The main
regulatory body at large in the pharmaceutical manufacturing industry is the
Food and Drug Administration (FDA). The FDA sets de jure standards responsible
for protecting and promoting public health through the regulation and
management of food safety, pharmaceutical drugs, and many other fields relating
to public health. The main body of the FDA responsible for the development and
approval of drugs is the Center for Drug Evaluation and Research (CDER). The
goal of CDER is to ensure that drugs marketed in the United States are safe and
effective. CDER recently published a strategic plan to discuss the steps it
will be taking to address pressing issues and their proposed ways of enhancing
operations over the next five years. One of the main issues outlined in the plan
is scientific innovation. CDER admits that not all current trends in the
pharmaceutical industry are positive. “Despite the significant advances in
basic research witnessed over recent decades, the cost of new drug research and
development has never been greater, nor the failure rate in drug development
higher” (FDA CDER). It is estimated that the failure rate in late-stage
clinical development is around 50 %. One of the major, reoccurring factors
contributing to this failure rate is scientific uncertainty. New methods and
technologies for gauging the clinical benefits and risks of a drug much earlier
in development would help reduce these uncertainties, resulting in a lower cost
and risk in drug development. This would allow more innovators to invest in the
development of new medicines.
One example of an
area that would benefit from a reduction in scientific uncertainty is
biotechnology. The pharmaceutical protein products developed by biotechnology processes
are derived from complicated expression and production systems that usually
involve a genetically modified host cell and growth media. Production
conditions can greatly affect the final protein structure, which may result in
changes in efficacy or safety of the product. “Understanding the relationships
between production conditions, product characteristics, and clinical
performance and safety is critical for both innovator biologics as well as
biosimilars” (FDA CDER).
The foundation of
CDER’s scientific innovation strategy includes addressing scientific
uncertainties, collaborating to develop tools and approaches to deal with those
uncertainties, qualifying new drug development tools for use in regulatory
decision-making, and conducting training on and making informatics and data
analysis readily available to reviewers. Once these new scientific standards
are established, the FDA can update their regulatory requirements and decision
protocols to include these methods. By continuously revising regulatory
requirements, the FDA incorporates scientific innovation into their management
strategy. All prescription and over-the-counter drug manufactures are required
to comply with FDA regulations and therefore integrate scientific innovation
into their business and manufacturing model.
CDER’s strategic
plan also includes scientific innovation goals and initiatives, including
information about when each initiative will start and identifying the key
external stakeholders. For example, one of CDER’s initiatives is, “Advancing
regulatory sciences related to innovator and generic product manufacturing and
quality” (FDA CDER). This initiative is labeled as on-going with stakeholders
in academia, regulated industry, research consortia, standards organizations,
and other federal agencies. It is interested to note that several of the
initiatives have standards organizations as one of the stakeholders. The FDA
recognizes that some of the work it does directly affects how standards
organizations like ASTM and USP developed their standards. Standard
organizations need to aware of the drug approval process and quality
regulations outlined by the FDA in order to ensure seamless transition from the
research and development laboratory to clinical production and manufacturing.
As with many scientific fields, the regulatory bodies and standards
organizations of the pharmaceutical industry are interconnected and dependent
on each other for proper functionality.
Table
1—CDER’s Scientific Innovation Initiatives
Scientific Innovation
Initiatives
|
Start
|
Key External
Stakeholders
|
Advancing
the Use of Biomarkers and Pharmacogenomics
|
2013
|
·
Regulated
Industry
·
Research
Consortia
|
Advancing
Development of Patient-Reported Outcomes (PROs) and Other Outcome Assessment
Tools
|
2013
|
·
Patients
·
Research
Consortia
·
Regulated
Industry
|
Advancing
Development of Drugs for Rare Diseases
|
2013
|
·
Patients
·
Research
Consortia
·
Regulated
Industry
|
Advancing
the Science of Meta-Analysis Methodologies
|
2012
|
·
Other
Federal Agencies
·
Regulated
Industry
·
Academia
|
Advancing
the Development of Predictive Safety Models, Biomarkers, and Assessment Tools
(e.g., through public private consortia)
|
On-going
|
·
Patients
·
Research
Consortia
·
Regulated
Industry
·
Other
Federal Agencies
|
Advancing
Social and Behavioral Science to Help Consumers and Professionals Make
Informed Decisions about Regulated Products
|
On-going
|
·
Patients
·
Research
Consortia
·
Regulated
Industry
·
Academia
|
Advancing
Regulatory Sciences Related to Innovator and Generic Product Manufacturing
and Quality
|
On-going
|
·
Academia
·
Regulated
Industry
·
Research
Consortia
·
Standards
Organizations
·
Other
Federal Agencies
|
Advancing
Regulatory Science Related to the Manufacture, Characterization and
Assessment of Biologic Drug Products
|
On-going
|
·
Academia
·
Regulated
Industry
·
Research
Consortia
·
Standards
Organizations
·
Other
Federal Agencies
|
Advancing
the Development of Electronic Data Analysis Tools to Enhance Review
Capabilities
|
On-going
|
·
Standards
Organizations
·
Private
Industry
·
Academia
·
Research
Consortia
·
Other
Federal Agencies
|
Source— FDA Center for Drug Evaluation
and Research (CDER): Strategic Plan 2013-2017
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