us-fda-guidance-5efeee913c1b119477c2d17c2b54f646•E19 OPTIMISATION OF SAFETY DATA COLLECTION
E19 OPTIMISATION OF SAFETY DATA COLLECTION
us-fda-guidance-5efeee913c1b119477c2d17c2b54f646E19 OPTIMISATION OF SAFETY DATA COLLECTIONDraft Guidance
Administrative draft guidance, not enacted legislation. This captured publisher edition preserves the listed document and attachments; later developments are not independently consolidated.
- Docket Number:
- FDA-2019-D-1828
- Issued by:
- Guidance Issuing OfficeCenter for Drug Evaluation and Research
This Guideline is intended to provide internationally harmonised guidance on when it would be appropriate to use a selective approach to safety data collection in some late-stage pre-marketing or post- marketing studies, and how such an approach would be implemented. By collecting selective safety data, the burden to patients would be reduced, a larger number of informative clinical studies could be carried out with greater efficiency, studies could be conducted with greater global participation, and the public health would be better served.
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E19 OPTIMISATION OF SAFETY DATA COLLECTION This draft guidance, when finalized, will represent the current thinking of the Food and Drug Administration (FDA or Agency) on this topic. It does not establish any rights for any person and is not binding on FDA or the public. You can use an alternative approach if it satisfies the requirements of the applicable statutes and regulations. To discuss an alternative approach, contact the FDA staff responsible for this guidance as listed on the title page. The draft guidance has been left in the original International Council for Harmonisation format. The final guidance will be reformatted and edited to conform with FDA’s good guidance practice regulation and style. For questions regarding this draft document, contact (CDER) Ellis Unger, M.D., 301-796-2270.
INTERNATIONAL COUNCIL FOR HARMONISATION OF TECHNICAL REQUIREMENTS FOR PHARMACEUTICALS FOR HUMAN USE ICH HARMONISED GUIDELINE Optimisation of Safety Data Collection E19 Draft version Endorsed on 3 April 2019 Currently under public consultation At Step 2 of the ICH Process, a consensus draft text or guideline, agreed by the appropriate ICH Expert Working Group, is transmitted by the ICH Assembly to the regulatory authorities of the ICH regions for internal and external consultation, according to national or regional procedures.
2 E19 Document History Code History Date E19 Endorsement by the Members of the ICH Assembly under Step 2 and release for public consultation (document dated 28 February 2019). 3 April 2019 Legal notice: This document is protected by copyright and may, with the exception of the ICH logo, be used, reproduced, incorporated into other works, adapted, modified, translated or distributed under a public license provided that ICH's copyright in the document is acknowledged at all times. In case of any adaption, modification or translation of the document, reasonable steps must be taken to clearly label, demarcate or otherwise identify that changes were made to or based on the original document. Any impression that the adaption, modification or translation of the original document is endorsed or sponsored by the ICH must be avoided. The document is provided "as is" without warranty of any kind. In no event shall the ICH or the authors of the original document be liable for any claim, damages or other liability arising from the use of the document. The above-mentioned permissions do not apply to content supplied by third parties. Therefore, for documents where the copyright vests in a third party, permission for reproduction must be obtained from this copyright holder.
