Protecting and Promoting Public Health: Advancing the FDA’s Medical Countermeasures Mission

By Anna Abram

The U.S. Food and Drug Administration’s wide-ranging public health responsibilities include the vital role we play on the frontlines of national security by facilitating the development and availability of safe and effective medical countermeasures. These are the vaccines, diagnostics and therapeutics that are needed to protect our nation from chemical, biological, and radiological and nuclear threats, whether naturally occurring, accidental, or deliberate. As in so many areas of public health, our work here is critical, and we are ever-cognizant of its urgency.

One of the many areas in which the agency is continuing to take steps to facilitate the development of medical countermeasures to protect Americans is with respect to the threat of smallpox. The World Health Assembly declared naturally occurring smallpox eradicated worldwide in 1980, following an unprecedented global immunization campaign. However, small amounts of the variola virus – the virus that causes smallpox – still exist for research purposes in two labs; one of these labs is in the U.S. and the other in Russia. Despite the eradication of naturally occurring smallpox disease, there are longstanding concerns that the variola virus could be used as a weapon. Since routine vaccination was discontinued in the 1970s, many people would be at high risk of getting very ill or dying if exposed to this highly contagious virus.

Medical Countermeasures Against Smallpox

The development of medical countermeasures for smallpox presents complex and unique challenges. It is not possible to conduct clinical trials involving patients with naturally occurring smallpox and exposing humans to the variola virus would be ethically unthinkable. To address this challenge – which also applies to many of the high-priority threat agents for which medical countermeasure are being developed – the FDA in 2002 established the Animal Rule, which allows efficacy data to be obtained solely from studies in animals when studies in humans are not ethical or feasible, provided the results can be reasonably extrapolated to expected human use and plans can be made for follow-up study when appropriate. (The FDA finalized guidance on product development under the Animal Rule in 2015).

Anna Abram

Anna Abram is FDA’s Deputy Commissioner for Policy, Planning, Legislation, and Analysis

However, the variola virus poses additional issues for drug developers. Unlike other products studied under the Animal Rule, studies of smallpox countermeasures require not just a surrogate host but also a surrogate pathogen. Most pathogens are capable of infecting multiple host species and therefore can be studied in other, nonhuman, species. But the variola virus only infects humans, which means that variola virus animal models are unlikely to convincingly resemble the human disease. To help delineate a path forward, the FDA issued a draft guidance “Smallpox (Variola) Infection: Developing Drugs for Treatment and Prevention” in 2007 and brought these important issues to an FDA public workshop in 2009 and an FDA advisory committee meeting in 2011. The revised draft guidance issued last week incorporates this input, providing developers with additional clarity on the regulatory path for products intended to treat smallpox. It recommends that efficacy be demonstrated based on studies in two animal models infected with related viruses – such as a monkey model using monkeypox and a rabbit model using rabbitpox. This guidance underscores how the FDA is continually working to identify and apply efficient solutions based on the most up-to date science in its regulation of safe and effective medical products.

The ultimate testament to the success of these efforts is the approval on July 13 of TPOXX (teconvirimat), the first drug with an indication for the treatment of smallpox and the 14th medical countermeasure approved under the Animal Rule. In conjunction with this product approval, the sponsor was awarded the first Material Threat Medical Countermeasure Priority Review Voucher, established by the 21st Century Cures Act, to incentivize the development of certain medical countermeasures against some of the most serious threat agents.

The FDA’s Other Recent Work on Medical Countermeasures

Smallpox isn’t the only area of medical countermeasure work ongoing at the FDA. On July 10, we approved an autoinjector which provides a one-time dose of the antidote atropine to block the effects of a nerve agent or certain insecticide poisonings (organophosphorus and/or carbamate).

We also recently issued an Emergency Use Authorization (EUA) to the Department of Defense (DoD), permitting the emergency use of a specific freeze-dried plasma product manufactured to treat U.S. military personnel with severe or life-threatening hemorrhage or coagulopathy (a condition that affects the blood’s ability to clot) due to traumatic injuries sustained in the conduct of military operations in situations when plasma is not available or when its use is not practical. The use of plasma in combat settings is severely limited by logistical and operational challenges, such as the need for refrigeration and, in the case of frozen plasma, a long thawing period. In January 2018, the FDA and DoD announced a joint program to prioritize the efficient development of safe and effective medical products intended to save the lives of American military personnel.  We are working closely with our DoD colleagues in these important priority areas, including the goal of having a licensed freeze-dried plasma product as soon as possible.

These are just some of the ways in which the FDA has been hard at work to advance our medical countermeasure mission. But there is more work to do and the agency is committed to doing it. We are constantly reminded that chemical, biological, radiological, and nuclear threats – whether deliberate, naturally occurring or accidental – can, and often do, emerge with little to no warning. Emerging threats are often not deterred by geographical boundaries in our modern times. The recent Ebola outbreak in the Democratic Republic of Congo is a reminder of the need to remain ever vigilant in our work to advance medical countermeasures as part of protecting and promoting public health.

We are committed to doing all that we can to continue to facilitate the development and availability of medical countermeasures. The FDA’s Medical Countermeasures Initiative (MCMi), established in 2010, is focused on providing clear regulatory pathways for medical countermeasures, advancing regulatory science to support regulatory decision-making, and articulating important regulatory policies and mechanisms to facilitate the timely development and availability of medical countermeasures. These actions are translating into tangible results. Since 2012, the FDA has approved, licensed or cleared more than 120 medical countermeasures (including supplemental changes to already approved applications and modifications to diagnostic devices) for a diverse array of threats including anthrax, smallpox, botulinum toxin, plague, and pandemic influenza.

Under the MCMi, the FDA is taking key actions to address many of the challenges associated with countermeasure development. For example, we still do not have adequate animal models to support the development of medical countermeasures against many potential biothreats nor do we have sufficient biomarkers to assist in supporting the extrapolation of data generated in animal models to humans. Without such tools, it can be difficult to generate the data necessary to support regulatory decision-making.

Given the urgency inherent in our medical countermeasure work, addressing these regulatory science gaps remains a high priority for the agency. To help address these challenges, the FDA has established a broad and robust portfolio of cutting-edge research under the MCMi Regulatory Science Program and is working with our private sector and government partners, including DoD, to help facilitate the translation of discoveries in science and technology into safe and effective medical countermeasures. Congress has also provided vital support and our recent actions in this space underscore how we are fully leveraging the authorities Congress has given us, including measures enacted as part of the Pandemic and All-Hazards Preparedness Reauthorization Act of 2013 and the 21st Century Cures Act.

The FDA remains deeply committed to working closely with its partners to achieve our mission of protecting and promoting the public health, both at home and abroad, by doing our part to facilitate the timely development of safe and effective medical countermeasures to protect our nation.

Anna Abram is the FDA’s Deputy Commissioner for Policy, Planning, Legislation and Analysis.

FDA Budget Matters: Investing in Advanced Domestic Manufacturing

By: Scott Gottlieb, M.D.

There’s new technology that can improve drug quality, address shortages of medicines, lower drug costs, and bring pharmaceutical manufacturing back to the United States. At the FDA, we’re focused on propelling these innovations, collectively referred to as advanced manufacturing.

Dr. Scott GottliebAdvanced manufacturing, which includes various technologies, such as continuous manufacturing and 3D printing, holds great promise for improving the American market for drugs and biologicals.

Consider continuous manufacturing. These methods integrate traditional step-wise manufacturing processes into a single system that’s based on modern process monitoring and controls. This enables a steady output of finished drug products even as raw materials are continuously added to the closed system. The closed and continuous nature of these manufacturing systems means that the process is easier to control. These systems also require smaller footprints to operate.

And they’re far more efficient than standard manufacturing processes.

