History of the Montreal Protocol, History of the Montreal Protocol, FDA regulation of CFCs and FDA regulation of CFCs and

Background to MeetingBackground to Meeting

History of the Montreal Protocol, History of the Montreal Protocol, FDA regulation of CFCs and FDA regulation of CFCs and

Background to MeetingBackground to Meeting

Robert J. Meyer, MDRobert J. Meyer, MD

Director, ODE II / CDERDirector, ODE II / CDER

2Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

General BackgroundGeneral BackgroundGeneral BackgroundGeneral Background

The earth’s ozone layer is a region of relatively higher ozone concentrations in the stratosphere

The earth’s ozone layer is a region of relatively higher ozone concentrations in the stratosphere

3Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

General BackgroundGeneral BackgroundGeneral BackgroundGeneral Background

• This “layer” reduces the amount of ultraviolet radiation (UV-B) reaching the surface from sunlight

• As a result of ozone loss, the increased UV-B leads to increases in skin cancers (melanoma and non-melanoma), cataracts, impaired immunity

• Other deleterious effects on the environment also result, as do effects on man-made substances (like plastics)

• This “layer” reduces the amount of ultraviolet radiation (UV-B) reaching the surface from sunlight

• As a result of ozone loss, the increased UV-B leads to increases in skin cancers (melanoma and non-melanoma), cataracts, impaired immunity

• Other deleterious effects on the environment also result, as do effects on man-made substances (like plastics)

4Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

• Development of US law, FDA regulations, and the Montreal Protocol have proceeded in overlapping timeframes, so this talk will overlap the discussions

• Development of US law, FDA regulations, and the Montreal Protocol have proceeded in overlapping timeframes, so this talk will overlap the discussions

General BackgroundGeneral BackgroundGeneral BackgroundGeneral Background

5Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

• 1974- Work by Molina and Rowland published tying ozone depletion to stratospheric chlorine from degraded CFCs1

• At that time, use of CFCs was widespread in the US – Refrigerators, A/C, foams, and in many

consumer and medical aerosol products

1 – Nature, 1974; vol 249:810-812

• 1974- Work by Molina and Rowland published tying ozone depletion to stratospheric chlorine from degraded CFCs1

• At that time, use of CFCs was widespread in the US – Refrigerators, A/C, foams, and in many

consumer and medical aerosol products

1 – Nature, 1974; vol 249:810-812

6Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

• 1978 – In response to growing evidence of CFCs harming the ozone layer, CFCs were generally banned in spray can/aerosols by U.S. Govt (EPA) – e.g. hairsprays, spray paint…

• FDA published 21 CFR 2.125 banning use of CFCs in FDA regulated products (with essential exemptions)

• 1978 – In response to growing evidence of CFCs harming the ozone layer, CFCs were generally banned in spray can/aerosols by U.S. Govt (EPA) – e.g. hairsprays, spray paint…

• FDA published 21 CFR 2.125 banning use of CFCs in FDA regulated products (with essential exemptions)

7Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

• 1987 - 27 nations (including U.S.) initiate a global ozone treaty in Montreal, known as the “Montreal Protocol on Substances that Deplete the Ozone Layer”

• hereafter referred to as the “MP” • The original protocol now has over 180

signatory Parties (countries) and is regarded as the model for successful, global environmental treaties

• 1987 - 27 nations (including U.S.) initiate a global ozone treaty in Montreal, known as the “Montreal Protocol on Substances that Deplete the Ozone Layer”

• hereafter referred to as the “MP” • The original protocol now has over 180

signatory Parties (countries) and is regarded as the model for successful, global environmental treaties

8Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

• Original phase-out of CFCs slated for 2000 (London - 1990)

• Phase-out of CFCs is moved up to end of 1995 (Copenhagen - 1992) due to evidence of increasing ozone depletion, especially over the Antarctic (ozone “hole”)

• While depletion is most prominent over southern hemisphere, the depletion is global

• MP controls many ozone depleting substances (ODS): CFCs, Halons, HCFCs, methyl bromide, carbon tetrachloride,…

• Original phase-out of CFCs slated for 2000 (London - 1990)

