Title: Innovative Systems for Delivery of Drugs and Biologics DrugEluting Stents Current Approach to Review
1Innovative Systems for Delivery of Drugs and
BiologicsDrug-Eluting Stents Current Approach
to Review
- Ashley B. Boam, MSBE
- Division of Cardiovascular Devices
- Office of Device Evaluation
- Center for Devices and Radiological Health
2What is a Drug-Eluting Stent (DES)?
Example Cordis Cypher Sirolimus-Eluting
Coronary Stent
Components
- Stent Platform Delivery System
- Carrier(s)
- Drug
DHHS/FDA/CDRH
3DES and the Regulatory Process
Three Component System
Stent Platform Delivery System CRDH Review
Drug Eluting Stent
Pharmacologic Agent (Drug) CDER Review
Carrier (e.g., Polymer) CDRH Review
DHHS/FDA/CDRH
4Overview of Review Challenges for DES
- Regulatory jurisdiction
- Inspectional authority site readiness
- Disparity in statutory regulatory requirements
between CDRH CDER
- Appropriate leveraging of information from INDs,
NDAs, DMFs, MAFs, etc.
- Appropriate pre-clinical testing clinical trial
design
- Post-market studies and surveillance
5Regulatory Jurisdiction
- Combination Products (21 CFR Part 3)
- CDRH lead center with CDER consultation
- http//www.fda.gov/oc/combination/updates.html
- Divisions involved include
- Cardiovascular Devices (ODE/CDRH)
- Cardio-Renal Drug Products (OND/CDER)
- New Drug Chemistry I (OPS/CDER)
- Pharmaceutical Evaluation I (OCP/CDER)
- Mechanics Materials (OST/CDRH)
- Submissions IDEs PMAs
DHHS/FDA/CDRH
6Regulatory Review Team for DES
Expertise required
Mechanical Performance Testing Regimes
Animal Experimentation Evaluation
Clinical Trial Design Methodology
Chemistry Drug Substance Carrier(s)
Pharmacokinetics / Pharmacodynamics
Manufacturing
DHHS/FDA/CDRH
7Inspectional Authority and Site Readiness
- Inspections conducted by CDRH with CDER/ONDC
participation
- Validations should be complete prior to
inspection
- Subsequent manufacturing changes may require
reinspection
8Approval of Devices, Drugs Biologics
9Comparison of Device Drug Development
DHHS/FDA/CDRH
10Information to Support DES Applications
Refer to CDER Guidance, Content Format of
INDs for Phase 1 Studies of Drugs www.fd
a.gov/cder/guidance/phase1.pdf
Refer to CDRH Guidance, Interventional
Cardiology Devices Intravascular Stents
www.fda.gov/cdrh/ode/846.pdf
DHHS/FDA/CDRH
11Approved vs. UnstudiedDrug Substances
- Potential Sources for Safety Data (Phase 1 IND)
- Approved drug NDA
- Drug under IND investigation
- Unstudied New Molecular Entity (NME)
- Analog of Approved Drug is an NME
- Necessary Categories of Safety Information
- Chemistry, Manufacturing Controls (CMC)
- Systemic Pre-clinical Pharmacology/Toxicity
- Systemic Clinical Exposure
- Potentially Influences Clinical Trial Design
12Preclinical Testing Objectives
- Characterization of finished, sterilized product
to be studied is essential
- Coating/drug loading characteristics drug and
carrier content, uniformity, abrasion resistance
(if coating), particulate
- In vitro/ in vivo elution
- Methods and initial specifications for stability
testing
- Adequate animal studies needed to assess safety
prior to human studies
DHHS/FDA/CDRH
13Common Preclinical Testing Deficiencies
- Inadequate Stent Platform Testing
- Fatigue and corrosion testing
- Inadequate Analysis of Surface Modifications
- Coating integrity/durability
- Drug content/uniformity
- Incomplete In vitro Pharmacokinetics
- Methodology and IVIVC, if possible
- CMC Issues Inadequately Addressed
- Stability/shelf life
14Common Animal Study Deficiencies
- Inadequate Reports to Assess Safety
- Lack evaluation of doses intended for clinical
evaluation /or overdosage at appropriate time
points
- Lack evaluation of serial sections of myocardium
- Lack description of arterial histopathology
- Lack necropsy reports (especially
important for unexpected deaths)
DHHS/FDA/CDRH
15Clinical Evaluation of DES
- Reasonable Assurance of Safety and Effectiveness
- Clinical Study Needs to Be Designed for Both
Objectives
- Usual Standard of Evidence is RCT
- Study Endpoints for Coronary DES
- Primary Clinically Meaningful
- Use of surrogate and/or co-primary endpoints?
- Non-inferiority trial - appropriate delta
- Use of Independent Core Labs, CEC Active DSMB
DHHS/FDA/CDRH
16DES Post-Market
- TPLC is critical for DES!
- 5 year follow-up of all patient cohorts
(feasibility, pivotal, any supportive)
- Additional data collection post-market to gain
further understanding of rates of drug-related
adverse events
- Approval for new indications, new study
populations through IDE
- Adverse events are reported through MDR
- reports to CDRH, data shared with CDER
17Questions? Talk to us!
- Coronary DES
- Ashley Boam, Branch Chief (aab_at_cdrh.fda.gov)
- Joni Foy, Ph.D., Lead Reviewer (jrf_at_cdrh.fda.gov)
- Peripheral DES
- Elisa Harvey, DVM, Branch Chief
(edh_at_cdrh.fda.gov)
- Jennifer Goode, Lead Reviewer (jlg_at_cdrh.fda.gov)