3D printing is another approach to advanced manufacturing. These methods are capable of manufacturing pre-determined 3D geometric structures of solid drug products in various shapes, strengths and distributions of active and inactive ingredients. This approach provides a unique opportunity to produce medicines that are tailored for individual needs of patients.

But harnessing the potential of these innovations requires deliberate private and public investments and new policy development. We need to define how these new technologies will be regulated for their reliability and safety. And provide clear guidance on how they can be adopted by sponsors.

The FDA is taking many steps to help realize the potential of advanced manufacturing. We’ve been issuing guidance on emerging technologies and approving continuous manufacturing for several New Drug Applications. However, to drive an earnest and more efficient conversion to these often-superior platforms, it’s going to take a broader effort on the part of the Agency.

The bottom line is this: Drug makers won’t switch to these systems until we create a clear path toward their adoption, and provide more regulatory certainty that changing over to a new manufacturing system won’t be an obstacle to either new or generic drug approvals. The FDA recognizes that it’ll require additional investment in policies and programs that’ll provide regulatory clarity to enable these new methods to be more quickly and widely adopted. To achieve these goals, the President’s fiscal year 2019 budget dedicates $58 million to accelerate the development of the regulatory and scientific architecture needed to progress this technology.

diagrams of continuous and batch manufacturingMany of the technologies currently used in traditional “batch” drug manufacturing – where the ultimate finished product is made after many stops and starts in a series of steps – are decades old. This shouldn’t come as a complete surprise. Drug development is a risky endeavor. After drug makers have navigated the years of risk involved in discovering and developing a new medicine, the last thing they want to do is inject a whole bunch of uncertainty at the last step toward approval – the adoption of the manufacturing process. So most drug makers have continued to use tried and true methods, even if these conventional processes have shortcomings.

However, this customary calculus is changing.

These continuous manufacturing systems are more ideally suited to new trends in drug development, such as personalized medicine and regenerative medicine products. Drugs that target small patient populations will require much greater manufacturing flexibility. The small scale of continuous manufacturing equipment works well for these endeavors. Close and continuous manufacturing systems can provide cost-effective drug product for early stage clinical development and yet can easily ramp up production for commercialization.

While development trends and market forces have made the commercial impetus for private capital investment in these technologies clear, meaningful adoption will not occur without supporting regulatory science and a collaborative regulatory environment. To drive adoption, the FDA will need to establish clear principles for how these new platforms will be evaluated and approved. We need to invest in the regulatory science to develop policies to support these innovations. That includes, for example, the development of analytical tools for monitoring these continuous systems. While much of this scientific work will be done outside the agency (typically through public and private partnerships) the basic regulatory principles need to be defined by the FDA.

The FDA has recognized and embraced the potential for this technology for years. We established an Emerging Technology Team in 2014 that works collaboratively with companies for both new and currently marketed drugs to support the use of advanced manufacturing.

The FDA’s Center for Biologics Evaluation and Research is building on that effort. We’re advancing the application of continuous manufacturing and other cutting-edge technologies. These manufacturing approaches may be ideally suited to new biological platforms like cell and gene therapies, as well as vaccines. In some cases, these manufacturing approaches may be the key enabling technology for the safe and effective development of these new biological platforms.

Take gene therapy as one example. Many gene therapies are being developed for very small populations ranging from tens to hundreds of patients. It can be costly and slow to build traditional manufacturing platforms to support such small yields, or to switch from a small, research grade manufacturing platform to one capable of supporting bigger trials, or commercial launch. And when it comes to products like gene therapies, a lot of the uncertainty is in how these products are manufactured. So, switching between different manufacturing platforms can create risk.

Applying continuous manufacturing approaches to these products could allow for the development of a quality manufacturing process that could support the production of enough commercial grade product to conduct an initial clinical trial as small as 10 to 20 patients. This would represent one production “cassette.”  Using continuous manufacturing, the scaling of manufacturing for larger trials wouldn’t require the build out of a completely new manufacturing facility. It would just require the introduction of additional “cassettes” into the closed system. Subsequently, if the clinical trial produced definitive data on safety and efficacy, then marketing could commence with product produced by making use of additional manufacturing cassettes. This could have a transformational effect on the costs and feasibility of applying gene therapy to rare diseases.

These manufacturing technologies are not only suited to emerging technologies, but also help address old challenges, like issues with drug shortages and pharmaceutical quality.

Drug shortages are a serious public health issue. What’s not widely known is that quality issues cause the majority of drug shortages. These quality issues are often related to facility remediation efforts and product manufacturing issues. Drug shortages have consequences for patient access to critical and lifesaving drugs. They also can cause prices to rise, in some cases substantially.

Continuous manufacturing systems may be far less prone to the shortcomings that trigger many drug shortages. This technology also reduces the number of steps in the manufacturing process and centralizes all manufacturing steps in one location. Simplification and centralization, in turn, allows for issues to be identified – and remedied – more quickly. In this way, continuous manufacturing helps address the primary root causes of drug shortages. Advanced manufacturing techniques also allow for more flexible manufacturing capacity, which enables manufacturers to respond to drug shortages faster. With these systems, drug makers can more quickly adjust volumes based on product demand and therefore release product to the market more quickly.

This flexibility – and the capacity to increase production easily – could also be important for vaccines; both for seasonal flu and vaccines to combat new outbreaks.

For example, egg-based vaccine manufacturing requires about six months to meet demand, which requires the World Health Organization and public health agencies to predict the flu strand six months prior to the flu season. In contrast, advanced manufacturing has the potential to expedite the process, shortening the amount of time between when the flu strain is selected and distributed.

This can allow us to produce the vaccine closer to the flu season, when we might have more certainty about the circulating strain. It also allows us to switch the strain more easily in the event of an unforeseen change. Or to produce a new vaccine in the event of a pandemic. These approaches also enable easier scaling of manufacturing if vaccine supplies should run short.

This additional flexibility when it comes to manufacturing can also provide a critical boost for emergency preparedness products, enabling manufacturing that can be more easily scaled to quickly respond to new threats. Consider when access to a vaccine is a key strategic need; for example, a vaccine to guard against a bioterror threat. Instead of stockpiling massive volumes of the vaccine; we would instead be able to mothball a just-in-time continuous manufacturing platform. The system could then scale up production in the event of an infectious threat.

Advanced manufacturing also provides an opportunity for the U.S. to regain a leadership position in pharmaceutical manufacturing and bring more high-quality manufacturing jobs back to this country. Many of the products that would benefit from advanced manufacturing are breakthrough-designated drug products that are usually first approved and marketed in the U.S. But many are still manufactured overseas. The traditional approach to manufacturing drugs requires large facilities and a lot of manual labor. Drug makers have made a calculation that these manufacturing sites can be operated more cheaply in countries with lower labor costs.

Continuous manufacturing changes this calculus.

These advanced platforms are small footprint operations. They require a reduced complement of more highly skilled workers. It’s the sort of manufacturing where America excels.

The U.S. is the current pioneer for advanced manufacturing. Our investments in educating engineers and establishing a research base for the development of domestic facilities will ensure that we maintain our lead in the world. Many U.S. universities have already established advanced manufacturing academic programs that train on these approaches. Some are funded through grants from the FDA that were authorized in 21st Century Cures. These approaches have also been applied with success to other fields, such electronic devices and chemical industries.

Producing more drugs domestically doesn’t just mean more American jobs. It could also reduce import costs for manufacturers and increase security of our supply chain.

Continuous manufacturing technologies could save 30 percent in manufacturing costs. This estimate does not include the savings from potential future technologies. That totals $60 billion per year in savings in the United States. This can help reduce drug costs. PCAST estimates that “Continuous manufacturing may reduce manufacturing costs, which currently consume as much as 27 percent of the revenue for many pharmaceutical companies, by up to 40 to 50 percent.”

