us-fda-guidance-1ac74bd7b032a70aecf6e831267ac143•Pediatric Rare Diseases--A Collaborative Approach for Drug Development Using Gaucher Disease as a Model; Draft Guidance for Industry: Draft Guidance for Industry
Pediatric Rare Diseases--A Collaborative Approach for Drug Development Using Gaucher Disease as a Model; Draft Guidance for Industry: Draft Guidance for Industry
us-fda-guidance-1ac74bd7b032a70aecf6e831267ac143Pediatric Rare Diseases--A Collaborative Approach for Drug Development Using Gaucher Disease as a Model; Draft Guidance for Industry: Draft Guidance for IndustryDraft Guidance
Administrative draft guidance, not enacted legislation.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-2017-N-6476
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- Guidance Issuing OfficeCenter for Drug Evaluation and Research
The emergence of concomitant trials for multiple investigational drug products for the treatment 21 of rare diseases can pose significant challenges to effective drug development due to the limited 22 number of patients worldwide with any given rare condition. The purpose of this guidance is to 23 facilitate drug development in pediatric rare diseases. In particular, it discusses a new possible 24 approach to enhance the efficiency of drug development in pediatric rare diseases using Gaucher 25 disease as an example. This new approach consists of a controlled, multi-arm, multi-company 26 clinical trial, which aims to facilitate the development of multiple drug products in a time27 efficient manner while minimizing the number of patients necessary to be treated with placebo. 28 The general principles presented should be viewed as a proposal only, and the principles 29 underlying the proposal may be extended to other areas of drug development in rare diseases. Of 30 note, the specific recommendations regarding drug development for Gaucher Disease apply only 31 to systemic (i.e., non-neurological) manifestations of Gaucher disease in treatment-naïve patients 32 with Type I and Type III phenotypes, across all the pediatric ages (i.e., up to 18 years of age).
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Pediatric Rare Diseases — A Collaborative Approach for Drug Development Using Gaucher Disease as a Model Guidance for Industry DRAFT GUIDANCE This guidance document is being distributed for comment purposes only. Comments and suggestions regarding this draft document should be submitted within 60 days of publication in the Federal Register of the notice announcing the availability of the draft guidance. Submit electronic comments to https://www.regulations.gov. Submit written comments to the Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. All comments should be identified with the docket number listed in the notice of availability that publishes in the Federal Register. For questions regarding this draft document, contact Hong Vu at 301-796-7401. U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) December 2017 Rare Diseases 16252414dft.docx 11/28/17
Pediatric Rare Diseases — A Collaborative Approach for Drug Development Using Gaucher Disease as a Model Guidance for Industry Additional copies are available from: Office of Communications, Division of Drug Information Center for Drug Evaluation and Research Food and Drug Administration 10001 New Hampshire Ave., Hillandale Bldg., 4th Floor Silver Spring, MD 20993-0002 Phone: 855-543-3784 or 301-796-3400; Fax: 301-431-6353; Email: druginfo@fda.hhs.gov https://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) December 2017 Rare Diseases
TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. 1 II. BACKGROUND ............................................................................................................... 2 A. Disease Characteristics and Response to Treatment .................................................................. 2 B. Unmet Needs in Pediatric Gaucher Disease ................................................................................ 3 III. NONCLINICAL AND CLINICAL CONSIDERATIONS............................................ 3 A. Nonclinical Models of Gaucher Disease ....................................................................................... 3 B. Endpoint Assessments in Gaucher Disease .................................................................................. 4 C. Long-Term Clinical Aspects ......................................................................................................... 5 D. The Use of Extrapolation of Efficacy for Pediatric Gaucher Disease ....................................... 5 IV. PROPOSED MULTI-ARM, MULTI-COMPANY TRIAL FOR PEDIATRIC GAUCHER DISEASE ...................................................................................................... 6 GENERAL REFERENCES AND GUIDELINES ................................................................... 10
