FDA Draft Guidance on Safety Assessment Committees | Page 2

INTRODUCTION Because the safety of a drug is of paramount importance to public health, the systematic identification and evaluation of unanticipated adverse reactions, trends and safety signals is needed for timely and appropriate action. As a best practice, most sponsors have already established a form of safety assessment or a method by which to monitor adverse events and safety signals. The challenge with analyzing signals and trends for most companies is the ability to make decisions based on an imperfectly understood problem, often using incomplete information. The FDA has recognized the importance of the identification, analysis and monitoring of safety signals and has initiated discussions via a recently issued draft guidance to recommend ways to formalize the safety assessment of clinical trials. Here, we discuss this recent FDA draft guidance for safety assessment, the definition and purpose of a Safety Assessment Committee (SAC) and examples of SAC activities related to safety signals, supported by an integrated technology platform. Recent FDA Guidance The importance of detecting, reporting and acting upon safety issues in clinical trials has long been recognized, and the FDA has recommended risk assessment throughout a product’s lifecycle: early identification of a potential product, through the premarketing development process and after approval. 2 However, the recommendations for reporting unanticipated adverse reactions or increases in adverse events and reactions are becoming more formalized. In December 2015, the FDA issued a draft guidance for safety assessments to support safety reporting for an investigational new drug application (IND). Since this is a draft guidance, FDA has invited review and comment from the public.2 According to this guidance, the systematic approach to safety surveillance should include the following: Œ USING THE ENTIRE CLINICAL TRIAL DATABASE, THE SPONSOR SHOULD REVIEW, EVALUATE AND MANAGE SERIOUS ADVERSE EVENT (SAE) DATA AS IT ACCUMULATES.  USING UNBLINDED DATA, COMPARE THE RATES OF EVENTS ACROSS TREATMENT GROUPS TO DETECT: a. Increased rates of serious and unexpected suspected adverse reactions (SUSARs). b. A clinically important increase in the rates of known SAEs Ž PROACTIVELY IDENTIFY ANTICIPATED SAES. To achieve these goals, the guidance recommends that sponsors create a safety surveillance plan and SAC.