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Antibacterial Drug Products: Use of Noninferiority Studies to Support Approval

FinalCenter for Drug Evaluation and Research11/29/2010

Description

The purpose of this guidance is to inform industry of the Food and Drug Administration’s (FDA’s) current thinking regarding appropriate clinical trial designs to evaluate antibacterial drug products, and to provide an opportunity for sponsors to amend ongoing or completed trials accordingly. This guidance is in response to a number of public discussions in recent years regarding the use of active-controlled trials designed to show noninferiority (NI) as a basis for approval of antimicrobial drug products. These discussions initially focused on the indications acute bacterial sinusitis (ABS), acute bacterial exacerbation of chronic bronchitis (ABECB), and acute bacterial otitis media (ABOM). However, the science of active-controlled trials designed to show NI and the selection of appropriate NI margins in circumstances where an activecontrolled trial designed to show NI is an appropriate trial design has been a focus of recent discussions in other antimicrobial drug product indications and in other therapeutic areas as well.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

1
Antibacterial Drug Products

superseded guidance topic

Stakeholders

1
Sponsor

Entity responsible for submitting applications under section 524B

Regulatory Context

Regulatory Activities

3
Investigational New Drug Application

IND for treatment use; Regulatory submission required for clinical trials and expanded access.

Special Protocol Assessment

repeat-dose toxicity studies that support a carcinogenicity Special Protocol Assessment (SPA)

New Drug Application

Rule does not apply to products marketed under an NDA

Document Types

1
Protocol

Defines the standard of veterinary practice and limits for anesthetic regimens

Attributes

1
Efficacy Endpoint

critical to have an adequately justified NI margin and to use appropriate efficacy endpoints

Technical Details

Testing Methods

3
Superiority Design

other trial designs (i.e., superiority designs) will be needed

Noninferiority Study

active-controlled trials designed to show noninferiority

Noninferiority Trials

Clinical trial design used to support approval

Clinical Concepts

7
Acute Bacterial Exacerbations of Chronic Bronchitis

The disease previously referred to as ABECB; The primary disease state being studied in the clinical trials.; Patients with greater severity of ABECB-COPD should be offered treatment with an antibacterial drug.

Acute bacterial skin and skin structure infections

Example of a clinical indication for an antibacterial drug

Community-acquired bacterial pneumonia

Example of infection where disease process may be similar between adult and pediatric populations.

Hospital-acquired bacterial pneumonia

Example of a serious bacterial disease; Example of serious bacterial disease in labeling language

Acute bacterial otitis media

Indication where NI margin definition is challenging; indications such as ABOM where data will not support the use of an NI design

Acute bacterial exacerbation of chronic bronchitis

Indication where NI margin definition is challenging

Acute bacterial sinusitis

Indication where NI margin definition is challenging; indications such as ABS where data will not support the use of an NI design

Standards & References

Specifications

1
Noninferiority Margin

Justification provided in the appendix for trial design.; Justification for a noninferiority margin for diabetic foot infections; Determining an NI margin for patients with DFIs

ICH References (1)

ICH E10

Choice of Control Group in Clinical Trials.

Related CFR Sections (1)

Related MFDS Guidelines

Korean regulatory guidelines covering similar topics

See Also (8)

Antibacterial Drug Products: Use of Noninferiority Studies to Support Approval | Guideline Explorer | BioRegHub