Oncology Pediatric Initiatives

Richard Pazdur, MD

Director, Division of Oncology Drug Products

Food and Drug Modernization Act of 1997- An incentive Program

• Provision for 6 month extension to existing marketing exclusivity or patent protection can be granted to an entire product line of an active moiety for providing new pediatric information that will benefit the public health.

• Submissions must come in response to an FDA Written Request.

Pediatric Rule of 1998- A Mandate

• A product under review must provide pediatric information if the indication under review is a disease found in children. If the disease is not found in children, a waiver may be granted.

Comparison of FDAMA vs. 1998 Rule

• Voluntary

• Applies to entire product line

• No restriction on eligible pediatric diseases

• Only applies when there is underlying patent or exclusivity protection

• Biologicals and some products excluded

• Orphan products included

• Mandatory

• Only applies to the product and indication under review

• Only applies if the pediatric disease is similar to the adult disease

• Applies to biologicals

• Orphan products excluded

Pediatric Exclusivity

Written RequestFrom FDA

Submission of Study Reports

FDA Determination

Proposed PediatricStudy Request

FDA experience with FDAMA incentive

Overall

• Proposals received: 184

• Written Requests issued: 153

Oncology

• Proposals received: 5

• Written Requests issued: 3

• Written Requests pending: 4

Pediatric Development Plan

Overview

• Dosing and pharmacokinetics in Phase 1

• Phase 2 or pilot studies in a range of potential indications

• Not a supplemental NDA since efficacy need not be demonstrated

• Applies to both new agents and approved agents that have not been adequately investigated in pediatric oncology

Pediatric Development PlanFirst Stage

• Phase 1 studies to determine dose, pharmacokinetics, and toxicities

• Planned for about 25 patients

• If unacceptable toxicity occurs, the development would stop and an exclusivity extension could be granted

• If toxicity is acceptable, proceed to second stage (anticipated general case)

Pediatric Development Plan

Second Stage

• Phase 2 studies (single agent or add on comparative design) and/or pilot studies (combinations) to demonstrate an agent’s characteristics and contribution to – efficacy, perhaps using surrogate endpoints

such as response rate– justification for further development to examine

clinical benefit

Possible Outcomes

At the completion of the second stage• If efficacy is demonstrated, approval for the

indication under subpart H or full approval

• If no beneficial effect is observed, development is stopped

• If results are promising but not sufficient to support approval, a commitment to further development

ALL THREE CASES CAN RESULT IN GRANTING OF EXCLUSIVITY EXTENSION

Results of Completion of a Pediatric Development Plan

• The results are summarized in a study report and submitted to the FDA

• Upon review, if the conditions of the initial Written Request are met, REGARDLESS OF OUTCOME, a 6 month exclusivity extension may be granted

• Well designed, well executed studies with a negative result can qualify

• Intent is a prospective plan to produce new information of importance to pediatric oncology