A FDA Perspective on Nanomedicine Current Initiatives in the US



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A FDA Perspective on Nanomedicine Current Initiatives in the US Carlos Peña, PhD Office of the Commissioner FDA September 3, 2010

Outline Context Nanotechnology Task Force report summary Identification and considerations for FDA products relevant to nanomedicine Current activities within FDA s Center for Drug Evaluation and Research New activities across FDA

FDA focus on Nanotechnology Increasingly used in products regulated by FDA Drugs, medical devices, cosmetics, dietary supplements Near term/future applications-food applications, targeted medical therapies, device materials FDA plays key regulatory role for Nanotechnology in US National priority for the US 3

FDA Development of the Nanotechnology Task Force Scientific Issues: Understanding the interaction of nanoscale materials with biological systems Adequacy of testing approaches Regulatory Policy Issues: Ability to identify products that contain nanoscale materials Scope of authority regarding evaluation of safety and effectiveness

Science Recommendation: Understanding biological interactions More knowledge needed about biological interactions detection and measurement In-house expertise and infrastructure should be strengthened Agency-wide regulatory-science coordination for nanoscale materials needed.

Science Recommendation: Adequacy of testing approaches Current testing approaches to assess safety, effectiveness, and quality of products with nanoscale materials should be evaluated. Promote/participate in Development of characterization methods and standards for nanoscale materials Development of models for the behavior of nanoscale particles in-vitro and in-vivo.

Regulatory Policy Issue: Identification and Scope of products containing Nanomaterials Requesting submission of data and other information addressing the effects on product safety and effectiveness of nanoscale materials in products subject to FDA premarket authorization. Issue guidance requesting submission of information on whether and how the presence of nanoscale materials affects the manufacturing process Issue guidance for products Subject to premarket approval Not subject to premarket approval

List of terms applicable to Nanomedicine Nanoparticle Polymeric nanoparticle platforms Dendrimer Liposomes Micelles Nanoemulsions Nanocrystal 8

Considerations for nanomaterial-containing drug products Product quality assessment Characterization Quality control Manufacturing Product safety assessment Biodistribution Clearance Metabolism Toxicology

Characterization Questions Identification of products containing nanomaterials Identification of critical properties requiring characterization, for optimal product quality and performance assessment. Use of appropriate tools and methodologies to: Adequately assess chemistry and any unique characteristics of products containing nanomaterials, using the complete formulation. Use of appropriate quality control measures in order to produce consistent formulations with low batch-tobatch variability.

Safety Questions Physico-chemical properties of nanoparticles can impact biodistribution: Size, surface charge, stability, density, crystallinity, surface characteristics, solubility Bioavailability of encapsulated and free drug may need to be assessed separately Multicomponent constructs may require ADME on each moiety Possibility of long term studies

Existing Guidance documents As the issues regarding nanoparticle-containing therapeutics are fully identified, all existing Guidance documents are applicable

Topic Area CMC Imaging Procedural PK/ADME Current Good Manufacturing Practice for Combination Products Residual Solvent in Drug Products Marketed in the United States Guideline on General Principles of Process Validation Good Laboratory Practice Regulations: Questions and Answers Process Validation: General Principles and Practices Guidance for Reviewers: Pharmacology/Toxicology Review Format Guidelines for Submitting Documentation for the Manufacture of and Controls for Drug Products Guidelines for Submitting Supporting Documentation in Drug Applications For the Manufacture of Drug Substances Drug Interaction Studies-Study Design, Data Analysis, and Implications for Dosing and Labeling Drug Metabolism/Drug Interaction Studies in the Drug Development Process: Studies in Vitro Nonclinical Safety Evaluation of Reformulated Drug Products and Products Intended for Administration by an Alternate Route Nonclinical Studies for the Safety Evaluation of Pharmaceutical Excipients Safety Testing of Drug Metabolites Single Dose Acute Toxicity Testing for Pharmaceuticals Guidance Title Analytical procedures and methods validation: Chemistry, manufacturing, and controls documentation Comparability Protocols- Chemistry, Manufacturing, and Controls Information Liposome drug Products: Chemistry, Manufacturing, and Controls: Human Pharmacokinetics and Bioavailability, and Labelign Documentation Developing Medical Imaging Drug and Biological Products Part 1: Conducting Safety Assessment; Part 2: Clinical Indications; Part 3: Design, Analysis, and Interpretation of Clinical Studies Content and Format of Investigational New Drug Applications (INDs) for Phase I Studies for Drugs, Including Well-Characterized, Therapeutic, Biotechnology-derived Products Early Development Considerations for Innovative Combination Products Statistical Aspects of the Design, Analysis, and Interpretation for Chronic Rodent Carcinogenicity Studies of Pharmaceuticals. Publication Date 2000 2003 2004 2009 1987 1998 2002 2008 2004 1995 2006 2001 1987 2006 1997 2008 2005 2008 1996 2001

A few examples of guidance that may be applicable to nanomedicine Combination products Liposome products Comparability protocols

Center for Drug Evaluation and Research Current Activities Development of a MaPP on collection of information on nanomedicines in CMC reviews-completed Development of a comprehensive database of approved drugs and drugs under review-in progress

FY2011 FDA Science Budget Initiative and Request 1st explicit and dedicated support of science infrastructure and capacity in FDA s budget ~$25 million across agency Major components Emerging science Nanotechnology, Critical Path, Science Leadership, and others Nanotechnology review & safety $7.33 million 17

Key Components of 2011 Nanotechnology Regulatory Science Initiative CORES Program (Collaborative Opportunities for Research Excellence in Science Program) Enhance external and cross-center activities Support external research programs Laboratory Capacity to Assess Nanotechnology Products Equip Core Laboratory Facilities Training and staff development 18

CORES Program Priorities Characterization of Nanomaterials Define physical/chemical characteristics of nanomaterials that affect potency Define characteristics that impact safety Biocompatibility Interaction with biological processes in tissues, fluids Pharmacokinetics Safety Toxicokinetics In vitro toxicity test methods (e.g. cytotoxicity, genotoxicity) In vivo toxicity tests (e.g. 90-day, 2-yr) 19

Staff Training & Professional Development Invited Expert Presentations Product Specific Agency Wide Day Long Workshops FDA Staff International Experts Meeting Center Specific Activities 20

Nanotechnology Research Laboratory Core Facilities: Locations White Oak Campus and Surrounding Region - CBER - CDER - CDRH - CFSAN - CVM Jefferson Laboratories - NCTR - ORA 21

Summary A number of nanomedicine relevant products are approved and currently on the market The existing regulatory framework can accommodate the types of nanoparticle therapeutics under development and when needed, adapt to address new challenges Current published guidances may be applicable to nanoparticle therapeutics Staff are working on addressing the need for guidance documents that address nano-related issues as well as the regulatory science to bring to bear to this emerging technology FDA continues to encourage and participate in stakeholder dialogues

Closing Thoughts International Partnerships

Acknowledgements