Dear all:
FDA Announces Availability of a Public Docket, “Exposure-Response Analysis in 
Drug Development and Regulatory Decision Making; Request for Comments”

On April 6, 2018, the U.S. Food and Drug Administration (FDA) announced the 
availability of a public docket entitled “Exposure-Response Analysis in Drug 
Development and Regulatory Decision Making; Request for Comments” to give 
interested parties an opportunity to identify areas of scientific policy that 
may need further clarity or elaboration, as well as any obstacles preventing 
use of exposure-response analyses in drug development and regulatory review.

The Prescription Drug User Fee Act of 2017 (PDUFA VI), part of the FDA 
Reauthorization Act of 2017 (FDARA), highlights the goal of advancing 
model-informed drug development (MIDD). Exposure-response analysis is a MIDD 
strategy that has been used in drug development and regulatory decision making. 
On May 6, 2003, FDA issued a guidance for industry titled “Exposure-Response 
Relationships – Study Design, Data Analysis, and Regulatory Applications” 
(available at 
https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM072109.pdf).
 This guidance provides recommendations for the use of exposure-response 
analyses in the development of drugs, including therapeutic biologics. Since 
then, FDA and drug developers have gained a wealth of experience performing 
exposure-response analyses and leveraging the results to influence drug 
development and inform regulatory review, and have identified obstacles 
limiting its routine application. FDA wants to capture the public’s experience 
to inform future efforts on providing additional clarity, new insights, and 
updated recommendations for employing exposure-response analyses in drug 
development.

Interested persons are invited to provide detailed information and comments on 
the use of exposure-response analysis in drug development and regulatory 
review. FDA is particularly interested in responses to the following questions 
and will consider all information and comments submitted:

1.      In general, are there any aspects of the 2003 guidance for industry 
titled “Exposure-Response Relationships--Study Design, Data Analysis, and 
Regulatory Applications” that merit further elaboration? Additionally, are 
there any new topic areas that should be addressed?

2.      What are best practices for conducting exposure-response analysis that 
can be generally applied across development programs and regulatory 
submissions? Input on best practices can include any of the following topic 
areas:

·        Planning and design (e.g., data considerations, assumption setting)

·        Analytical approaches (e.g., exposure and response metrics, choice and 
inclusion of predictors, methods for addressing confounding factors)

·        Model evaluation and qualification (e.g., goodness-of-fit, assessment 
of model risk, impact on regulatory decisions)

·        Communication of results and impact on subsequent drug development or 
regulatory decisions

3.      What attributes of an exposure-response analysis are critical to 
effectively inform a drug development or regulatory decision? Additionally, 
what are the main obstacles preventing widespread acceptance of 
exposure-response analyses?

4.      During which stages of drug development would it be most productive to 
interact with the FDA regarding exposure-response analysis planning? What type 
of feedback would be useful to inform exposure-response analyses and to reduce 
uncertainty in regulatory acceptance?

The “Exposure-Response Analysis in Drug Development and Regulatory Decision 
Making; Request for Comments” public docket is available at 
https://go.usa.gov/xQ4m2. Please refer to the public docket for more details.

FDA established this public docket to collect public comments. You may submit 
your comments to this public docket by July 5, 2018 to the Docket No. 
FDA-2018-N-0791 available at https://www.regulations.gov. Your comments do make 
a difference and can impact the outcomes of FDA regulatory policy. Share your 
knowledge and experience, and make your voice count.
________________________________
We always welcome your thoughts regarding the format, content, and utility of 
the communication. Comments may be sent via email to 
o...@fda.hhs.gov<mailto:o...@fda.hhs.gov>.
This communication was prepared by Office of Clinical Pharmacology, Office of 
Translational Sciences, CDER, FDA.


Yaning Wang, Ph.D.
Director
Division of Pharmacometrics
Office of Clinical Pharmacology
Office of Translational Sciences
Center for Drug Evaluation and Research
Food and Drug Administration
Phone: 301-796-1624
Email: yaning.w...@fda.hhs.gov<mailto:yaning.w...@fda.hhs.gov>
Disclaimer: The contents of this message are mine personally and do not 
necessarily reflect any position of the Government or the Food and Drug 
Administration.

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