• Phase-out of CFCs is moved up to end of 1995 (Copenhagen - 1992) due to evidence of increasing ozone depletion, especially over the Antarctic (ozone “hole”)

• While depletion is most prominent over southern hemisphere, the depletion is global

• MP controls many ozone depleting substances (ODS): CFCs, Halons, HCFCs, methyl bromide, carbon tetrachloride,…

9Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

• As of January 1st, 1996, all use of CFCs banned in industrial countries; rest of the world in 2010

• MDIs for asthma and COPD currently exempted under essential use process

• Nominations for essential uses reviewed annually (e.g., in 2005, the Parties ordinarily review 2007 nominations)

• As of January 1st, 1996, all use of CFCs banned in industrial countries; rest of the world in 2010

• MDIs for asthma and COPD currently exempted under essential use process

• Nominations for essential uses reviewed annually (e.g., in 2005, the Parties ordinarily review 2007 nominations)

10Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

Montreal Protocol has stipulated the following:

• Decision IV/25 - All essential uses of CFCs based on products necessary for public health without adequate alternatives (technically & economically) - ‘macroscopic’ determination of essentiality (i.e., use of CFCs in MDIs for asthma and COPD)

Montreal Protocol has stipulated the following:

• Decision IV/25 - All essential uses of CFCs based on products necessary for public health without adequate alternatives (technically & economically) - ‘macroscopic’ determination of essentiality (i.e., use of CFCs in MDIs for asthma and COPD)

11Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

Montreal Protocol has stipulated the following:

• Decision XII/2 - Any product approved after Dec. 2000 must individually meet IV/25 – Product-centered determination of

essentiality that essentially precludes new CFC generics or other new CFC products unless the new product individually exceeds the high hurdle of IV/25

Montreal Protocol has stipulated the following:

• Decision XII/2 - Any product approved after Dec. 2000 must individually meet IV/25 – Product-centered determination of

essentiality that essentially precludes new CFC generics or other new CFC products unless the new product individually exceeds the high hurdle of IV/25

12Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

Montreal Protocol has stipulated the following:

• Decision XV/5:– Essential use nominations are now use

specific (e.g., XX tonnes for albuterol)– No quantity of essential use CFCs will be

authorized for albuterol beginning with this year’s MOP if a “plan” for albuterol phase-out has not been submitted by the OEWG the summer of 2005

» FDA final rule published in March 2005 on phase-out of albuterol meets this stipulation for US

Montreal Protocol has stipulated the following:

• Decision XV/5:– Essential use nominations are now use

specific (e.g., XX tonnes for albuterol)– No quantity of essential use CFCs will be

authorized for albuterol beginning with this year’s MOP if a “plan” for albuterol phase-out has not been submitted by the OEWG the summer of 2005

» FDA final rule published in March 2005 on phase-out of albuterol meets this stipulation for US

13Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

• CAA amendments of 1990, in part, codified MP into US law

• Implementing EPA regulations refer to HHS/ FDA through 21 CFR 2.125 for definition of medical essentiality

• Again, 2.125 was originally published in as a final rule in 1978

• CAA amendments of 1990, in part, codified MP into US law

• Implementing EPA regulations refer to HHS/ FDA through 21 CFR 2.125 for definition of medical essentiality

• Again, 2.125 was originally published in as a final rule in 1978

14Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

• 1978 Federal Regulation (21 CFR 2.125) was promulgated stating that CFC containing regulated products were misbranded/adulterated unless deemed essential

• “Essential” based on:• No technically feasible alternatives• Provides substantial (health, public, or

environmental) benefit • Release of CFC small, or justified given benefit

• 1978 Federal Regulation (21 CFR 2.125) was promulgated stating that CFC containing regulated products were misbranded/adulterated unless deemed essential

• “Essential” based on:• No technically feasible alternatives• Provides substantial (health, public, or

environmental) benefit • Release of CFC small, or justified given benefit

History of the Montreal History of the Montreal Protocol and 21 CFR 2.125Protocol and 21 CFR 2.125

History of the Montreal History of the Montreal Protocol and 21 CFR 2.125Protocol and 21 CFR 2.125

15Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

• 1978 FDA rule had no mechanism to determine when uses are no longer essential and to delist them (only mechanims to add new classes/drugs to the list)

• Many important drugs not listed separately, but in broad classes– e.g., “Adrenergic bronchodilators for human

use….”• 1996, FDA publishes an Advanced Notice of

Proposed Rulemaking (ANPR) proposing revisions to 2.125

• 1978 FDA rule had no mechanism to determine when uses are no longer essential and to delist them (only mechanims to add new classes/drugs to the list)

• Many important drugs not listed separately, but in broad classes– e.g., “Adrenergic bronchodilators for human

use….”• 1996, FDA publishes an Advanced Notice of

Proposed Rulemaking (ANPR) proposing revisions to 2.125

History of the Montreal History of the Montreal Protocol and 21 CFR 2.125Protocol and 21 CFR 2.125

History of the Montreal History of the Montreal Protocol and 21 CFR 2.125Protocol and 21 CFR 2.125

16Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

• Close to 10,000 comments received, many sparked by lobbying efforts

• NPR published in 1999 with fewer resulting substantive comments and little controversy

• FR amending 2.125 published on July 24, 2002

• FR went into effect January 2003

• Close to 10,000 comments received, many sparked by lobbying efforts

• NPR published in 1999 with fewer resulting substantive comments and little controversy

• FR amending 2.125 published on July 24, 2002

• FR went into effect January 2003

17Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

2002 revisions to 2.125:• Listed individual moieties as essential uses of ozone

depleting substances (ODS) in 2.125 (e) rather than classes (e.g., albuterol is listed, rather than all adrenergic bronchodilators)

• Added a higher hurdle for IND use of ODSs and to raise the bar for new listings of essential uses

• Lists criteria for determining individual uses are no longer essential

2002 revisions to 2.125:• Listed individual moieties as essential uses of ozone

depleting substances (ODS) in 2.125 (e) rather than classes (e.g., albuterol is listed, rather than all adrenergic bronchodilators)

• Added a higher hurdle for IND use of ODSs and to raise the bar for new listings of essential uses

• Lists criteria for determining individual uses are no longer essential

18Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

Non-essentiality Criteria:– At least one non-ODS product with the same

active moiety* , the same indication, route of administration, about the same level of convenience

– At least 1 year of post-marketing data is available for the non-ODS product

– Production capabilities and supplies are adequate– Patients who require the CFC product are

adequately served* For products with only one marketed brand or strength

Non-essentiality Criteria:– At least one non-ODS product with the same

active moiety* , the same indication, route of administration, about the same level of convenience

– At least 1 year of post-marketing data is available for the non-ODS product

– Production capabilities and supplies are adequate– Patients who require the CFC product are

adequately served* For products with only one marketed brand or strength

19Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

Non-essentiality Criteria (continued):– For Moieties with more than one available

product/strength:– At least two non-ODS product with the

same active moiety , the same indication, route of administration, about the same level of convenience

– Other criteria the same

Non-essentiality Criteria (continued):– For Moieties with more than one available

product/strength:– At least two non-ODS product with the

same active moiety , the same indication, route of administration, about the same level of convenience

– Other criteria the same

20Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

History of the Montreal Protocol History of the Montreal Protocol and 21 CFR 2.125and 21 CFR 2.125

• Since a moiety-by-moiety approach does not effectively address drugs not being reformulated, rewrite of 2.125 stated that:

• Since a moiety-by-moiety approach does not effectively address drugs not being reformulated, rewrite of 2.125 stated that:

[FDA] has therefore revised § 2.125(g)(2) to permit the [FDA] has therefore revised § 2.125(g)(2) to permit the agency to undertake an evaluation of all ODS products agency to undertake an evaluation of all ODS products after January 1, 2005, not just those products without a after January 1, 2005, not just those products without a non-ODS replacement.non-ODS replacement.

21Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

• Beginning in 2005, FDA may convene public meetings (i.e., PADAC meetings) to discuss those products still listed as essential to determine if changes in the medical practice and availability of alternatives render these products as no longer essential

• “Essential” based on:• No technically feasible alternatives• Provides substantial (health, public, or

environmental) benefit • Release of CFC small, or justified given benefit

• Beginning in 2005, FDA may convene public meetings (i.e., PADAC meetings) to discuss those products still listed as essential to determine if changes in the medical practice and availability of alternatives render these products as no longer essential

• “Essential” based on:• No technically feasible alternatives• Provides substantial (health, public, or

environmental) benefit • Release of CFC small, or justified given benefit

History of the Montreal History of the Montreal Protocol and 21 CFR 2.125Protocol and 21 CFR 2.125

History of the Montreal History of the Montreal Protocol and 21 CFR 2.125Protocol and 21 CFR 2.125

22Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

History of the Montreal History of the Montreal Protocol and 21 CFR 2.125Protocol and 21 CFR 2.125

History of the Montreal History of the Montreal Protocol and 21 CFR 2.125Protocol and 21 CFR 2.125

• Note that if PADAC recommends that DRUG X is no longer essential, there is a process that plays out from here

• For FDA to follow the advice, FDA would need to publish a NPR stating that we had preliminarily determined DRUG X to no longer be an essential use

• Public comments would be sought and considered prior to final regulatory action (i.e., a final rule)

• Note that if PADAC recommends that DRUG X is no longer essential, there is a process that plays out from here

• For FDA to follow the advice, FDA would need to publish a NPR stating that we had preliminarily determined DRUG X to no longer be an essential use

• Public comments would be sought and considered prior to final regulatory action (i.e., a final rule)

23Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

CFC essential Use - then and nowCFC essential Use - then and nowCFC essential Use - then and nowCFC essential Use - then and now• Beta-agonists: isoethrane, isoprot.,

albuterol, epineph, metaprot., pirbuterol, bitoterol, salmeterol

• ICS: fluticasone, flunisolide, TAA, BDP, Dexamethsone

• Nasal Steroids• Cromones: Cromolyn, Nedocromil• Anticholinergics: Ipratropium, atropine• Albuterol/Ipratropium , Talc, Contraceptive

Foams, Rectal CS foams, Ergotamine MDIs, Polymyxin, anesthetic drugs, NTG

• Beta-agonists: isoethrane, isoprot., albuterol, epineph, metaprot., pirbuterol, bitoterol, salmeterol

• ICS: fluticasone, flunisolide, TAA, BDP, Dexamethsone

• Nasal Steroids• Cromones: Cromolyn, Nedocromil• Anticholinergics: Ipratropium, atropine• Albuterol/Ipratropium , Talc, Contraceptive

Foams, Rectal CS foams, Ergotamine MDIs, Polymyxin, anesthetic drugs, NTG

No longer essential; Delisting possible soon

24Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

Approved Non-CFC Inhaled Approved Non-CFC Inhaled Respiratory Medications*Respiratory Medications*

Approved Non-CFC Inhaled Approved Non-CFC Inhaled Respiratory Medications*Respiratory Medications*

1. Beta-agonists: – albuterol (Proventil HFA, Ventolin HFA, IVAX’s albuterol

sulfate HFA – all MDIs)– levalbuterol (Xopenex HFA - MDI) – salmeterol (Serevent Diskus – MDPI (multidose dry

powder inhaler)) – formoterol (Foradil Aerolizer – DPI (dry powder inhaler))

2. Inhaled Corticosteroids:– Budesonide (Pulmicort Turbuhaler – MDPI) – fluticasone (Flovent Diskus - MDPI and Flovent HFA -

MDI)– mometasone (Asmanex – MDPI) – beclomethasone (QVAR - MDI)

1. Beta-agonists: – albuterol (Proventil HFA, Ventolin HFA, IVAX’s albuterol

sulfate HFA – all MDIs)– levalbuterol (Xopenex HFA - MDI) – salmeterol (Serevent Diskus – MDPI (multidose dry

powder inhaler)) – formoterol (Foradil Aerolizer – DPI (dry powder inhaler))

2. Inhaled Corticosteroids:– Budesonide (Pulmicort Turbuhaler – MDPI) – fluticasone (Flovent Diskus - MDPI and Flovent HFA -