One example of promising investment in these technologies is recent efforts by General Electric to “launch prefabricated manufacturing units for producing virus-based gene and cell therapies, novel anti-cancer treatments and vaccines.” Innovations like these could make it more feasible for small, innovative biotech companies to enter the market and compete against larger pharmaceutical companies, especially for gene and cell-based cancers. This could provide a broader array of innovation, and infuse more competition into these promising therapeutic areas.

The agility of continuous manufacturing platforms should ultimately reduce costs of drug manufacturing and could provide savings to our health system. But the efficient adoption of these approaches will require a paradigm change in the regulation of manufacturing. And that will require an investment to write new principles for how the FDA oversees these tasks. This is the opportunity before the FDA, and the heart of the proposal in the President’s budget.

Scott Gottlieb, M.D., is Commissioner of the U.S. Food and Drug Administration

Follow Commissioner Gottlieb on Twitter @SGottliebFDA

Additional Resources:

“Continuous Manufacturing” -Common Guiding Principles Can Help Ensure Progress

Establishment of a Public Docket-Submission of Proposed Recommendations for Industry on Developing Continuous Manufacturing of Solid Dosage Drug Products in Pharmaceutical Manufacturing

Spotlight on CDER Science: Modernizing the Way Drugs Are Made: A Transition to Continuous Manufacturing

Emerging Technology Program

FDA Budget Matters: A Cross-Cutting Data Enterprise for Real World Evidence

By: Scott Gottlieb, M.D.

Over time, as our experience with new medical products expands, our knowledge about how best to maximize their benefits and minimize any potential risks, sharpens with each data point we gather. Every clinical use of a product produces data that can help better inform us about its safety and efficacy.

Dr. Scott GottliebThe FDA is committed to developing new tools to help us access and use data collected from all sources. This includes ways to expand our methodological repertoire to build on our understanding of medical products throughout their lifecycle, in the post market. We don’t limit our knowledge to pre-market information, traditional de novo post-market studies, and passive reporting. Newer methodologies enable us to collect data from routine medical care and develop valid scientific evidence that’s appropriate for regulatory decision making to help patients and health care providers prevent, diagnose, or treat diseases.

This includes our ability to leverage what’s often referred to as “real world data.” Real world data consists of data relating to patient health status and/or the delivery of health care routinely collected from a variety of sources, including information obtained at the point of care. By using this information, we can gain a deeper understanding of a medical product’s safety and benefits, its additional treatment implications, and its potential limitations. By better leveraging this information, we can also enable more efficient medical product development by integrating greater complements of safety and benefit information gleaned from clinical care. This is especially true when it comes to our important obligation to continue to evaluate products in the post-market setting.

Traditional randomized clinical trials can provide key information on a medical product’s performance to support regulatory marketing decisions and health care decisions made by patients and providers. However, traditional clinical trials have their own limitations. The FDA, along with others, sometimes benefit from more information than these trials can provide about how medical products are used in medical practice.

For example, traditional clinical trials have patient inclusion and exclusion criteria that often narrow the patient population that can participate in a traditional trial. So, patients who’ve undergone another treatment, or who are taking other medications, may not qualify for a certain trial that’s looking for patients who haven’t been treated for that disease or condition, or who are taking certain medications.

When this product comes to market, it’s possible that patients who pursued other treatments or patients taking medications for other conditions will be prescribed this therapy. Because these patients weren’t studied, there’ll be no clinical trial evidence available showing how these other factors may affect the safety or efficacy of this product. Clinical trials provide a picture of a medical product’s potential in a narrow and highly controlled setting. But they do not provide a complete picture as to how a product works outside of that setting. This can limit our broader understanding of how a new product will work in “the real world.”

Real World Evidence diagramThe FDA is uniquely positioned and qualified to lead the effort to expand the use of real world data to address these knowledge gaps. Over the past decade, through the FDA’s Sentinel System and the National Evaluation System for health Technology (NEST), the FDA has begun to harness formerly untapped information to help us answer some of the most pressing questions facing patients and providers about the use of medical products. This use of real world data is referred to as “real world evidence.” This is meant to express the use of real world data to generate practical clinical evidence regarding the potential benefits or risks of a product. In this case, the evidence is derived from analysis of real world data.

We’re working to promote and expand the use of both real world data and real world evidence in medical product development and regulatory science. And not only for FDA uses, but also for others that seek to answer critical questions about health care delivery. To accomplish this goal, the FDA will leverage our knowledge and skills from building and using the Sentinel System and further supporting the development of NEST. Most importantly, we must develop the means to govern the responsible use of these data and to provide timely access to a broad group of public and private entities through the creation of a national resource. All the while, we must maintain strict data security and privacy of personal information.

To these ends, as part of the President’s Fiscal Year 2019 Budget, we’ve put forward a $100M medical data enterprise proposal to build a modern system that would rely on the electronic health records from about 10 million lives. This system would expand the data enterprise that we already maintain by incorporating new information from electronic health records, and other sources that would allow us to more fully evaluate medical products in the post-market setting.

This is the next evolution in the Agency’s development of a comprehensive data enterprise to improve medical product regulation and better inform us on the safety and benefits of new innovations.

Post-Market Data Sources: Claims Data vs. EHRs

Previously, our investments in post-market data have mostly focused on the development of systems to consolidate and analyze information derived from healthcare payer claims. This was a key advance in our regulatory system. And relying on health claims information was the state of the art at the time that we built these systems. Now we have the capacity to use clinical data derived from electronic health records to develop faster reporting on the performance of medical products in real world medical settings.

Claims data provides important insights. But it also has some limitations. For example, there’s an inherent lag between when a medical event occurs, and when it’ll show up in payer claims. There’s also some ambiguity in this process. It’s not always clear, by looking at claims data alone, what actually happened to the patient and whether the medical product was a factor. So, in the current system, we need to make certain assumptions when we evaluate claims data, to draw conclusions from this information. And some of these assumptions can inject uncertainty. The FY 2019 Budget request seeks to address some of these limitations by giving the Agency the ability to access the clinical medical information contained in de-identified electronic health records.

Investments in such a system can become a national utility for improving medical care, and allowing the FDA to optimize its regulatory decisions. It would give patients and providers the access to near-real-time, post-market information that can better inform their decisions. Such an enterprise can not only support our evaluation of safety and benefit using data derived from real-world settings, but it can also make the development of new innovations more efficient. If we have more dependable, near-real-time tools for evaluating products in real-world settings, we can allow key questions to be further evaluated in the post-market setting. This can allow some of the cost of development to be shifted into the post-market, where we can sometimes access better information about how products perform in real-world settings.

Establishing a System that can Leverage All Data Sources

Real world data can come from many sources. It not only can include electronic health records, but also claims and billing activities, product and disease registries, patient-related activities in out-patient or in-home use settings, and mobile health devices. It’s key that the sources of these data elements, such as different health care systems, be able to communicate electronically. This requires full “interoperability” and the elimination of any silos. The FY 2019 Budget request seeks to establish these building blocks, and assemble the data into an interoperable platform. There are several foundational steps that we’re already undertaking to build a strong programmatic basis for using real world data and evidence.

Achieving interoperability and establishing data standards, while conceptually obvious, is by no means easy to accomplish. Different groups may collect the same information in different ways. Consider that one group collects temperature using Celsius and another uses Fahrenheit. The group that uses Celsius may document a temperature of 37 degrees, while the one that uses Fahrenheit would document a temperature of 98.6 degrees. While these both are the same finding, in the absence of data standards, they would appear drastically different. Therefore, one key to this effort is the development of data standards and agreed upon definitions that allow different groups to meaningfully share their data.

