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Printable Handouts
Navigable Slide Index
- Introduction
- Dr. Lothar Tremmel
- DIA-ASA Biopharm Safety Working Group (SWG)
- What we will talk about
- Section 1: Key concepts in safety surveillance
- Pre-marketing safety surveillance
- Pre-marketing reporting requirements
- Definition: Seriousness
- Definition: Expectedness
- Definition: Relatedness
- Summary of reporting requirements
- Section 2: Assessment of relatedness
- FDA’s final rule
- FDA’s 2010 final rule on IND safety reporting
- The spirit of the rule
- Potential serious risk that require IND safety reporting
- Assessment of ‘relatedness’ per FDA’s ‘final rule’
- FDA IND safety reporting final rule
- Who will do the unblinded aggregate safety review?
- Who will do the unblinded aggregate safety review?
- The ‘known unknowns’
- REBINYN, pegylated Factor IX for hemophilia
- The ‘unknown unknowns’
- Monitoring for increased frequency
- Example 1: The REST trial
- Design of rotavirus efficacy and safety trial
- The REST trial: Results
- Example 2: Mehtrota dataset
- Berry and Berry’s Bayesian model allows using evidence from similar AEs
- Frequentist approach based on FDR (False Discovery Rate)
- Section 3: Providing context and perspective to emerging suspected safety issues
- Context: Disease-specific background rates
- Why the concept of ‘anticipated events’ is so important
- The importance of accurate background rates
- EHR/health claims databases may present issues for extrapolation to clinical trial databases
- Quantifying risk to provide perspective
- Quantifying risk: Example
- Perspective: risks vs. benefits
- The risk/benefit equation may not be the same in all sub-populations
- Section 4: The importance of interdisciplinary collaboration
- What you or your colleagues may not know
- Confused?
- The Aggregate Safety Assessment Plan (ASAP)
- Overview of ASAP sections
- ASAP section 1: Governance
- ASAP section 2: Define the ‘known unknowns’
- ASAP section 3: Analysis of ‘known unknowns’
- Section 3 specifies proper analyses for the safety topics of interest, following these principles:
- ASAP section 4 identifies data gaps
- ASAP section 5: Specifies the ‘increased frequency analyses’
- Section 6: Safety communications
- Communication of safety information: Planning
- The ASAP: burden vs. value
- Standardization of product level statistical analyses avoids operational confusion
- Summary
Topics Covered
- Key-concepts in safety surveillance
- Pre-marketing and post-marketing surveillance
- Assessing drug-event relatedness via increased frequency analysis
- The FDA’s final rule on IND safety reporting
- Surveilling for unknown unknowns
- Providing context and perspective to emerging suspected safety issues
- The importance of interdisciplinary collaboration
- The Aggregate Safety Assessment Plan (ASAP)
Links
Categories:
External Links
- EMA. ICH Topic E2A Clinical Safety Data Management: Definitions and Standards for Expedited Reporting. European Medicines Agency. 1995
- FDA. Safety Reporting Requirements for INDs (Investigational New Drug Applications) and BA/BE (Bioavailability/Bioequivalence) Studies. Guidance for Industry and Investigators. 2012
- FDA. Code of Federal Regulations Title 21 Food and Drugs; Chapter I Food and Drug Administration Department of Health and Human Services Subchapter D Drugs for Human Use Part 312 Investigational New Drug Application. 2010
- FDA. Sponsor Responsibilities - Safety Reporting Requirements and Safety Assessment for IND and BA/BE Studies. 2021
- FDA. Appendix B: REBINYN Clinical Review Memo. 2017
- The Winton Centre analysis of the risks and benefits of the AZ/Oxford COVID vaccine, April 2021
Talk Citation
Tremmel, L. (2021, October 28). A structured approach for pharmaceutical pre-marketing safety surveillance [Video file]. In The Biomedical & Life Sciences Collection, Henry Stewart Talks. Retrieved December 30, 2024, from https://doi.org/10.69645/XEJI1615.Export Citation (RIS)
Publication History
Financial Disclosures
- Dr. Lothar Tremmel has not informed HSTalks of any commercial/financial relationship that it is appropriate to disclose.
A selection of talks on Methods
Transcript
Please wait while the transcript is being prepared...
0:00
Hello, my name is Lothar Tremmel.
I work at CSL Behring, which is a plasma-based pharmaceutical company,
and I work there as the Head of QCSR, which stands for 'quantitative clinical sciences and reporting'.
The topic of my talk today is: pre-marketing safety surveillance, a structured approach.
0:22
Here you can see some more details about myself in case you're interested,
I'm not going to read this for you, you can do this at your leisure.
0:32
What is important is that I'm a member of the DIA-ASA Biopharm Safety Working Group,
and it's important because a lot of the thinking I'm going to present comes out of this working group,
in particular, the thinking around the structured approach that we call A, S, A, P or ASAP.
0:52
Here is what we will talk about.
We will talk about key concepts in safety surveillance,
then about the difficult issue of assessing drug event-relatedness through increased frequency analysis,
in particular in the light of the FDA's 'final rule' concerning IND safety reporting.
The third topic is providing context and perspective to emerging suspected safety issues.
The fourth topic is the importance of interdisciplinary collaboration.
Finally, I will introduce a structured approach towards safety surveillance
in the pre-marketing setting, that we call the Aggregate Safety Assessment Plan or ASAP.
1:35
Let's talk about some key concepts in safety surveillance.
Many of you may be familiar with post-marketing surveillance,
this is the effort of collecting spontaneously reported adverse events once the drug is
in the marketplace, these data are then collected in databases,
we record evidence databases such as for instance, the class of RWE databases
that are joined together in the FDA's sentinel project.
These are very large databases, but the data quality can be problematic.
There is no denominator information available, no exposure information available,
and limited ways to query these databases.
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