Contains Nonbinding Recommendations Draft — Not for Implementation 1 Pediatric Rare Diseases — 2 A Collaborative Approach for Drug Development 3 Using Gaucher Disease as a Model 4 Guidance for Industry1 5 6 7 8 9 This draft guidance, when finalized, will represent the current thinking of the Food and Drug 10 Administration (FDA or Agency) on this topic. It does not establish any rights for any person and is not 11 binding on FDA or the public. You can use an alternative approach if it satisfies the requirements of the 12 applicable statutes and regulations. To discuss an alternative approach, contact the FDA staff responsible 13 for this guidance as listed on the title page. 14 15 16 17 18 I. INTRODUCTION 19 20 The emergence of concomitant trials for multiple investigational drug products for the treatment 21 of rare diseases can pose significant challenges to effective drug development due to the limited 22 number of patients worldwide with any given rare condition. The purpose of this guidance is to 23 facilitate drug development in pediatric rare diseases. In particular, it discusses a new possible 24 approach to enhance the efficiency of drug development in pediatric rare diseases using Gaucher 25 disease as an example. This new approach consists of a controlled, multi-arm, multi-company 26 clinical trial, which aims to facilitate the development of multiple drug products in a time 27 efficient manner while minimizing the number of patients necessary to be treated with placebo. 28 The general principles presented should be viewed as a proposal only, and the principles 29 underlying the proposal may be extended to other areas of drug development in rare diseases. Of 30 note, the specific recommendations regarding drug development for Gaucher Disease apply only 31 to systemic (i.e., non-neurological) manifestations of Gaucher disease in treatment-naïve patients 32 with Type I and Type III phenotypes, across all the pediatric ages (i.e., up to 18 years of age). 33 34 Modified approaches may be proposed, but the sponsor should justify the specific choice of each 35 new strategy. Given that rare disease drug development tends to require global involvement, and 36 the potential differences in requirement between the FDA and other regulatory agencies, 37 sponsors are advised to consult the appropriate regulatory agency(ies) prior to initiation of such 38 trials. 39 1 This guidance has been prepared by the Division of Gastroenterology and Inborn Errors Products in the Center for Drug Evaluation and Research at the Food and Drug Administration. This guidance adapts with minor modifications the 2017 update of the 2014 Food and Drug Administration – European Medicines Agency Collaborative Approach document titled “Gaucher Disease — A Strategic Collaborative Approach From EMA and FDA.” 1
Contains Nonbinding Recommendations Draft — Not for Implementation 40 In general, FDA’s guidance documents do not establish legally enforceable responsibilities. 41 Instead, guidances describe the Agency’s current thinking on a topic and should be viewed only 42 as recommendations, unless specific regulatory or statutory requirements are cited. The use of 43 the word should in Agency guidances means that something is suggested or recommended, but 44 not required. 45 46 47 II. BACKGROUND 48 49 A. Disease Characteristics and Response to Treatment 50 51 Gaucher disease is one of the most common lysosomal storage disorders, estimated to affect 52 6,000 individuals in the United States.2 It meets the U.S. regulatory definition of an orphan 53 disease (i.e., fewer than 200,000 affected individuals). 54 55 Historically, Gaucher disease has been classified into three phenotypes. Although nowadays 56 many view Gaucher disease as a spectrum of manifestations, and alternative classifications have 57 been proposed on the basis of absence or presence of neurological symptoms (the latter further 58 subdivided into acute or chronic forms), the following phenotypes continue to be commonly 59 referenced: 60 61 Type I refers to the somatic, non-neurological form (the most prevalent) 62 Type II refers to the acute, infantile neuronopathic form, usually lethal in infancy 63 Type III refers to the chronic, neuronopathic form (it may have somatic manifestations as 64 well) 65 66 In Gaucher disease, the age at onset of symptoms tends to correlate with clinical severity and 67 subsequent outcomes. A lower residual level of enzyme activity generally results in earlier onset 68 and greater severity of disease manifestations. 