Senior Scientist from Johnson & Johnson Testifies Before Senate HELP Committee on Follow-On Biologics
WASHINGTON, March 08, 2007 /PRNewswire-USNewswire/ -- Johnson & Johnson representative Jay P. Siegel, M.D., testified before the Senate HELP committee today, providing a scientific perspective on the issues relevant to any proposed framework for the approval of follow-on biologics. Johnson & Johnson fully supports transparent, science-based discussions -- such as the Senate HELP Committee hearing -- to identify a pathway for the development of safe follow-on biologic products with the goal of increasing patient access to these important therapies.
"As we examine proposed legislative pathways for follow-on biologics, I encourage all parties to continue to pursue scientifically driven public debate to ensure that public policy is well-founded in science and supports the development of follow-on biologics that are safe and effective for the patients who need them," said Dr. Siegel.
Group President of Research & Development for Johnson & Johnson's Biotechnology, Immunology and Oncology research and development companies, Dr. Siegel is a scientist with specific expertise in the fields of biotechnology, immunology, and clinical trial design. He has dedicated much of his life and career to public health, working 20 years regulating biologics at the Food & Drug Administration (FDA), most recently as Director of the Office of Therapeutics Research and Review within the Center for Biologics Evaluation and Research (CBER). Particularly relevant to today's hearing, he led efforts to develop FDA policy regarding scientific standards for demonstrating the comparability of biological products before and after a manufacturing change.
In his testimony, Dr. Siegel outlined the following five science-based principles that should be addressed in any regulatory paradigm allowing abbreviated applications for follow-on biologic product. All merit close attention in the crafting of a legislative framework:
* There will always be a need for appropriate pre-marketing clinical data
to help ensure that a follow-on biologic is safe and effective. The
complexities of biologics make them particularly susceptible to
clinically significant changes when changes are made to the process by
which they are manufactured. As the production of follow-on biologics
will necessarily involve many changes in process, there will always be
the potential for subtle, but clinically meaningful differences to occur
with follow-on products. Since laboratory testing has proven
insufficient to detect many clinically important differences in
biologics, testing in humans will be necessary to help ensure their
safety and efficacy.
* There cannot be allowance for determinations of "comparability" for
products that are so different in structure that they should be
considered different products entirely, or for products that may have
clinically meaningful differences. Products that are substantially
different in structure should be regulated as different products
requiring full testing for safety and efficacy.
* A follow-on biologic product should not be considered interchangeable
with its reference product. Follow-on biologics can be similar, but
never identical to an innovator biologic. Any application of
"interchangeability" status to a follow-on could lead to inappropriate
assumptions of sameness and substitution of one for the other, with
potentially serious adverse health consequences. Such substitution of
biologics should be discouraged.
* The FDA must be empowered to require post-marketing clinical studies and
post-marketing safety surveillance to ensure safety. Some risks
associated with a follow-on biologic, like all pharmaceuticals, will
become apparent only in the post-marketing period. To optimize patient
safety and control such risks, the safety of follow-on biologics, like
other drugs and biologics, should be monitored by the license holder
through a robust post-marketing safety surveillance program. Also, FDA
must not be limited in its ability to request post-marketing clinical
studies when appropriate.
* There should be no constraints placed on the FDA for ensuring the safety
of follow-on products. As we enter this new field with new safety
risks, the FDA should be unhampered in its ability to request and
receive additional data from a manufacturer as the need becomes
apparent.
Dr. Siegel noted it is additionally critical that such a framework provides appropriate incentives for innovation so that the promise of new and innovative biologic therapies can continue to be realized for patients for generations to come.
"Patient safety and welfare are important concerns that we all share and that must guide us as we develop a statutory pathway for follow-on biologics," said Dr. Siegel.
"It is my hope and that of Johnson & Johnson that a scientifically-based public process will provide a framework and pathway for follow-on biologics in the US -- a pathway which reflects an overriding concern for patient safety and which provides appropriate incentives for innovation so that the promise of new and innovative biologic therapies can continue to be realized for patients for generations to come," added Dr. Siegel.
Johnson & Johnson is the world's most comprehensive and broadly based manufacturer of health care products, as well as a provider of related services, for the consumer, pharmaceutical and medical devices and diagnostics markets. The more than 200 Johnson & Johnson operating companies employ approximately 122,000 men and women and sell products throughout the world.
CONTACT: Mark T. Wolfe, +1-908-541-4058, +1-908-672-4988 cell
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