Additionally, as noted above, there are many potential sources of real world data. Our familiarity and ability to harness these data varies across these sources. For example, the Sentinel System has taken advantage of a well-established source of real world data, claims and billing data. But claims and billing data, while well established and characterized, don’t necessarily capture the full scope of actual patient treatment. When it comes to medical devices, these claims data may not include the Unique Device Identifier which can limit the utility of the information. In addition, physicians may not be recoding every treatment in claims and billing data because of payment bundles, so the exact treatment is not known.

In comparison, electronic health records capture more of the patient experience and have the potential to provide more “real-time” information. But the information is also captured in a much less standardized way. Often key information is documented in unstructured ‘free text’ as part of a provider’s note. So, standardizing this information — and assembling it into formats that can allow for easier analysis and integration — will take additional investment in systems that can consolidate this information and make it interoperable.

Part of our proposed investment will go toward building these new capabilities to assemble real world data into formats to make this information more accessible. Ultimately, our goal is that such a tool can become a national utility that can be accessed by qualified research partners to inform a host of important clinical questions.

Improving Clinical Trials

The development of such a tool can also make the entire clinical trial process much more efficient. And it can enable us to enroll more patients from more diverse backgrounds into trials.

For example, real world data can be used to more efficiently identify and recruit patients for a clinical trial. Key design considerations, such as randomization, can be integrated across clinical care settings, introducing a much more diverse population into the clinical trial system. Innovative statistical approaches — such as Bayesian and propensity scores methods — can combine information from different sources and potentially reduce the size and duration of a clinical trial while expanding the scope of healthcare questions that we’re able to evaluate. This will enable a modern clinical trial system that improves upon trials being conducted in large medical care centers. It could enable more clinical trials at smaller community-based health care providers. Such a system can expand the number of patients we’re able to evaluate, and broaden the information that we’re able to collect, while at the same time reducing the cost of developing this information. We can have more and better information, and a less costly process.

All of this is contingent upon our ability to have confidence in the quality of data we’re accessing to make decisions, be that regulatory or derived from individual patient care.  We’re working with public and private partners to ensure optimal data quality, validity, and utilization. Our goal is to develop better data standards, to promote interoperability, and improve data quality.

Investing in Tools to More Wisely Use Data to Improve Health

Data quality has different impacts when considering the use of this data for individual patient care as opposed to broader public health evaluations. However, our capacity to make effective use of real world data and real world evidence will have a profound impact on individual patients and the public health.

Investing in the creation of a national resource that leverages real world data, establishes data standards to facilitate interoperability, and promotes data quality for the integration of this evidence into medical product development and clinical care is a key national investment. It’ll improve patient care, and make the process for developing safe and effective new medical innovations more efficient. It’ll give us a near real-time tool for monitoring the post-market safety of medical products, and will help inform better and more timely regulatory decisions.

Most importantly, such a system will provide patients with better care and more informed treatment decisions. The wider use of real world data could decrease the cost of product development, while increasing our understanding of how, when, and in whom, to use medical products. It’ll allow us to use the post-market period to refine our understanding of medical products. And it’ll allow us to make reliable post-market information available to providers and patients to better inform their treatment decisions.

Scott Gottlieb, M.D., is Commissioner of the U.S. Food and Drug Administration 

Follow Commissioner Gottlieb on Twitter @SGottliebFDA

The American Chamber of Horrors

By: Vanessa Burrows, Ph.D., Suzanne Junod, Ph.D., and John Swann, Ph.D.

In the early 20th century, Americans were inundated with ineffective and dangerous drugs, as well as adulterated and deceptively packaged foods.

A cosmetic eyelash and eyebrow dye called Lash Lure, for example, which promised women that it would help them “radiate personality,” in fact contained a poison that caused ulceration of the corneas and degeneration of the eyeballs. An elixir called Banbar claimed to cure diabetes as an alternative to insulin, but actually provided no real treatment and caused harm to those patients who substituted this for effective insulin therapy. Food producers short-changed consumers by substituting cheaper ingredients. Some products labeled as peanut butter, for instance, were filled with lard and contained just a trace of peanuts, and some products marketed as “jellies” had no fruit in them at all.  Unscrupulous vendors even sold products to farmers, falsely promising they could treat sick animals – in at least one case, a product called Lee’s Gizzard Capsules killed an entire flock of turkeys instead of curing them.

Although the FDA sought to remove these unsafe and misleading products from commerce, it was severely limited in its efforts by the 1906 Pure Food and Drugs Act.  That law laid the cornerstone for the modern FDA and marked a monumental shift in the use of government powers to enhance consumer protection by requiring that foods and drugs bear truthful labeling statements and meet certain standards for purity and strength.

Over time, however, the shortcomings of the Pure Food and Drugs Act became apparent, as it failed to take into account the extraordinary changes in industries, products, markets, and advertising tactics. Dangerous drugs were a particular problem. As long as a drug met the law’s labeling requirements, the agency did not have the authority to remove even clearly dangerous products such as radium water and drugs with poisonous ingredients from the market because legal action against a drug product required a finding of fraud. If a drug’s maker could convince a court that he truly believed his own therapeutic claims, he won his case. In addition, the law provided no authority over cosmetics or medical devices, and did not specifically authorize standards for foods, which limited the agency’s ability to take action on behalf of consumers.

A popular book of the day, “100,000,000 Guinea Pigs: Dangers in Everyday Food, Drugs, and Cosmetics,” claimed that consumers were being used as guinea pigs in a giant experiment by food companies and makers of patent medicines, with the authors blaming the FDA for failing to act. But the critics failed to acknowledge the limits of the agency’s authority under the law at the time.

In an effort to inform the public about the 1906 law’s shortcomings, the FDA’s Chief Education Officer, Ruth deForest Lamb, and its Chief Inspector, George Larrick, led the creation of an influential traveling exhibit in 1933 to highlight about 100 dangerous, deceptive, or worthless products that the FDA lacked authority to remove from the market.

The exhibition was put on display at events like the 1933 World’s Fair in Chicago, at state fairs, and on Capitol Hill. It was so shocking that it was dubbed the “American Chamber of Horrors” by a reporter who accompanied First Lady Eleanor Roosevelt to view the exhibit. Lamb also adapted the exhibit into a 1936 book in which she explained, “All of these tragedies…have happened, not because Government officials are incompetent or callous, but because they have no real power to prevent them.”

The exhibit, which was viewed by millions, was an enormous success, helping promote greater awareness and understanding about the FDA’s role in protecting the public and the need for greater consumer protection and the limitations on its power to do so. To this end, it played an important role in moving Congress to enact a stronger food and drug law – the 1938 Food, Drug, and Cosmetic Act.

The 1938 law, which has been amended many times and remains the law of the land today, brought cosmetics and medical devices under the FDA’s authority, and required that drugs be labeled with adequate directions for safe use. It also mandated pre-market approval of all new drugs, such that a manufacturer would have to prove to the FDA that a drug was safe before it could be sold. And it prohibited false therapeutic claims for drugs. The Act also corrected abuses in food packaging and quality, and it mandated legally enforceable food standards. It formally authorized factory inspections, and added injunctions to the agency’s enforcement tools. In short, it gave the FDA many of the means it has today to protect the American public.

Many of the products from the original Chamber of Horrors exhibit are in the FDA’s permanent collection, and, to commemorate the 80th anniversary of the 1938 law, they are part of a special display currently on exhibit at the FDA. The objects provide a compelling visual record of how far science has brought us from the worthless and dangerous elixirs, foods, and other consumer products of the early 20th century, as well as underscoring the essential role the FDA today plays in protecting and promoting American health.

Vanessa Burrows, Ph.D., Suzanne Junod, Ph.D., and John Swann, Ph.D., are FDA Historians

FDA Budget Matters: Infrastructure to Support Robust Generic Drug Competition

By: Scott Gottlieb, M.D.