1 ICH HARMONISED GUIDELINE 2 Optimisation of Safety Data Collection 3 E19 4 5 TABLE OF CONTENTS 6 1 INTRODUCTION ............................................................................................................ 4 7 1.1 Objective of the Guideline ...................................................................................................... 4 8 1.2 Background ............................................................................................................................. 4 9 1.3 Scope of the Guideline ............................................................................................................ 4 10 2 GENERAL PRINCIPLES ............................................................................................... 5 11 2.1 Types of Data for Which Selective Safety Data Collection May be Appropriate .................. 5 12 2.1.1 Types of Safety Data Where it May be Appropriate to Limit or Stop Collection ............ 5 13 2.1.2 Types of Safety Data That Should Generally be Collected under All Circumstances .... 5 14 2.1.3 Baseline 15 Data……………………………………………………………………………….5 16 2.2 When May Selective Safety Data Collection Be Considered? ............................................... 6 17 2.2.1 Benefit-Risk Considerations for Selective Safety Data Collection.................................. 6 18 2.2.2 Extent of 19 Exposure………………………………………………………………………….7 20 2.3 Examples Where Selective Safety Data Collection May be Considered ................................ 7 21 2.4 Ensuring Patient Safety within Studies ................................................................................... 7 22 2.5 Changes in Approach to Safety Data Collection..................................................................... 8 23 2.6 Early Consultation with Regulatory Authorities ..................................................................... 8 24 3 METHODS OF IMPLEMENTATION .......................................................................... 8 25 3.1 Selective Safety Data Collection for All Patients in the Study ............................................... 9 26 3.2 Comprehensive Safety Data Collection for a Specific Subset(s) of the Population, with 27 Selective Safety Data Collection for Other Patients ........................................................................... 9 28 3.3 Comprehensive Safety Data Collection in a Representative Subset of the Population, with 29 Selective Safety Data Collection for Other Patients ........................................................................... 9 30 3.4 Comprehensive Safety Data Collection for the Initial Portion of the Study, with Selective 31 Data Collection Thereafter .................................................................................................................. 9 32 4 RELATIONSHIP WITH OTHER GUIDELINES/REGULATIONS ....................... 10 33 34
ICH E19 Guideline 4 1 INTRODUCTION 35 1.1 Objective of the Guideline 36 This Guideline is intended to provide internationally harmonised guidance on an optimised 37 approach to safety data collection in some late-stage pre-approval or post-approval studies 38 when the safety profile of a drug is sufficiently characterised. Optimisation of safety data 39 collection using a selective approach may improve the efficiency of clinical studies while 40 reducing the burden to study participants. Adoption of an internationally harmonised approach 41 to selective safety data collection may facilitate global participation in clinical studies. 42 1.2 Background 43 Regulators and industry have a shared interest in reducing the burden to study participants 44 while facilitating the conduct of studies that could yield important new medical knowledge and 45 advance public health. Although safety monitoring of patients during clinical studies remains 46 critically important, unnecessary and burdensome data collection may serve as a disincentive 47 to participation in clinical studies, e.g., frequent and time-consuming patient visits; laboratory 48 tests; and/or physical examinations. 49 Knowledge about a medicinal product’s safety profile continually evolves as safety data 50 accumulates. Throughout the course of medicinal product development and subsequently 51 while the drug is marketed, sponsors collect extensive safety-related data, including all vital 52 signs, laboratory data, and adverse events. In the later stages of drug development, and if the 53 safety profile is well-understood and documented, comprehensive collection of all safety data 54 may provide only limited additional knowledge of clinical importance. In such circumstances, 55 a more selective approach to safety data collection may be adequate and optimal, as long as the 56 study objectives and the welfare of study participants are not compromised. 57 Importantly, sponsors and investigators should ensure that routine patient care is not 58 compromised by the selective safety data collection approach outlined in this Guideline. It is 59 recognised that safety monitoring serves to protect individual study participants and will 60 continue to be performed as per standard of care. 61 1.3 Scope of the Guideline 62 This guidance is intended to apply to collection of safety data during the late-stage development 63 of medicinal products in interventional and non-interventional studies, in the post-approval 64 setting and, for specific cases, in the pre-approval setting. 65 In the pre-approval setting, comprehensive safety data collection is expected in order to 66 elucidate frequency, severity, seriousness, and dose-response of adverse events, including 67 potential differences across subsets, e.g., demographic; concomitant illnesses; and/or 68 concomitant therapy. However, even before approval of a new medicinal product, if there is 69 agreement with regulatory authorities that sufficient safety data are available or are being 70 collected in ongoing late-stage studies, selective safety data collection may be appropriate in 71 certain studies. 72
