINE HYDROCHLORIDE AND EPINEPHRINE National Drug Code Directory

How to change the legal classification of a medicine in New Zealand

THE FDA DRUG APPROVAL PROCESS Under the Federal Food, Drug, and Cosmetic (FD&C) Act, FDA is responsible for ensuring that all new drugs are safe and

Transcription:

Naloxone Expanded Access: OTC status Considerations for a Nonprescription Drug Development Program Andrea Leonard-Segal, M.D., M.S. Director, Division of Nonprescription Clinical Evaluation 1

Contents Regulatory Requirements for Nonprescription Drug Marketing OTC Drug Labeling How Could Naloxone Become an OTC Drug? NDA (Content of an Application) Rulemaking Other issues 2

Regulatory Requirements for Nonprescription Drug Marketing 3

Durham Humphrey Amendment to the Food, Drug and Cosmetic Act (1951) Formally differentiates Rx from Non Rx Drugs 2 Criteria carve niche for Prescription Drugs: Drug can be used safely only under supervision because of: drug's toxicity or other potentiality for harmful effect, or method of its use, or collateral measures necessary to its use If drug is limited by an approved application to use under professional supervision Otherwise, the drug should be available without a prescription. Code of Federal Regulations (21 CFR 310.200) describes the procedure by which drugs that have been limited to prescription use shall be exempted from prescription-dispensing requirements 4

How Can Drugs Be Marketed in the U.S.? There are two marketing options for drugs in the U.S. Prescription (Rx) Nonprescription = Over-the-Counter (OTC) Behind-the-Counter is not a marketing venue in the U.S. Available in European and other international markets Intermediate distribution status for drugs that allows trained pharmacists to interact with a consumer and then select and provide medication to the consumer No input from a physician required 5

How Can Drugs Be Marketed in the U.S.? Law has been interpreted so dual marketing of the same active ingredient in products that are both Rx and OTC can only occur when a clinically meaningful difference exists between the two that makes the Rx product safe only under the supervision of a licensed practitioner A drug cannot be marketed both Rx and OTC for the same indication, population, and same conditions of use 6

How Might the Law Apply to Naloxone? Would a clinically meaningful difference exist between an OTC naloxone and Rx naloxone so the current Rx product(s) would remain after the OTC switch? Would a difference in dosage form between the Rx products and the proposed OTC product be interpreted as a clinically meaningful difference? 7

OTC Drug Labeling 8

OTC Drug Facts Label OTC drugs have their own labeling regulations (21 CFR 201.66) Standardized format is intended to provide clarity and consistency to consumers so they know what to expect from OTC labels and where to find the important information Limited real estate on an OTC product All important information necessary for effective and safe use of OTC product must be in the Drug Facts Label This would be the case for naloxone 9

10

Consumer Information Leaflet (CIL) This additional labeling element sometimes is included inside the box of an OTC drug product May provide additional information about the drug or the condition the drug treats that can be useful to the consumer May provide explicit diagrams on how to use the product Naloxone products could have CILs 11

How Could Naloxone Become an OTC Drug? 12

Regulatory Mechanisms by which Naloxone Could Become an OTC Drug New Drug Application (takes months, proprietary, product specific, applicant pays user fee) Rulemaking (takes years, public, ingredient specific, no user fee) Regulated under the OTC Drug Monograph 13

New Drug Application for OTC Marketing Proprietary 14

Each Switch NDA Fresh Look at the Drug All components of Rx NDA and more. Chemistry New formulation, stability, packaging, etc. Pharmacology/Toxicology New formulation, new method of delivery, new combination of ingredients, possibility of longer duration of exposure in the OTC venue because of repeated use, etc. Microbiology (if applicable) e.g., Drug resistance issues raised by the OTC setting, sterility issues Clinical Pharmacology New formulation, new combination, etc. 15

Each Switch NDA Fresh Look at the Drug All components of Rx NDA and more. Efficacy data If OTC and Rx indications differ, if dose, if not bioequivalent to approved reference drug, etc. Safety data Clinical trials Postmarketing worldwide safety data to identify new signals after broad time and extent of Rx product use and to assess safety in markets in which this product may already be nonprescription (e.g., Sweden) Consumer studies (unique to OTC drug evaluation) New OTC indication, new warnings, new directions for use, etc. Labeling An OTC application for Naloxone, depending upon the formulation, may need to contain new data to address all of these components. 16