The FDA launched its Drug Competition Action Plan more than a year ago, with the aim of advancing policies that would promote robust generic drug entry as a way to foster competition and lower drug prices. Access to drugs is a matter of public health. And among the best ways to help consumers get broader access to medicines is through policies that help ensure branded drugs are subject to timely generic competition.

Dr. Scott GottliebOur work is far from finished. But the policies we’ve advanced are already showing benefits toward these goals. The benefits we’ve seen reinforce the fact that policy can be used as a vehicle to advance these purposes.

New resources have also helped advance our work. Owing in large measure to the FDA’s implementation of the Generic Drug User Fee Amendments of 2012 (GDUFA), which funded critical enhancements to FDA’s generic drugs program, our staff eliminated the backlog of generic drug applications. In 2017, we also approved the largest number of generic drugs in the FDA’s history.

As part of GDUFA, as well as through our own new efforts, the FDA also has put policies in place to promote generic drug development in areas where there’s inadequate competition. This includes a focus on developing new guidance aimed at promoting development of generic versions of complex drugs. These are drugs that are often harder to copy. By advancing clear, objective, science-based guidance for developing generic copies of complex drugs, we hope to foster more competition.

And the FDA also has improved the efficiency and predictability of the generic drug review process to help promote more robust generic drug competition. For example, we’re prioritizing the review of generic drug applications for which there are no blocking patents or exclusivities. The aim is to promote competition so that there are at least four approved applications for each product (including the brand drug). Our data shows that there are significant price decreases once there are at least three generic drugs on the market. Our new policy will help ensure that there is robust competition across the market that will drive down drug costs to consumers.

In addition, we’re taking other new steps to curtail various forms of “gaming” by brand companies, where some sponsors sometimes adopt tactics that seek to delay entry of generic competition.

But we know that we need to do even more to promote access and competition. And so we’ve put forward a broader plan, as part of the President’s Budget, to achieve these aims.

Toward these goals, the President’s fiscal year 2019 Budget Request included $37.6 million to fund two initiatives that will help modernize aspects of our generic drug review process.

The first initiative will create a new review platform — the Knowledge-aided Assessment & Structured Application (KASA) platform — to modernize generic drug review from a text-based to a data-based assessment. The KASA will enable a structured review that will make the application review process more efficient, and allow deficiencies to be spotted earlier. This will allow the FDA to provide earlier feedback to generic drug makers that will, in turn, help to reduce multiple cycles of application review, one of our key aims and a primary focus of our overall efforts to speed market access to new generic medicines. Going through multiple review cycles is one of the primary reasons why the approval of generic drug applications is sometimes delayed many years. The new KASA system will help sponsors submit high-quality and more complete applications on the first submission. It will decrease the risk that applications will be refused for receipt and reduce the number of review cycles that applications undergo.

We anticipate that the new platform will allow more generic applications to be approved after the first cycle. This will promote timely generic entry and increase overall competition.

The new platform will also enable more efficient and robust knowledge management across different aspects of the FDA’s review process, helping reviewers capture and manage all of the information about products allowing for more seamless and effective product surveillance based upon quality and risk. This system will benefit both the agency and generic drug sponsors by increasing overall speed and efficiency of the pre- and post-market processes.

Having a structured template that completely replaces the current largely narrative-based review will allow for more consistent and predictable entry and analysis of data. Current assessments require manual review of the entire application. KASA will enable automated analysis of some portions of the application, which will save time, and ensure consistency.

The second initiative is aimed at promoting the more widespread use of existing generic drugs by looking for ways to keep generic drug labeling up-to-date with the latest information about each medicine’s risks and benefits. Generic drugs are generally required to have the same labeling as the brand drug they reference. And the burden to update the labeling with new safety and effectiveness information is typically born by the brand company.

However, when brand reference drug companies voluntarily withdraw their marketing applications, they also stop updating their labeling. When this happens, the FDA loses a key mechanism that the agency relies on as a way to update generic labeling. This can stymie the ability to modernize generic labels. In turn, when labels become out-of-date, providers may not have complete information about the full range of benefits and risks of the product. This can serve to diminish the use of these lower cost alternatives.

Consistent with our current authorities, which allow for certain types of labeling changes to continue to be made for generic drugs after the brand drug is withdrawn, this budget request will provide the funding to allow the FDA to assume more responsibility to help bring these drug labels up to date. We intend to launch this initiative initially for oncology products.

Our goal is to help ensure that doctors and patients have up-to-date information for these products. This will better inform clinical decisions regarding these medicines, and help promote more widespread use of low-cost, generic alternatives. By ensuring generic product labels are up to date, we’ll promote wider and more clinically optimal use of these drugs, which can save patients money.

We appreciate that the appropriations committees of both chambers of Congress supported this budget request in their appropriations bills. Congress has long recognized the need for — and importance of – investments in our generic drug program and efforts to promote generic drug use. The benefits of these initiatives are significant to the FDA’s modernization and efficiency. They’ll help advance a robust generic drug market that drives product competition and lowers drug prices.

Scott Gottlieb, M.D., is Commissioner of the U.S. Food and Drug Administration 

Follow Commissioner Gottlieb on Twitter @SGottliebFDA

Report Spotlights Achievements of FDA-Mexico Produce Safety Partnership

En Español

By: Stephen M. Ostroff, M.D.

The United States and Mexico are major trading partners in fresh produce. Each year, billions of dollars of fruits and vegetables move across the border. These include Mexican tomatoes, avocados, chilies, berries, cucumbers, lemons, and limes that reach U.S. consumers, as well as American apples, pears, grapes, onions, strawberries, potatoes, peaches and other produce that are sent to Mexico.

Stephen Ostroff, M.D.Both our countries benefit when we can help to ensure that these valuable commodities are safe for consumers on both sides of our borders. For that reason, the FDA-Mexico Produce Safety Partnership (PSP) was formed in July 2014, forging a stronger relationship between the FDA and Mexico’s National Agro-Alimentary Health, Safety, and Quality Service (SENASICA) and its Federal Commission for the Protection from Sanitary Risk (COFEPRIS).

We are pleased to share that our partnership is making real progress toward our goal of reducing the risk of foodborne illness associated with our produce trade. A new report, titled U.S. FDA-Mexico Produce Safety Partnership: A Dynamic Partnership in Action, provides some specific examples of this progress.

For example, the partnership recently worked to address the contamination of papayas grown in Mexico. In the fall of 2017, the FDA, SENASICA and COFEPRIS worked together to respond to four outbreaks of salmonellosis tied to Mexican-grown papayas. The Mexican agencies conducted inspections and sampled various farms and packing houses in several Mexican states, and shared their findings with the FDA. We were able to leverage their work and resources, along with the findings of our own outbreak investigation, to place four farms on import alert, thus providing information to the FDA inspectors who detained those products without having to physically examine them. SENASICA likewise implemented a regulatory response. In October 2017, Mexico strengthened its food safety oversight of papayas, which are subject to the Produce Safety Rule under the FDA Food Safety Modernization Act if they will be imported or offered for import in the U.S.

Chart - Mexico Exports of Fresh Produce to USAIn another example, in 2015, Listeria monocytogenes was detected in kiwi and apples grown in the U.S. and exported to Mexico. The exchange of information under the PSP, including the sharing of bacterial isolates and testing by both FDA and SENASICA laboratories, helped prevent more contaminated produce from entering Mexico. It also established a protocol for the future exchange of bacterial strains to improve detection and understanding of contamination.

These are just two of several instances in which the partnership has led to coordinated preventive activities in addition to enforcement activities that help to reduce the risk of foodborne illnesses and enable both countries to respond more rapidly to a potential or actual outbreak, better protecting both American and Mexican consumers.