ICH E19 Guideline 5 Selective safety data collection following the principles of this Guideline does not alter 73 local/regional safety reporting requirements. 74 2 GENERAL PRINCIPLES 75 2.1 Types of Data for Which Selective Safety Data Collection May be Appropriate 76 2.1.1 Types of Safety Data Where It May be Appropriate to Limit or Stop Collection 77 1. Non-serious adverse events 78 2. Routine laboratory tests 79 3. Information on concomitant medications 80 4. Physical examinations (including vital signs) 81 5. Electrocardiograms 82 2.1.2 Types of Safety Data That Should Generally be Collected under All Circumstances 83 For the following types of events/data, comprehensive details should generally be provided to 84 allow adequate assessment of the event/data, e.g., history; associated adverse events; relevant 85 laboratory values; concomitant medications; vital signs; and/or follow-up outcome. 86 1. Deaths 87 2. Serious adverse events 88 3. Significant adverse events that led to an intervention, including withdrawal or dose 89 reduction of investigational medicinal product or addition of concomitant therapy 90 4. Marked laboratory abnormalities (other than those meeting the definition of serious) 91 5. Overdose 92 6. Pregnancies 93 7. Adverse events of special interest (if defined). These adverse events may warrant 94 collection of additional information across the entire study population to better 95 characterise these events (e.g., particular laboratory parameters; vital signs; risk 96 factors; concomitant therapies; and/or concomitant illnesses). For example, if 97 gastrointestinal haemorrhage was an adverse event of special interest, one might 98 want to proactively collect concomitant antithrombotic therapy across the entire 99 study population 100 8. Laboratory data, vital signs, electrocardiograms of special interest (if defined) 101 2.1.3 Baseline Data 102 Use of a selective safety data collection approach does not change considerations for baseline 103 data collection. Baseline data are needed to ensure that subjects meet inclusion and exclusion 104 criteria for study enrolment and are important in the assessment of safety. For example, 105 particular serious adverse events may occur more frequently in subgroups defined on the basis 106 of demographics, baseline disease characteristics, coexisting illnesses, or concomitant 107 therapies; analyses of such information can be important in considering the benefit-risk profile 108 of the drug. 109
ICH E19 Guideline 6 2.2 When May Selective Safety Data Collection Be Considered? 110 When sponsors choose to implement selective safety data collection for a clinical study, a 111 scientific justification should be provided. Factors that contribute to a determination that 112 selective safety data collection would be appropriate include: 113 1. The medicinal product has received marketing authorisation from a regulatory 114 authority for the indication under investigation 115 2. Availability of post-approval safety data and findings 116 3. The dose, dosing regimen, dosage form, route of administration and treatment 117 duration used in the previously conducted studies are comparable to the planned use 118 of the drug in the proposed study 119 4. The patient population from previously conducted studies is representative of 120 subjects in the planned study regarding demographic characteristics, underlying 121 medical conditions, concomitant drugs, and other important factors (e.g., 122 Cytochrome P450 enzymes (CYP) metabolizer status) 123 5. Exposure in previously conducted (or ongoing, if applicable) studies that contribute 124 to the overall safety database, i.e., number exposure to drug, treatment duration 125 6. Consistency of the safety profile across previous studies 126 7. Characteristics of previous studies, e.g., study design; study conduct; adequacy of 127 safety monitoring/safety data collection; availability of protocols; statistical analysis 128 plan; and/or access to data 129 8. Knowledge of the mechanism of action of the medicinal product under study 130 9. Knowledge of the safety profile of approved drugs in the same pharmacologic class 131 The above factors should be considered in determining whether the safety of the medicinal 132 product has been sufficiently characterised to provide justification for selective safety data 133 collection in the proposed study. 134 In the pre-approval setting, selective safety data collection may be justifiable if sufficient safety 135 data are available from completed studies. Moreover, when sufficient safety data will be 136 forthcoming from one or more ongoing late-stage study(ies), selective safety data collection 137 may be appropriate for a concurrently conducted study-initiated pre-approval. 138 2.2.1 Benefit-Risk Considerations for Selective Safety Data Collection 139 It should be recognised that the contribution of non-serious adverse events to the benefit-risk 140 profile of a drug may differ depending on the indication of use and patient characteristics (e.g., 141 age and/or cardiovascular risk factors). These factors should be considered when accepting the 142 comparability of patient populations and the applicability of selective safety data collection. 143 For example, even when safety of a drug is sufficiently characterised in a patient population 144 with advanced disease, comprehensive safety data collection in a patient population with less 145 advanced disease may be appropriate to ensure that the benefits outweigh the risks in the less 146 severely affected population. 147
