US 505(b)(2) Regulatory Pathway and Strategies

US 505(b)(2) Regulatory Pathway and Strategies US 505(b)(2) Regulatory Pathway and Strategies

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Case Study: Cafcit • Caffeine citrate for treatment of apnea of prematurity (MeadJohnson, NDA 20-793, September 21, 1999)• Development Program:– Submitted 1 double-blind trial in 58 preterm infants and 90 literaturearticles• Human PK studies from literature (19 articles)• Drug-drug interactions from literature (71 articles)– No human PK studies conducted in premature infants• Used plasma caffeine levels from subjects in the study and used special software to dopopulation PK analysisReceived orphan drug status (7 years data exclusivity) and expedited review

Pro-Drugs• Fundamental:– Where does the pro-drug become the RLD?–

Case Study: Cafcit • Caffeine citrate for treatment of apnea of prematurity (MeadJohnson, NDA 20-793, September 21, 1999)• Development Program:– Submitted 1 double-blind trial in 58 preterm infants <strong>and</strong> 90 literaturearticles• Human PK studies from literature (19 articles)• Drug-drug interactions from literature (71 articles)– No human PK studies conducted in premature infants• Used plasma caffeine levels from subjects in the study <strong>and</strong> used special software to dopopulation PK analysisReceived orphan drug status (7 years data exclusivity) <strong>and</strong> expedited review

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