FDA Matters is always impressed by how much FDA does. The everyday tasks are overwhelming: reviewing, approving, monitoring and inspecting the products and facilities responsible for 80% of our food supply and 100% of drugs, biologics, medical devices, vaccines, and animal drugs. Then there are the policy issues, big and small, that must be tended to.
These are largely functional tasks—someone has a job (or several) and does them. Yet, FDA has another life, as the bridge to the future of foods, drugs and devices. This responsibility is vitally important to our nation. It also takes time to bear fruit.
FDA is determined to help develop the fields of personalized medicine, nanotechnology, biomarkers, population-based adverse event tracking, safe use of genetically-modified foods, and regulatory science. By statutory directive, the agency is also helping to develop the fields of generic biologics (formerly bio-similars), medical countermeasures against bio-terrorist threats, and antibiotics for emerging infectious diseases. Advocates usually offer these activities as the rationale for strengthening science at the agency.
There is something more that connects these initiatives–the role of FDA in accelerating public benefits from the increasingly complex science generated by medical and food product companies, academia and federal agencies. There is understandable impatience from stakeholders. While there is a resource issue (more people working on these issues equals faster progress), there is also a rate-limiting aspect–procedural and scientific–to success.
Some have wondered (including me) as to why FDA did not appear more ready to take on generic biologics when the new legislation passed….or why the agency’s subsequent action have exhibited more energy than urgency.
One reason is that FDA has unveiled new complexities of interpretation and implementation each time it has moved forward on generic biologics. Since this is, arguably, the first new approval pathway for medical products in 20 years, perhaps we should all take a deep breath…and acknowledge that a viable program (with regulations, guidances, scientific support and usable precedents) might take four to six years or more to implement. The field itself will be developing for years to come.
Patience is also needed for personalized medicine, biomarkers, antibiotics, etc. At a minimum, we know that clinical trials often fail, sometimes quite miserably, just when everyone is surest that the solution is logical, success is guaranteed and progress is certain. The human body is almost always more complex and subtle than we can discern, even with the best tools.
My yardstick is the history of biotechnology. As with all great transformative achievements, latecomers might imagine that success was inevitable and progress was smooth and relatively trouble-free. The reality has been quite different:
· A rocky childhood, including efforts to restrict or ban experiments (1970′s)
· The “next big thing,” with a very limited number of successes (1980′s)
· Finally a significant impact, but also several “near death” experiences (1990′s)
· Some biotechs mature and big pharma swallows small biotechs for their knowledge, capacity and pipeline (2000′s)
There was almost 20 years between childhood and impact…and about the same amount of time between initial successes and a track record of success. Nearly forty years later, biotechnology is still as much about promise as it is about accomplishments.
So, forget the hype and re-calibrate your expectation about how fast the future will arrive. FDA is fully committed and only needs sufficient resources to hasten that day. Just as importantly, don’t lessen your own (or your organization’s) commitment to the future. Despite frustrations with the seemingly slow pace of change, the benefits to patients and other stakeholders will come in due time.
Steven
Some related columns:
FDA: An Honest Broker on the Slow Path to Biosimilars
October 24th, 2010
FDA Matters’ enthusiasm for biosimilars is a matter of public record. The market will build slowly, but 10 years from now the new law will be seen as ushering in a new age of biopharmaceutical product development. FDA will be satisfied (and successful) if the new law stimulates biosimilars, bio-betters, and innovative new biological products, along with a dramatic increase in knowledge about the nature and characterization of biologic products. Read the rest of this entry
Long-term Challenges Need Short-term Attention
December 13th, 2009
FDA Matters sees seven long-term challenges for FDA. Some of these challenges may take years to accomplish; all need to be started now. Three or four years from now, the Commissioner will be judged by whether she moved the agency forward in these areas. I think she has gotten off to a very good start, but there is immense amount of work still required. Read the rest of this entry