69 70 The underlying biology of Gaucher disease is the same in adults and children. However, clinical 71 manifestations in children differ from those seen in adults, both in presentation and disease 72 course. Disease-modifying factors such as type of genetic mutation, residual enzyme activity, 73 and epigenetic factors may further influence disease presentation and rates of clinical 74 progression. 75 76 The current standard of care in the pediatric Gaucher population in the United States consists of 77 enzyme replacement therapy (ERT), which is used to treat the non-neurological (i.e., somatic) 78 manifestations of the disease in patients with Type I and Type III phenotype. Despite the 79 availability of ERT, other therapies with different mechanisms of action may still offer 80 complementary or additive clinical benefit. 81 82 Given that ERT is the current standard of care, placebo-controlled trials of new generation ERTs 83 in pediatric patients with Type I Gaucher disease are not considered ethical because of 2 https://rarediseases.org/rare-diseases/gaucher-disease/ 2
Contains Nonbinding Recommendations Draft — Not for Implementation 84 demonstrated clinical improvements with the currently available ERT. However, new non-ERT 85 investigational drug products may be studied using a placebo add-on design while continuing 86 current ERT management. 87 88 B. Unmet Needs in Pediatric Gaucher Disease 89 90 Studies conducted thus far have not adequately addressed all the major medical needs across all 91 pediatric age groups. For example, few patients younger than 2 years of age have been enrolled 92 in clinical trials. Additionally, the disease’s impact on growth rate, bone, and pulmonary 93 manifestations has not been fully studied with available ERT therapy. Another unmet medical 94 need is that of drug products with more practical routes of administration. Developing age 95 appropriate oral pharmaceutical drug products (e.g., substrate reduction therapies) could be 96 beneficial across all pediatric ages and may add benefit to the existing ERTs. Finally, although 97 not addressed by this guidance, there is an unmet clinical therapeutic need for pediatric patients 98 with neurological involvement (Types II and III), because current ERT therapy does not impact 99 neurologic manifestations of Gaucher disease. 100 101 102 III. NONCLINICAL AND CLINICAL CONSIDERATIONS 103 104 A. Nonclinical Models of Gaucher Disease 105 106 Animal models of Gaucher disease are available to test preliminarily the effect of new drug 107 products prior to initiating human studies (Farfel-Becker et al. 2011). However, the Gaucher 108 disease phenotypes in many disease models have little or no similarity to the human Gaucher 109 phenotypes. The selection of an animal Gaucher disease model to support pediatric drug 110 development should be based on the relationship with efficacy endpoints to be evaluated in 111 pediatric studies, or the need to measure or develop pharmacodynamic (PD) markers of drug 112 product activity. Because toxicity may result from the sudden release and accumulation of 113 metabolites resulting from the enzymatic degradation of the accumulated substrate, it may be 114 appropriate to include toxicity endpoints in the pharmacology studies conducted in animal 115 models of the disease. 116 117 For ERTs, the need for juvenile animal toxicology studies should be decided on a case-by-case 118 basis, depending on the age of the patient population to be treated. Toxicology studies in 119 juvenile animals of appropriate age should be conducted when considered necessary. 120 121 Small molecules also should be assessed on a case-by-case basis to determine the need for 122 juvenile animal toxicity studies. Factors to consider are described in the International Council 123 for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH) 124 guidance for industry M3(R2) Nonclinical Safety Studies for the Conduct of Human Clinical 125 Trials and Marketing Authorization for Pharmaceuticals.3 It should be noted that the assessment 126 for small molecules may be more complex than for ERTs, because the on- and off-target effects 3 We update guidances periodically. To make sure you have the most recent version of a guidance, check the FDA Drugs guidance web page at https://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm. 3