Chart - U.S. Exports of Fresh Produce to MexicoBut the partnership has also provided benefits beyond individual outbreaks. Both countries have also been working collaboratively through working groups on institutionalizing approaches that reinforce preventive practices and rapid response to outbreaks. The groups have focused on information sharing, education and outreach, training, laboratory methods and processes, and how to respond effectively to outbreaks.

Looking to the future, the report outlines our five-year plan to increase engagement and the exchange of knowledge with key public and private partners. Through the partnership, we plan to also work on identifying common approaches for auditors and inspectors to better execute compliance and enforcement activities, and will create a strategy to conduct joint inspections and sampling. This will help both countries maximize their resources for the benefit of consumers on both sides of the border.

This is a long-term partnership. While there are differences in our systems, technologies, and environments, the U.S. and Mexico both want consumers to be confident in the safety of their food. By working together, we can achieve that goal.

Stephen M. Ostroff, M.D., is FDA’s Deputy Commissioner for Foods and Veterinary Medicine.

FDA’s New Efforts to Advance Biotechnology Innovation

By: Scott Gottlieb, M.D., and Anna Abram

Scientific advances in biotechnology, such as genome editing and synthetic biology, hold enormous potential to improve human and animal health, animal welfare, and food security. And researchers and companies based in the United States helped pioneer these technologies. They position the U.S. as a global leader of this rapidly growing and highly promising field.

Dr. Scott Gottlieb

Scott Gottlieb, M.D., Commissioner of the U.S. Food and Drug Administration

To advance this progress, it’s key that the FDA adopt a regulatory approach to these technologies that’s as innovative and nimble as the opportunities that we’re tasked with evaluating.

FDA is committed to helping ensure the safety of biotechnology products, while also facilitating innovation by applying a risk-based regulatory approach that provides developers with regulatory clarity and predictability and maintains public confidence in our regulatory system.

And we’re taking some new steps to advance these goals. We know that products enabled by new techniques of biotechnology have the potential to significantly enhance public health.

For instance, these new methods can be used to alter animals to minimize or prevent their ability to spread human disease. Genome editing in animals and plants also can be used to produce human drugs, devices, or biologics, including tissues or organs for xenotransplantation. Scientists are also exploring editing the genomes of animals with the goal of improving the health and welfare of food producing animals and public health, for example by reducing their susceptibility to diseases like novel influenzas and resistance to zoonotic or foreign animal diseases.

Similar and equally beneficial applications of genome editing are currently being explored in food crops. These include our ability to develop disease-resistant plants and plants with increased resistance to environmental stress. Such advances can have many advantages to consumers, including better yields, more product variety, and healthier nutrient profiles.

Anna Abram

Anna Abram, FDA’s Deputy Commissioner for Policy, Planning, Legislation, and Analysis

We believe the FDA is uniquely positioned — with the expertise, experience, credibility and trusted scientific framework — to advance innovation and support the development of products with immense potential for public benefit. And we’re fully committed to these goals.

The breadth of FDA’s statutory authorities and regulatory framework allows us to comprehensively review the potential impacts of products on both human and animal health. For example, for genetically engineered animals, FDA evaluates not only the safety of food or drug products derived from that animal, but also the effect of the genetic alteration on the health of the animal. FDA has decades of experience successfully evaluating products of complex technologies, such as recombinant DNA-derived plant foods, medicines made with nanotechnology, and cellular and gene therapy products.

Moreover, because of the wide spectrum of products that we regulate, and the in-depth scientific and policy engagement that the agency has with innovators and counterpart regulatory agencies around the world, FDA can help facilitate the progression of research and development. For example, we’re focused on the timely transition of technologies from animal research models to products intended for use in humans. As our knowledge of genome editing applications increases over different product areas, we expect to build on those even greater synergies and increase our understanding to help with assessments of risks to human and animal health.

FDA will continue to apply a risk-based framework grounded in sound science to evaluate products of plant and animal biotechnology, and our framework will continue to evolve as science advances and experience with these technologies grows. We also look forward to working with stakeholders to help understand current scientific information and describe challenges and gaps in regulatory science that are important for our regulatory decision-making. We’re also going to take new steps to help developers understand their responsibility to ensure product safety and we’ll identify ways to help reduce unnecessary regulatory burden and undue barriers to bring potential beneficial products to commercialization while ensuring their safety.

Protecting and promoting public health is our mission and we’re taking steps to help ensure the safety (and as applicable, effectiveness) of products that can benefit patients and consumers, while supporting innovation and sustaining public confidence.

To help advance these goals, in early May, FDA formed a new Biotech Working Group. This Working Group is comprised of representatives from multiple FDA centers and offices. In the coming months, we’ll release an Action Plan that lays out the steps we intend to take to ensure that we have a flexible regulatory framework for evaluating the safety of products that also supports plant and animal biotechnology innovation.

Our actions will focus on three key areas:

First, advancing and protecting public and animal health by promoting innovation through an efficient and predictable science- and risk-based regulatory framework; second, strengthening public outreach and communication through strong, effective and transparent engagement with stakeholders; and third, increasing engagement with domestic and international partners through coordinated and collaborative actions to support regulatory alignment and efficiency.

The Working Group’s efforts are well underway and we’ll be providing more details soon.

Finally, we’ll continue the work we began to modernize the regulatory system for biotechnology, including the effort in 2015 with USDA and EPA to ensure preparedness of federal regulatory agencies for future products of biotechnology; as well as the implementation of the 2018 recommendations of the Interagency Task Force on Agriculture and Rural Prosperity. We’ll also continue to build on our Formal Agreement with the USDA, which commits the FDA and USDA to better align and enhance our efforts to develop regulatory approaches to biotechnology.

We’re committed to all of these goals, and we look forward to working with the Interagency Task Force and sharing more of our important work with our stakeholders going forward.

FDA is taking concrete and proactive steps to help ensure the safety of plant and animal biotechnology products, while promoting innovation and enhancing public and market confidence in FDA’s regulation of these products at home and abroad. We recognize the tremendous opportunities offered by this new technology. We’re committed to developing a framework that allows these innovations to safely advance, to fulfill the potential envisioned by those who are pioneering these approaches, and to inspire public confidence in these methods.

The advance of these technologies holds significant public health promise. Unlocking their full potential and competitiveness depends on the trust we build now and in the years to come.

Scott Gottlieb, M.D., is Commissioner of the U.S. Food and Drug Administration 

Anna Abram is FDA’s Deputy Commissioner for Policy, Planning, Legislation, and Analysis

Follow Commissioner Gottlieb on Twitter @SGottliebFDA

FDA Proposes Process Modernization to Support New Drug Development

By: Janet Woodcock, M.D.

The staff of the FDA’s Center for Drug Evaluation and Research (CDER) always tries to utilize cutting-edge science and up-to-date process management, befitting our stature as the global “gold standard” in drug regulation. Maintaining that standard requires us to keep up with evolving technology and the latest scientific, medical and regulatory advances. Current factors impacting drug development include the genomic revolution, the rise of targeted therapy, the availability of digital health data, the focus on patient involvement, complex drug-device combinations, globalization of drug development and harmonization of international standards. To be successful drug regulators, we reach well beyond the borders of the FDA. We collaborate with a wide variety of medical and scientific organizations such as those in biomedical research, the pharmaceutical industry, academia, global organizations and other regulatory agencies. Importantly, these collaborations also extend to patients and their caregivers and advocacy groups. All these interactions are critical to successful drug regulation.

Janet Woodcock

Janet Woodcock, M.D., Director of the FDA’s Center for Drug Evaluation and Research

I have recently proposed changes to CDER’s new drug regulatory program. These changes are intended to free up resources so that our scientists and physicians have more time to focus on drug development, particularly for unmet medical needs, and on the multiple collaborations needed to make sure candidate drugs are developed and assessed properly, with appropriate input from external scientists, expert physicians and patient communities. The proposals include regulatory and review process changes, as well as organizational restructuring. We also intend to strengthen the support structures, including personnel and Information Technology (IT), that underpin the regulatory process.