MDI)– mometasone (Asmanex – MDPI) – beclomethasone (QVAR - MDI)

* Products for nebulization excluded

25Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

3. Cromones: – none

4. Anticholinergics: – ipratropium (Atrovent HFA - MDI) – tiotropium (Spiriva - DPI)

5. Corticosteroid/LABA combination: – salmeterol/fluticasone (Advair Diskus -

MDPI)

3. Cromones: – none

4. Anticholinergics: – ipratropium (Atrovent HFA - MDI) – tiotropium (Spiriva - DPI)

5. Corticosteroid/LABA combination: – salmeterol/fluticasone (Advair Diskus -

MDPI)

Non-CFC Inhaled Respiratory Non-CFC Inhaled Respiratory Medications*Medications*

Non-CFC Inhaled Respiratory Non-CFC Inhaled Respiratory Medications*Medications*

* Products for nebulization excluded

26Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

Moieties currently listed as essential Moieties currently listed as essential for which no current reformulated or for which no current reformulated or

direct alternative product exists:direct alternative product exists:

Moieties currently listed as essential Moieties currently listed as essential for which no current reformulated or for which no current reformulated or

direct alternative product exists:direct alternative product exists:

1. Beta-agonists* – metaproterenol (Alupent) – pirbuterol (Maxair)

2. Inhaled Corticosteroids – flunisolide (Aerobid), – triamcinolone (Azmacort)

3. Cromones – Cromolyn (Intal) – Nedocromil (Tilade)

4. Beta agonist/Anticholinergic combination– Albuterol/Ipratropium (Combivent)

1. Beta-agonists* – metaproterenol (Alupent) – pirbuterol (Maxair)

2. Inhaled Corticosteroids – flunisolide (Aerobid), – triamcinolone (Azmacort)

3. Cromones – Cromolyn (Intal) – Nedocromil (Tilade)

4. Beta agonist/Anticholinergic combination– Albuterol/Ipratropium (Combivent)

*epinephrine excluded

27Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

Trends in Global CFC essential Trends in Global CFC essential uses: TEAP Report 2004uses: TEAP Report 2004

Trends in Global CFC essential Trends in Global CFC essential uses: TEAP Report 2004uses: TEAP Report 2004

0

2000

4000

6000

8000

10000

12000

14000

16000

Exempted

Used

Stock

28Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

ConclusionsConclusionsConclusionsConclusions

• US Govt. moved proactively to address issue of ozone depletion and has had a key role in the Montreal Protocol

• MP is a successful treaty, leading to important reductions in CFCs and other ODS

• MP is increasingly moving towards control in specific essential uses, notably albuterol

• US Govt. moved proactively to address issue of ozone depletion and has had a key role in the Montreal Protocol

• MP is a successful treaty, leading to important reductions in CFCs and other ODS

• MP is increasingly moving towards control in specific essential uses, notably albuterol

29Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

• US is progressing in CFC transition, with many non-CFC products available, many CFC products no longer marketed

• Some CFC products/moieties remain on the market with no current alternatives

• Do these product remain essential?

• US is progressing in CFC transition, with many non-CFC products available, many CFC products no longer marketed

• Some CFC products/moieties remain on the market with no current alternatives

• Do these product remain essential?

ConclusionsConclusionsConclusionsConclusions

30Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004

Charge to the PADACCharge to the PADACCharge to the PADACCharge to the PADAC

• As per the revisions to 2.125, FDA is convening its first PADAC meeting to discuss those products listed as essential to determine if changes in the medical practice and availability of alternatives render these products as no longer essential

• “Essential” based on:• No technically feasible alternatives• Provides substantial (health, public, or

environmental) benefit • Release of CFC small, or justified given benefit

• As per the revisions to 2.125, FDA is convening its first PADAC meeting to discuss those products listed as essential to determine if changes in the medical practice and availability of alternatives render these products as no longer essential

• “Essential” based on:• No technically feasible alternatives• Provides substantial (health, public, or

environmental) benefit • Release of CFC small, or justified given benefit

31Pulmonary-Allergy Drugs Advisory Committee Pulmonary-Allergy Drugs Advisory Committee June 10June 10thth, 2004, 2004