ICH E19 Guideline 7 2.2.2 Extent of Exposure 148 Selective safety data collection could be considered for studies using lower doses and/or shorter 149 durations than in previous studies. Conversely, selective safety data collection would generally 150 not be acceptable if higher doses and/or longer treatment durations than previously studied are 151 planned. Nonetheless, even when exposure is greater in the planned study, there may be 152 circumstances where selective safety data collection is still appropriate, e.g., a study designed 153 to characterise infrequent serious adverse events (e.g., renal toxicity; myocardial infarction; 154 and/or stroke) associated with longer term use of the medicinal product within the labelled 155 indication; a planned five-year study when a one-year study has been completed. 156 2.3 Examples Where Selective Safety Data Collection May be Considered 157 Selective safety data collection may be appropriate in studies used to evaluate some of the 158 following objectives. These are not the only circumstances where selective safety data 159 collection may be appropriate. 160 1. New indications of approved drugs 161 2. To study additional endpoints, e.g., patient-reported outcome for symptomatic 162 improvement; quality of life; and/or outcome studies (e.g., mortality; morbidity; and/or 163 specific safety issues) 164 3. To study comparative effectiveness/efficacy 165 4. Demonstration of superiority when non-inferiority has been demonstrated 166 5. Characterisation of adverse events of special interest 167 6. Fulfilment of post-approval requirements, post-authorisation safety studies based on 168 data collection from registries or electronic health records 169 7. Late-stage premarketing outcome study in a large population 170 Additional examples and situations for applying selective safety data collection may be found 171 in Section 3, Methods of Implementation. 172 2.4 Ensuring Patient Safety within Studies 173 Patient safety monitoring serves two purposes: 1) to protect the welfare of individual study 174 participants; and 2) to accumulate safety information to be used in the assessment of benefit- 175 risk for the proposed indication. The recommendations in this Guideline do not obviate the 176 need for monitoring to protect individual patient welfare. Although certain safety data, e.g., 177 non-serious adverse events, would not need to be recorded in the case report form (CRF) when 178 selective safety data collection is determined to be appropriate, the protocol should stipulate 179 that patients are monitored per standard of care. For example, for a medicinal product known 180 to cause hyperglycaemia, where routine blood glucose monitoring is recommended in labeling, 181 glucose should be monitored in patients participating in a study. If hyperglycaemia is well- 182 characterised with this medicinal product, the glucose data do not need to be recorded in the 183 CRF or reported to the sponsor in studies using selective safety data collection. Glucose levels 184 would be recorded in the CRF and reported to the sponsor if stipulated in the protocol, e.g., as 185 an adverse event of special interest, associated with a serious adverse event. 186
ICH E19 Guideline 8 2.5 Changes in Approach to Safety Data Collection 187 When an unexpected safety issue arises during the course of a study, e.g., a postmarketing 188 safety signal; a finding from a nonclinical study; higher than expected withdrawals; and/or 189 concern from a data monitoring committee; a change in the selective safety data collection 190 approach may be warranted, e.g., denoting a new adverse event of special interest; and/or 191 reverting to comprehensive safety data collection. 192 2.6 Early Consultation with Regulatory Authorities 193 Studies must be conducted according to local and regional laws and regulatory requirements. 194 When sponsors are considering selective safety data collection in interventional studies, they 195 should discuss their scientific rationale and planned methods with regulatory authorities prior 196 to initiating the study(ies). The same applies to non-interventional studies that are being 197 conducted to address requests from regulatory authorities. 198 It is possible to conduct a multi-regional clinical study using a single protocol with selective 199 safety data collection if the safety profile of the product is considered to be sufficiently 200 characterised, and all regulatory authorities agree with the proposed approach. A well- 201 designed multi-regional clinical study that takes this Guideline into account will help the 202 sponsor reach agreement with regulatory authorities in multiple regions (See ICH E17 – 203 General Principles for Planning and Design of Multi-Regional Clinical Trials). 204 3 METHODS OF IMPLEMENTATION 205 Having considered the principles outlined in Section 2, General Principles, with respect to 206 when it may be appropriate to limit or stop collection of certain types of safety data, a number 207 of approaches for selective safety data collection may be considered. 208 Use of selective safety data collection can introduce important complexities in study conduct 209 and safety analysis. The specific approaches should be carefully planned and clearly delineated 210 within the relevant study documents, e.g., protocol; monitoring plan; and/or statistical analysis 211 plan, with a reference to this Guideline. 212 Regardless of the method chosen, it is essential to ensure patient safety and adhere to local and 213 regional laws and regulations. When the selective safety data collection approach is used for 214 a clinical study, the approach should be described in the appropriate document(s) when safety 215 findings are presented, e.g., the Clinical Study Report (CSR); Development Safety Update 216 Report (DSUR); Periodic Benefit-Risk Evaluation Report (PBRER); Periodic Safety Update 217 Report (PSUR); and/or Common Technical Document (CTD). 218 The following examples of methods of implementation are not meant to be all-inclusive. These 219 approaches can be applied in both the pre- and post-approval settings and require a scientific 220 rationale and justification. The data supporting these approaches are more likely to be available 221 in the post-approval setting than in the pre-approval setting. 222