Contains Nonbinding Recommendations Draft — Not for Implementation 127 of small molecules are less predictable, and the development programs (clinical and nonclinical) 128 for small molecules differ from ERT development programs. 129 130 B. Endpoint Assessments in Gaucher Disease 131 132 Previous approval of ERT for Gaucher disease in adult patients has been based upon 133 demonstrated clinical improvements in hepatosplenomegaly and improvements in biochemical 134 endpoints (hemoglobin and platelet levels). 135 136 For drug development programs in pediatric rare diseases, it may be necessary to develop, 137 validate, and employ age-specific endpoints. The relevant endpoints and outcome measures for 138 the pediatric population should be identified as early as possible. It is important to include 139 protocol design features that allow pediatric patients to contribute directly in these measures 140 when possible (e.g., patient-reported outcome measures). Where relevant, it may also be 141 reasonable to assess, in the adult drug development program, endpoints that can be potentially 142 used in pediatric clinical trials. 143 144 Because the quality of available clinical outcome assessments (COAs) can vary, qualification 145 and standardization is strongly recommended. Developers are encouraged to discuss the selected 146 COA for the outcomes of interest with the FDA; involvement of relevant stakeholders, including 147 patients is encouraged. 148 149 If for any reason studies cannot be blinded, biases should be addressed. The issue of assay 150 sensitivity should be considered if the trial uses a noninferiority margin. 151 152 With specific relevance to Gaucher disease, the following should also be considered when 153 planning studies: 154 155 Disease-modifying factors (e.g., mutation, residual enzyme activity, age) and epigenetic 156 factors contribute to different disease presentations. Enrolling pediatric patients who are 157 as homogenous as possible will increase the probability of detecting a treatment effect. 158 The need for a study to be conducted in a homogeneous population should not delay the 159 timely access to a drug product for age subgroups that are inherently harder to study 160 because of intrinsic heterogeneity. 161 162 Exploratory biomarkers, such as markers of lung and bone disease, and measurement of 163 bone mineral density or bone marrow disease burden should be assessed. 164 165 Neurological assessments should be included in studies as exploratory endpoints to 166 inform further studies for neuronopathic manifestations of Type III Gaucher disease. 167 Inclusion of a pharmacogenomics perspective in the drug development program, to 168 evaluate and explore the different modifiers of the genotype-phenotype relationship, is 169 also recommended. 170 4
Contains Nonbinding Recommendations Draft — Not for Implementation 171 C. Long-Term Clinical Aspects 172 173 Long-term follow-up in a prospective study is necessary to evaluate the long-term safety and 174 efficacy of treatment on disease manifestations in pediatric patients. 175 176 Throughout many parts of the world, children with Gaucher disease are often managed at 177 specialized centers where enrollment into clinical trials can be facilitated. Follow-up of patients 178 from such centers should be encouraged to evaluate long-term safety and long-term maintenance 179 dosing. 180 181 Hematological and/or visceral endpoints have been standardized, and are most commonly 182 evaluated in the pediatric trials. 183 184 Improved documentation of other significant measurements (e.g., growth and developmental 185 changes, bone disease, pulmonary function, and neurological manifestations) should be 186 implemented to facilitate understanding of the long-term effects of treatment. 187 188 Patient registries are an adjunctive tool for monitoring efficacy and safety. When registries are 189 set up individually per drug product, the burden on all stakeholders is increased and comparative 190 analyses between patient groups or across drug products cannot be easily conducted. The FDA 191 recommends across-registry agreement on a uniform set of core data elements to be collected by 192 all existing or future Gaucher disease registries. This may include information on key pediatric 193 manifestations such as growth rate and bone disease, relationship between treatment and 194 outcomes, collection of adverse events, etc. All children born to treated mothers should also be 195 evaluated long term. 196 197 D. The Use of Extrapolation of Efficacy for Pediatric Gaucher Disease 198 199 Extrapolation of efficacy can be considered when the course of the disease and the expected 200 response to a drug product would be sufficiently similar in the pediatric and reference population 201 (i.e., adult or other pediatric age population). In the case of pediatric Gaucher disease, the 202 impact of the different mechanisms of action and disease-modifying factors (e.g., type of 203 mutation, residual enzyme activity, age) and epigenetic factors resulting in different 204 presentations of the disease should be carefully considered. When characteristics of different 205 patient populations are able to be identified, extrapolation can be considered. The use of 206 extrapolation of efficacy in pediatric Gaucher disease can avoid unnecessary studies, increase 207 efficiency, reduce testing burden to patients, and better allocate resources to address relevant 208 questions. An extrapolation plan could be formulated early during drug development, with the 209 recognition that the plan may not address all aspects necessary in the development of emerging 210 drug products across all ages of pediatric patients. Ultimately, additional clinical studies may be 211 necessary for determination of efficacy across all age groups. 