As always, our goals are to expand access to safe and effective new drug therapies, conduct efficient and comprehensive safety surveillance, and ensure that accurate information about those drugs is available.

Here are some highlights of our proposal:

  • Recruiting the best and brightest individuals from many disciplines – Scientific leadership is vital for our ongoing success. After hiring talented scientists, we need to develop long-term career paths for them so they can become our next generation of seasoned leaders. Our recruitment efforts, strengthened by hiring incentives and other provisions in a new law called the 21st Century Cures Act, will help provide the staffing necessary for continued success in supporting the development and approval of innovative new therapies that meet previously unmet medical needs.
  • Enhancing our focus on multidisciplinary teams – Setting standards for approval and assessing innovative new drugs requires large and well-coordinated teams of highly trained professionals with many different types of expertise. CDER’s Office of New Drugs (OND) has a staff of more than 1,000 individuals who work together in many ways. New drug development and approval also requires coordination across many offices within CDER, including the Office of Translational Sciences (OTS), the Office of Surveillance and Epidemiology (OSE) and the Office of Pharmaceutical Quality (OPQ). A central component of our proposed changes involves stronger integration of our talented staff so they can better work together – within and across offices, a concept we refer to as “integrated assessment.” Previously, CDER reviewers would seek consults from specialists in other scientific disciplines (as issues were identified in the course of review). For greater collaboration, a cross-disciplinary team will be assigned to work on a new drug application at the outset.
  • Prioritizing operational excellence – Staff throughout CDER face a staggering pace of work, much of which involves attention to detailed administrative procedures. Our proposal would centralize project management functions within OND. CDER currently has 19 separate review divisions that regulate drugs. Over time, many divisions have developed procedures specific to their areas of review. We are proposing a single and consistent process: One organization with one process. Our aim is to enable our scientific and clinical experts to focus on what they know best – science and medicine – and our regulatory experts to manage the many processes we conduct.
  • Improving knowledge management – The information we process in our work is vast and diverse. Knowledge management is essential to control the data we receive from outside sources as well as what we generate from within the FDA. We plan to enhance our IT capabilities and access to information to better enable the storage and management of the collected experience of our scientific review staff. Accurate historic information from many past drug reviews is essential to informing current and future reviews – and to assure consistent regulatory decision-making. We want to make it easy for staff to find and use scientific and regulatory data, information and precedents. We’re also proposing changes that will increase the number of offices that oversee our review divisions from five to nine – and we’re envisioning 30 review divisions within those offices – up from our current 19. In addition to enabling greater efficiency, these envisioned changes will help us to better understand the diseases intended to be treated by the drugs we evaluate for approval – another way we aim to enhance our knowledge management.
  • Emphasizing the importance of safety across a drug’s lifecycle – Safety remains a key component of our new plans. We will work to establish a unified post-market safety surveillance framework to monitor the benefits and risks of drugs across their lifecycles, both before and after approval.
  •  Incorporating the patient voice – Patients are the FDA’s most important stakeholder and our vision includes incorporating the patient voice in modern patient-focused drug development. In fact, all the elements in our proposal have a common thread: they ultimately serve to improve health for patients.

Last year, CDER approved 46 novel drugs, 100% of which were reviewed on time – fulfilling our commitments under the Prescription Drug User Fee Act (PDUFA). Our system is effective, but we can always improve. Our new plan is designed to help us generate efficiencies so we can build stronger external collaboration capabilities and enhanced support for the scientific, clinical and technological innovation necessary for new drug therapies.

This proposal to modernize our new drug review processes will help us maintain and advance our global leadership, and better support our deeply committed staff. Both science and technology are changing at a blistering pace, and we need to keep up. Patients depend on the FDA to do what is necessary to provide access to safe and effective drug therapies. They take FDA-approved drugs because they trust us. While we have many steps to go before we can realize these changes, we feel confident that they will reinforce that trust and align us for ongoing success.

Janet Woodcock, M.D., is Director of the FDA’s Center for Drug Evaluation and Research

Statement from FDA Commissioner Scott Gottlieb, M.D., on proposed modernization of FDA’s drug review office

 

 

FDA Update on Traceback Related to the E. coli O157:H7 Outbreak Linked to Romaine Lettuce

By: Scott Gottlieb, M.D., and Stephen Ostroff, M.D.

The FDA continues to investigate the outbreak of E. coli O157:H7 infections associated with romaine lettuce from the Yuma growing region. Any contaminated product from the Yuma growing region has already worked its way through the food supply and is no longer available for consumption. So any immediate risk is gone. However, the FDA is committed to investigating the source of the outbreak and working with industry to help prevent similar events in the future.

Dr. Scott Gottlieb

Scott Gottlieb, M.D., Commissioner of the U.S. Food and Drug Administration

This is a serious and tragic outbreak. And we’re devoting considerable effort to identifying the primary source. We’ve made progress in recent weeks toward this goal. This outbreak of E. coli O157:H7 illnesses is the largest in the United States in more than 10 years. As of today, it has affected 172 persons in 32 states, and it is anticipated the numbers will be updated on Friday. Tragically, 45 percent of these ill people have been hospitalized, and one has died. And 20 of these people have developed hemolytic uremic syndrome (HUS), one of the most serious complications that can occur with E. coli O157:H7 infection.

These statistics reflect the severity of this particular foodborne illness. The kidney damage that’s associated with HUS can require temporary dialysis and the kidneys may never fully recover. For these reasons, anytime outbreaks caused by this pathogen occur, we need to find the root cause of the contamination and determine what went wrong. We need to relay these findings to industry so that measures can be put in place to prevent it from happening again.

The FDA’s investigators are actively searching for answers as to the source of this outbreak, and what steps can be taken to prevent it from recurring in future growing seasons. In the current outbreak, illness has generally been linked to the consumption of chopped romaine lettuce. The lettuce was generally consumed at restaurants or purchased at markets. In one cluster of illnesses at an Alaska correctional facility, the prison received and served whole head romaine lettuce rather than chopped and bagged romaine.

The FDA and our state partners have been involved in extensive traceback efforts of the romaine lettuce that was likely consumed by those who became ill. Traceback involves working backwards from the point of consumption or purchase of the product through the supply chain. It often includes investigating the multiple steps along the way. These steps can include suppliers, distributors and processors where the lettuce was chopped and bagged, and then back to the farm or farms that could have grown the lettuce that ended up in those bags. It’s a labor-intensive task. It requires collecting and evaluating thousands of records; and trying to accurately reproduce how the contaminated lettuce moved through the food supply chain to grocery stores, restaurants and other locations where it was sold or served to the consumers who became ill.

Stephen Ostroff, M.D.

Stephen Ostroff, M.D., FDA’s Deputy Commissioner for Foods and Veterinary Medicine

Our traceback efforts are designed to find points of convergence from several well identified clusters of illness with a common point of exposure, such as a restaurant or grocery store. This means that as we draw lines for each cluster from one point in the supply chain to another point, we look for places where the lines will intersect and lead back to a common location. This can then help clarify where the contamination may have taken place.

We usually do this for clusters of ill individuals that occurred in different parts of the country; since lettuce in one part of the country may not follow the same pathway as lettuce in another part of the country. When that point of convergence is identified, efforts can then focus on how the contamination occurred at that location.

We’ve conducted traceback activities for many of the illnesses identified in this outbreak. We’ve used this information to create a traceback diagram that we’re releasing today. The diagram does not include tracebacks for all 172 cases. Rather, it focuses on settings where there were several well-documented clusters of cases. As additional traceback information is received, we anticipate the diagram will be updated.

