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I heard that population PK or PD studies will be mandatory for registration
in Europe by 2003. Can anyone confirm this, and indicate where we can find
confirmation of this. I have looked on the web site of the EMEA but found
no document to confirm that.
Thanks,
Eric Masson, Pharm.D.
Scientific Director,
Anapharm inc
2050, boul Rene-Levesque West,
Ste-Foy, QC, Canada, G1V-2K8
418-527-4000 (EXT:222)
FAX: 418-527-3456
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Dear Eric and others
In my dreams PK/PD studies are a mandatory part of the European
submission
package. In reality, this is not the case and there is no documentation
in
existence, or in preparation, that would make it mandatory. What I have
managed to put in place is that PK/PD information, if it is provided,
should
also be included in the SmPC (European Drug Label). There are a couple
of
other European regulatory documents being prepared that also make
mention of
PK/PD, but these are not final yet.
As a plea from a regulator who believes that PK/PD information is almost
vital
in some submissions, and that the lack of it means the implications of
changes
in PK cannot be properly assessed, I would ask that this kind of
information be
included in the submission package whether it is a mandatory requirement
or
not.
Kind regards
Janet
(Janet R. Wade
Medical Products Agency, Sweden)
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I have to agree with Janet. I've seen a number of situations were PK/PD
could save a drug.
In addition to dose selection, this is especially common with
supplemental applications where a new formulation is bioinequivalent
(esp. pharmaceutical alternatives).
PK/PD data, even if generated during the original marketing application
can show that differences in bioavailability are not expected to be
clinically significant. Alternatively if PK/PD data do indicate a
clinical difference they can help to justify a different dose with the
alternative formulation, or it may result in approval with slightly
different labeling.
Without PK/PD data there would be no basis to justify an approval.
The above is my personal opinion and does not necessarily reflect the
views of the FDA.
Ron Kavanagh
Food & Drug Administration, FDA
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Copyright 1995-2010 David W. A. Bourne (david@boomer.org)