212 213 Pediatric extrapolation of efficacy from adults to children can be considered for the somatic 214 manifestations of both Type I and Type III Gaucher disease, such as visceral, hematologic, and 215 pulmonary disease. In contrast, effects of therapy on specific pediatric manifestations (e.g., 5
Contains Nonbinding Recommendations Draft — Not for Implementation 216 growth rate, onset of puberty and progression of pubertal development) are not amenable to 217 extrapolation. 218 219 These characteristics should be specifically addressed in pediatric studies. In such studies safety 220 data should be collected to identify unexpected (age-specific) safety concerns. 221 222 Existing knowledge generated from adult Gaucher disease programs (such as nonclinical data, 223 data about related compounds, effect of treatment on specific disease subgroups) can inform 224 specific aspects of the pediatric program. Data from the adult Gaucher disease programs may 225 support conclusions of efficacy and safety. Such data could be used in exploring differences in 226 pharmacokinetic (PK), PK/PD, treatment-induced changes in different disease manifestations, 227 and clinical response to treatment in the pediatric population. A mechanism-based approach 228 (e.g., physiologically based PK modeling, mechanistic disease PK/PD) should play a key role for 229 dose characterization. Whenever new studies in children are deemed necessary, modeling and 230 simulation should be used to optimize pediatric studies (e.g., design, sample size, starting doses, 231 timing of sampling, and number of samples) and particularly to inform the dosing rationale. 232 233 Safety and risk considerations based on the existing knowledge should guide the decision of 234 whether specific mitigation, such as staggered enrollment based on age group, is necessary. 235 However, any uncertainties related to the use of existing knowledge should be identified early in 236 the pediatric drug development and managed prospectively (e.g., potential issues such as 237 differences in drug product quality/manufacturing, immunogenicity, pharmacokinetics). 238 239 240 IV. PROPOSED MULTI-ARM, MULTI-COMPANY TRIAL FOR PEDIATRIC 241 GAUCHER DISEASE 242 243 The proposal in this guidance covers the principal features necessary to demonstrate efficacy and 244 safety in treatment-naïve pediatric patients with Gaucher disease Type I. It also applies to the 245 systemic non-neurological manifestations in Type III Gaucher disease. The proposal provides a 246 strategy for designing a multi-arm, multi-company drug development program. It includes a 247 description of the main inclusion criteria, relevant age groups, suggested efficacy endpoints, and 248 study duration. Although such a program can be very challenging, the aim of the strategic plan 249 is not only to facilitate agreement on individual applications, but also to address the feasibility of 250 developing multiple drug products for a rare disease in a time-efficient manner. 251 252 While recognizing the inherent limitations and challenges in conducting simultaneous drug 253 development programs in pediatric Gaucher disease, this guidance proposes a multi-arm, multi 254 company, as presented in Table 1. If this approach is to be undertaken, each individual new drug 255 product should demonstrate both safety and efficacy. 256 257 This approach may allow for a reduction in the total number of children to be enrolled, as 258 compared to conducting separate controlled trials, because a single control arm can be used to 259 assess the effects of more than one drug product. The proposal applies only to systemic (i.e., 260 non-neurological) manifestations of Gaucher disease in treatment-naïve patients with Type I and 6