ICH E19 Guideline 9 3.1 Selective Safety Data Collection for All Patients in the Study 223 For all patients in the study, parameters listed in Section 2.1.2, General Principles, are collected 224 throughout the study, e.g., serious adverse events; adverse events of special interest; and/or 225 deaths. Conversely, the parameters listed in Section 2.1.1, General Principles, are not 226 collected, e.g., non-serious adverse events; routine laboratory values; concomitant 227 medications; physical examination data; vital signs; and/or electrocardiograms. 228 In the post-approval setting, this approach may be useful to address a specific safety concern, 229 for example, to meet a post-authorisation commitment, when safety in other regards has been 230 sufficiently characterised. 231 In the pre-approval setting, this approach may be also used. For example, consider a 232 development programme for a lipid-lowering drug, where a decrease in low-density lipoprotein 233 (LDL) cholesterol will serve as the basis of approval, but the impact on cardiovascular risk is 234 being investigated. In addition to the completed Phase 2 programme, two Phase 3 studies are 235 ongoing with LDL cholesterol as the primary endpoint, which will provide adequate exposure 236 to assess safety sufficiently. The sponsor wishes to initiate a third study with major adverse 237 cardiovascular events as the primary endpoint. For the third study, a selective safety data 238 collection approach could be justified considering the data available in light of the principles 239 above. 240 3.2 Comprehensive Safety Data Collection for a Specific Subset(s) of the Population, 241 with Selective Safety Data Collection for Other Patients 242 Comprehensive safety data are collected for specific subset(s) of the patient population where 243 additional information is deemed important, whereas selective safety data are collected for 244 other patients. For example, if the patient population in previous studies included few patients 245 over the age of 65, it could be of value to collect full data on this population in a new study in 246 the same indication or in a related indication. Other examples of specific subsets include those 247 based on geographic location; ethnicity; sex; baseline disease status (renal/hepatic impairment), 248 CYP status; or genetics. 249 3.3 Comprehensive Safety Data Collection in a Representative Subset of the 250 Population, with Selective Safety Data Collection for Other Patients 251 In some cases, efficacy studies must enrol many thousands of patients in order to achieve 252 adequate statistical power. In such settings, such as a large clinical outcomes study, the number 253 of patients planned for enrolment may greatly exceed the number needed to assess the non- 254 serious adverse events adequately. In this setting, comprehensive safety data could be collected 255 for only a representative subset of patients, for example, full data collection could be 256 undertaken at randomly selected sites. 257 3.4 Comprehensive Safety Data Collection for the Initial Portion of the Study, with 258 Selective Data Collection Thereafter 259 Comprehensive safety data are collected from baseline through some pre-determined interval 260 of the study, with selective safety data collection thereafter. A data monitoring committee 261
ICH E19 Guideline 10 could consider the safety data and provide agreement with selective safety data collection for 262 the subsequent portion of the study. These approaches can be useful for studies designed to 263 assess important long-term drug effects, where safety would be adequately characterised in the 264 early part of the study, e.g., one year, through comprehensive safety data collection. For 265 example, consider a study to prevent an important outcome such as dementia, end-stage kidney 266 disease, and/or hepatic failure. Assuming it would take three years to collect adequate events 267 to have adequate statistical power for efficacy, it may be appropriate to utilize a selective 268 approach to safety data collection once data have been analysed for all patients followed 269 through one year and non-serious adverse events have been deemed to be adequately 270 characterised. The selective approach would discontinue collection of non-serious adverse 271 events, vital signs, laboratory tests, etc., and utilize less frequent study visit intervals. The 272 protocol should include a prospective plan for concurrence of a data monitoring committee 273 prior to the change to selective safety data collection. 274 4 RELATIONSHIP WITH OTHER GUIDELINES/REGULATIONS 275 This guideline should be considered in conjunction with other ICH guidelines relevant to the 276 conduct of clinical studies and clinical safety data management, e.g., E2A (Clinical Safety Data 277 Management: Definitions and Standards for Expedited Reporting); E2F (Development Safety 278 Update Report); E3 (Structure and Content of Clinical Study Reports ); E6(R2) (Good Clinical 279 Practice: Integrated Addendum to ICH E6(R1)); E8 (General Considerations for Clinical 280 Trials); and/or E17 (General Principles for Planning and Design of Multi-Regional Clinical 281 Trials). Evaluation of the information generated through post-approval pharmacovigilance 282 activities is also important for all products to ensure their safe use, e.g. E2E (Pharmacovigilance 283 Planning); E2D (Post-Approval Safety Data Management: Definitions and Standards for 284 Expedited Reporting); and E2C(R2) (Periodic Benefit-Risk Evaluation Report). 285
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