As can be seen in the diagram, in the current outbreak, and based on the information we have to date, there are still no obvious points of convergence along the supply chain. There is only one straight line back to a single farm. And that particular instance involves the whole head lettuce served in the Alaska correctional facility, since it was not processed and was not mixed with lettuce from multiple farms, as seen in other parts of the traceback.

In these other tracebacks in the diagram, there are different suppliers, distributors and/or processors. These pathways lead back to different farms, sometimes many farms, where possibly contaminated lettuce could have been harvested during the timeframe of interest. The only point of commonality in our traceback efforts to date is that all of the farms are located in the Yuma growing region. This region is where a large portion of the romaine lettuce supply in the United States comes from during the winter months.

What does this traceback diagram tell us?

It says that there isn’t a simple or obvious explanation for how this outbreak occurred within the supply chain. If the explanation was as simple as a single farm, or a single processor or distributor, we would have already figured that out. The traceback diagram does show us that the contamination with E. coli O157:H7 was unlikely to have happened near the end of the supply chain (such as at a distributor) because there are no common distributors among the places that received and sold or served contaminated lettuce. The contamination likely happened at, or close to, the Yuma growing area.

Our task now is to investigate what happened. We are actively evaluating a number of theories about how romaine lettuce grown on multiple farms in the same growing region could have become contaminated around the same time. It’s possible that contamination occurred on multiple farms at once, through some sort of environmental contamination (e.g., irrigation water, air/dust, water used for pesticide application, animal encroachment). Another possibility is that it happened just after the lettuce left the farm. We are examining all possibilities and as we investigate we learn more about a potential common source we will communicate this information with growers and consumers. But the source and mode of contamination may remain difficult to identify.

Our efforts are complicated by the fact that romaine lettuce is a perishable commodity with a short shelf life of a couple of weeks. None of the lettuce that likely made people sick was available for testing because of the time between the incubation period of E. coli O157:H7 (the time between exposure to the lettuce and the onset of illness) and the time it takes to seek health care and collect specimens from ill people, test those specimens, report the illnesses to public health officials, fingerprint the pathogen to make sure it is part of the outbreak, and interview the ill people to identify where and when they were exposed.  By that time, the lettuce they ate which could have made them ill is long gone.

Similarly, the lettuce growing and harvesting season in the Yuma growing region was essentially over by the time the outbreak was recognized in April, and harvesting has since ceased. That is why we, and our colleagues at the Centers for Disease Control and Prevention, have said that there’s no longer any romaine lettuce from the Yuma growing region available for purchase or consumption.

Romaine lettuce production in this area is now idle until later in the year. This makes it difficult to find places where the E. coli O157:H7 organism that caused the outbreak may have been hiding.

We have no evidence that romaine lettuce from other growing regions have been a part of this outbreak.

The FDA is looking at all possibilities for how the contamination may have caused such a large outbreak. This work will continue. In these efforts, we’re collaborating with outside experts who may have insights, ideas, or suggestions. This includes working with farmers, technical experts, the lettuce processing industry, state partners, and others. It also includes on-site assessments. Through such assessments we may be able to find a possible explanation so that steps can be taken to prevent this problem from recurring.

We’re committed to these efforts, and finding the root cause of this outbreak.

Romaine lettuce is one of the most popular types of lettuce in this country. We want American consumers to be confident in the quality and safety of the lettuce they consume. In addition to working to identify the source and mode of contamination, we will also continue working after the outbreak to evaluate what happened and how lessons learned can be used to provide feedback to industry on best practices and areas to work on. These include better tools to more efficiently and swiftly traceback commodities like lettuce through the supply chain, and better ways to standardize record keeping. We also want to explore the use of additional tools on product packaging that could improve traceability. For example, could QR codes be used to provide additional information that could help consumers more easily identify which lettuce should be avoided and which lettuce is ok to eat?

We’re also working with the leafy greens industry and technical experts to explore methods to grow and process lettuce in ways that further reduce the risk of outbreaks. We live in an era of unprecedented innovation and technology, and we want to bring more of that innovation and technology to bear to help solve this problem and ensure consumer confidence in healthy fruits and vegetables.

Food safety is one of the highest priorities at the FDA. This outbreak is a clear illustration of why that’s the case. It shows the terrible consequences when something goes wrong.

This outbreak marks the importance of moving forward with the Food Safety Modernization Act’s Produce Safety Rule. That rule is designed to implement practical measures to prevent contamination of fruits and vegetables at the farm. This rule is being implemented in close collaboration with our state partners and with our federal partners at the U.S. Department of Agriculture.

State partners will do the vast majority of routine inspections under the Produce Safety Rule. They are often the most familiar with their farming communities and growing and harvest practices. These inspections are slated to begin next year. We’re currently in the process of finalizing the guidance and training farmers throughout the country and those who ship produce to the U.S. on the rule’s requirements.

We believe that the measures outlined by the Produce Safety Rule, when fully implemented, will reduce the chance of an outbreak similar to the one we just experienced. That’s our goal, and our commitment, to the American public.

Scott Gottlieb, M.D., is Commissioner of the U.S. Food and Drug Administration

Stephen Ostroff, M.D., is FDA’s Deputy Commissioner for Foods and Veterinary Medicine

Follow Commissioner Gottlieb on Twitter @SGottliebFDA

The FDA Issues Draft Guidance About the Absorption of Active Ingredients Being Considered for Inclusion in Over-the-Counter Drug Products Applied to the Skin and Marketed without Approved Applications

By: Theresa M. Michele, M.D.

All drugs have some risk — even over-the-counter (OTC) drugs available without a prescription — and the FDA is always taking steps to help ensure their safety. When you take a pill, you generally expect that some of the active ingredient gets into your body, but what about when you apply a topical product to the skin? How much of the product gets absorbed through the skin and enters the bloodstream, and is it safe? At the FDA, we’ve been working to better understand the absorption and safety profile of topical OTC products such as sunscreens and topical antiseptics. We are particularly interested in learning how these products affect vulnerable populations such as children, the elderly, and pregnant and breastfeeding women.

Theresa Michele, M.D.Until recently, there was little data available to demonstrate the extent to which topical OTC drugs are absorbed into the bloodstream after application, and whether there are any long-term consequences of this. In fact, many topical OTC products were first marketed when these products were thought not to be absorbed through the skin and when there were no effective methods available to measure absorption. Now, better measurement tools are available, and research indicates that topical drugs can indeed be absorbed into the body through the skin.

Consequently, the FDA has been generally encouraging manufacturers to collect data on the potential risks of a topical drug when used according to the maximum limits of the product’s instructions, what we call Maximal Usage Trials or MUsT studies. Most recently we included MUsT studies among the list of safety and efficacy studies recommended for sunscreen active ingredients being evaluated under a new marketing pathway established by the Sunscreen Innovation Act in a final guidance for industry in November 2016. Now we are issuing draft guidance that, when finalized, will provide recommendations to industry on how to design and conduct MUsT studies for topical active ingredients that are under consideration for inclusion in an OTC monograph.

The draft guidance includes discussions about how to study the topical active ingredient’s effects on specific subgroups of vulnerable patients like children and the elderly. The studies require a relatively small sample of patients for a short period of time and should not be overly burdensome. In fact, this draft guidance reflects the same safety and efficacy standards that have applied to all drug products marketed under the OTC Monograph System for more than 40 years.

Absorption studies have contributed significantly to the FDA’s knowledge of the safety of topical prescription products. Applying a similar level of safety research to active ingredients being considered for inclusion in an OTC monograph to that which currently exists for prescription products can help the FDA determine whether these ingredients should be included in OTC products marketed without approved applications.

Theresa M. Michele, M.D., is the Director of the Division of Nonprescription Drug Products, Office of New Drugs, at the FDA’s Center for Drug Evaluation and Research