Contains Nonbinding Recommendations Draft — Not for Implementation 261 Type III phenotypes, across all the pediatric ages. It is not intended for the neurological 262 manifestations of Gaucher disease for which there are no approved drug products at this time. 263 264 Table 1. Proposed Double-Blind, Controlled, Randomized, Multi-Center, Multi-Arm, 265 Multi-Company Noninferiority or Superiority ERT Trial for Non-Neurological 266 Manifestations of Gaucher Disease Study Identifier(s) Strategic Collaborative Pediatric Approach for Gaucher Disease Study design features Double-blind, controlled, randomized, multi-center, multi-arm, multi-company noninferiority or superiority trial to evaluate the efficacy and safety of “product A,” “product B,” “product C,” etc., compared to a single ERT drug product in pediatric patients with Gaucher disease Type I and Type III. Equal allocation to each arm: e.g., 1:1:1:1; an unequal 2:1 allocation (new drug product:ERT drug product) may be considered. Randomization should ensure that at any point in time, patients can be randomized to control as well as a new active drug product Centralized randomization stratified for type and age group Centralized assessment (laboratory and radiographic) may be considered. Main objective(s) To evaluate noninferiority or superiority of new drug product(s) to an approved ERT treatment. Study population and subset definition Male and female pediatric patients, from birth to younger than 18 years with Type I and Type III phenotypes with non-neurological manifestations of Gaucher disease.a Number of study The calculated sample size should be sufficient to detect noninferiority in the patients by pediatric proposed primary endpoint with at least 80% power and a type I error rate of 0.025 subset (e.g., age, sex, for each investigational drug product in the trial. Superiority trials are also severity or stage) acceptable. The noninferiority margin should be carefully chosen and prespecified. This is particularly crucial because the assay sensitivity of the trial cannot be assessed in the usual way due to lack of a placebo control group. Consulting regulatory bodies for scientific advice about this issue before study start is therefore highly recommended. The sample size is determined by the predefined noninferiority margin and the assumed variability of the primary endpoint. The most precise information available at the time of study planning should be thoroughly considered and be supported by data and/or literature references. Main inclusion criteria Clinical diagnosis of Gaucher disease, with documented deficiency of acid beta glucosidase activity by enzyme assay. Gaucher Type I and Type III with non-neurological manifestations. Genotyping for Gaucher disease. Treatment-naïve patients. Birth to younger than 18 years of age.a 267 continued 7
Contains Nonbinding Recommendations Draft — Not for Implementation 268 Table 1, continued Study Identifier(s) Strategic Collaborative Pediatric Approach for Gaucher Disease Main exclusion criteria Clinical symptoms predominantly indicative of neurological disease (i.e., Type II disease; Type III patients with neurological manifestations can be enrolled as long as the efficacy measures somatic disease). Study duration for Two years of treatment for the analysis of the primary endpoint. patients Long-term monitoring of primary and secondary endpoints and safety in an extension study. This extension should cover at least 3 years; however, at least 5 years is recommended. Dosage, treatment regimen, route of administration ERT drug products: doses should be defined. Substrate reduction therapy drug products: doses should be defined. b Other therapies: doses should be defined. Control(s) Active control group — ERT administered at the approved dose. The dose should be adjusted by weight at least every 6 months, in line with growth, as reflective of current standard of care. An add-on placebo-controlled design can be considered when evaluating study drugs with different mechanisms of action. Endpoint(s) with The relevant endpoints should be chosen based on the mechanisms of action of the time(s) of assessment selected drug products. Such selection should also take into consideration the heterogeneity of the pediatric Gaucher population. Consider the following suggestions: Change in hemoglobin relative to baseline, stratified by background hematinic usage. Growth rate as measured by Z-score; bone age, height change, weight and body mass index at baseline and subsequent time points (e.g., every 6 months and yearly thereafter). Age at pubertal onset (Tanner Stage II) and Tanner staging at baseline and at least every 6 months between Tanner Stage I and Stage IV for the duration of the trial. Platelet count at baseline and at least every 6 months. Liver and spleen size as multiples of normal (measured with magnetic resonance imaging) at baseline and subsequent time points. Bone manifestations; including pain intensity and duration and fractures, at least every 6 months. Pulmonary function, measured at baseline and appropriate time intervals (e.g., every 6 months). Safety and tolerability, including infusion-related reactions. Antibody levels (including neutralizing antibodies) for each ERT drug product — the specific schedule should be discussed with the regulatory agencies. Assays should be validated at the time of trial initiation. 269 continued 8
