Regulatory science: a special update from the United States Food and Drug Administration: Preclinical issues and status of investigation of botanical drug products in the United States
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文摘
A recent survey was conducted across the therapeutic divisions within the CDER, U.S. FDA regarding the number of submissions related to botanical drug products over the past ten years. The overall number of botanical submissions as expressed in the parenthesis are as follows: 1990 (1), 1991 (4), 1992 (4), 1993 (5), 1994 (6), 1995 (5), 1996 (13), 1997 (16), 1998 (10). In the total of 64 counted, 50 of them are submitted in original IND and the rest (14) in pre-IND format. The therapeutic categories are focused on dermatological and topical (19), anti AIDS/antiviral (12), oncologic (13), neuropharmacologic (8), endocrine and metabolic (3), urologic (2), tobacco (2), and cardio–renal products (1). The regulatory actions taken on these submissions showed that 68 % of them are evaluated as safe to proceed for the human trials, while the rest (32 % ) of submissions required agency’s regulatory guidance. Among the submissions that required further guidance, 81 % were deficient in preclinical pharmacology/toxicology information and the rest (19 % ) lacks information in other areas (chemistry, clinical protocols). Following agency’s guidance, 93 % of the submissions that were put on hold were allowed to proceed. In summary, a total of 94 % of all the botanical INDs submitted to the agency were allowed to proceed without additional animal toxicity studies conducted. In conclusion, this survey indicates that the growing public interest in botanical supplements has prompted more formal evaluation of the efficacy/safety claims of these products.