Additional Words on Efficacy and Safety Data Data from Rx NDA can sometimes support the switch sometimes need additional data Naloxone Efficacy Switch of approved Rx product no efficacy data needed New naloxone formulation may need new efficacy data based on differences in clinical pharmacology profile compared with that of the approved reference drug Safety Switch of approved Rx product supported by current safety database (clinical studies and postmarketing) New formulation» New clinical safety data needed (topical formulation)» If more bioavailable than the reference drug, wise to market Rx first to acquire postmarketing safety database before marketing OTC 17

Sources Post-Marketing Safety Data for OTC Switch Adverse Event Reporting System WHO International Drug Monitoring Program Literature review Drug abuse and overdose data For Naloxone, need to understand the potential for conversion into an opioid agonist that could be abused 18

Consumer Studies Unique to OTC Drug Assessment Conducted to support safe and effective use in the OTC setting Label Comprehension Human Factor Self-Selection Actual Use 19

Consumer Studies Are Helpful When.. Drug is first in its class to OTC market New OTC target population New OTC indication Substantive labeling change to existing OTC product New directions for use (not previously seen in the OTC marketplace) Needed to support a Naloxone Switch 20

Label Comprehension Study First step in predicting Consumer Behavior Can the consumer understand the label? If not, likely will not use the product properly However, converse is not necessarily true Tests if label communicates messages key to proper drug use Consumer reads the label and responds to questions about it Not a clinical trial No drug administered 21

Human Factors Study Can assess whether prospective consumers can follow the steps outlined in the directions for use to properly prepare or measure a product for dosing Not always needed for an NDA Can help to improve complex dosing instructions Naloxone e.g., Could assess if consumers can properly prepare or use product syringe based upon the directions 22

Self-Selection Study Tests whether, based on reading the product label, consumers can properly select to use or not to use the product Can consumers self-diagnose the condition for which the drug is indicated? Can they recognize whether the drug would be appropriate for them to use based upon their personal medical history? No drug administered 23

Self-Selection and Naloxone For Naloxone, the individual administering drug would not be the person receiving it This OTC paradigm exists now: parents self-select to treat symptomatic conditions in their minor children Data will be needed to assess whether the individual administering naloxone could properly diagnose the opioid overdose and determine that it is appropriate to give naloxone based upon the information on the Drug Facts Label 24

Actual Use Study (an atypical clinical trial) Provides data to enable us to predict if a drug will be used properly and safely in the OTC setting. Simulates OTC use of product naturalistic setting Generally open-label Access to study medication simulates what would occur if the drug were approved OTC Limited study investigator contact Timing of follow-up contacts consumer driven (as much as possible) Actual Use Data would be needed to support an OTC application for Naloxone 25

Rulemaking to Bring Naloxone into the OTC Drug Monogaph Public Process 26

Rulemaking Options to Bring Naloxone OTC FDA could initiate rulemaking on its own or in response to a Citizen Petition requesting that FDA do this Data needed would be the same as for the NDA Process involves data review, multiple Federal Register publications soliciting comments, comment review Ultimately final rule would state that naloxone (active ingredient) is or is not Generally Recognized as Safe and Effective OTC to treat opioid overdose when administered as a particular type of formulation 27

Some Other Issues Raised by OTC Naloxone Needle safety for the injectable formulation The impact of the injectable no longer being a prescription drug Management of withdrawal reactions Would it encourage opioid misuse or adversely impact the use of 911 Educational campaigns FDA does not control OTC drug advertising; FTC does 28

Summary There are different regulatory pathways to consider for the Rx to OTC switch of naloxone There are many interesting regulatory and scientific issues to address to support the expanded access of naloxone via OTC marketing Consumer data (among other data) would be essential to support a naloxone switch 29

The End 30

Time and Extent Application Process Process outlined in the Code of Federal Regulations (21 CFR 330.14) The data to support a TEA are the same as would be needed to support an NDA Once listed in the monograph, the active ingredient can be used if it meets the conditions of use as specified therein Guidance on TEAs located at http://www.fda.gov/downloads/drugs/guidancec omplianceregulatoryinformation/guidances/uc m078902.pdf 31