Contains Nonbinding Recommendations Draft — Not for Implementation 270 Table 1, continued Study Identifier(s) Strategic Collaborative Pediatric Approach for Gaucher Disease Statistical plan including study conduct and analysis Primary analysis of the primary endpoint: noninferiority comparison of each individual investigational drug product to control, respectively, by means of a 95% confidence interval method, in both the per-protocol and intent-to-treat population. c After data freeze, the main analysis of the multi-company study should be performed by therapy-blinded, independent statisticians. It is recommended that the long-term monitoring results be analyzed in the same way. All statistical analyses should be prespecified in detail in a statistical analysis plan. The potential impact of missing values should be addressed with sensitivity analyses. Various approaches should be performed and their results should be compared and critically discussed, in particular with respect to the noninferiority design of the trial. d Measures to minimize pain and distress Topical anaesthesia should be offered for all venous access procedures with documentation of usage. External independent data safety monitoring board External independent data safety monitoring boards should be used during trials. Early stopping of a treatment arm for clinical decline should be considered 271 a Although pediatric age is defined per FDA regulation from birth to 16 years (21 CFR 201.57(c)(9)(iv)(A)), studying patients up to 18 years of 272 age is appropriate because other definitions of pediatric age used in clinical practice apply to children up to 18 years. 273 b For a substrate reduction therapy or “other therapies” trial, a placebo, add-on design may be more appropriate. The FDA should be consulted. 274 c See the guidance for industry Non-Inferiority Clinical Trials to Establish Effectiveness. 275 d See the ICH guidance for industry E9 Statistical Principles for Clinical Trials for detailed recommendations. 276 9
Contains Nonbinding Recommendations Draft — Not for Implementation 277 GENERAL REFERENCES AND GUIDELINES 278 279 Literature 280 281 Dunne, J, WJ Rodriguez, MD Murphy, et al., 2011, Extrapolation of Adult Data and Other Data 282 in Pediatric Drug-Development Programs, Pediatrics, 128:e1242–e1249. 283 284 Farfel-Becker, T, EB Vitner, and AH Futerman, 2011, Animal Models for Gaucher Disease 285 Research, Dis. Model. Mech, 4:746–752. 286 287 Futerman, AH and A Zimran, editors, 2007, Gaucher Disease (Hardback), CRC Press. 288 289 Mistry, P, J Liu, M Yang, et al., 2010, Glucocerebrosidase Gene-Deficient Mouse Recapitulates 290 Gaucher Disease Displaying Cellular and Molecular Dysregulation Beyond the Macrophage, 291 PNAS, 107:19473–19478. 292 293 Pastores, GM, NJ Weinreb, H Aerts, et al., 2004, Therapeutic Goals in the Treatment of Gaucher 294 Disease, Semin Hematol, 41(Suppl 5):S4–S14. 295 296 Guidances for Industry 297 298 Draft guidance for industry General Clinical Pharmacology Considerations for Pediatric Studies 299 for Drugs and Biological Products4 300 301 Guidance for industry Non-Inferiority Clinical Trials to Establish Effectiveness 302 303 Guidance for industry Patient-Reported Outcome Measures: Use in Medical Product 304 Development to Support Labeling Claims 305 306 Guidance for industry Scientific Considerations in Demonstrating Biosimilarity to a Reference 307 Product 308 309 ICH guidance for industry E9 Statistical Principles for Clinical Trials 310 311 EMA Documents5 312 313 Concept Paper on Extrapolation of Efficacy and Safety in Medicine Development 314 315 Guideline on the Choice of the Non-Inferiority Margin 316 317 Guideline on Clinical Trials in Small Populations 318 4 When final, this guidance will represent the FDA’s current thinking on this topic. 5 EMA documents can be found on the Search the Document Library web page at http://www.ema.europa.eu/ema/index.jsp?curl=pages/document_library/landing/document_library_search.jsp. 10
Contains Nonbinding Recommendations Draft — Not for Implementation 319 Guideline on Missing Data in Confirmatory Clinical Trials 320 321 Patient Registries Workshop, 28 October 2016 322 323 Preliminary Meeting Report: Workshop on Methodological Aspects of Clinical Trials for 324 Efficacy Evaluation in Small Populations 325 326 Press Release: Orphan Drug and Paediatric Clinical Trials — EMEA Workshop on 327 Methodological Aspects of Clinical Trials for Efficacy Evaluation in Small Populations 328 329 Points to Consider on Switching Between Superiority and Non-Inferiority 330 11
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