Pharmaceutical industry perspective on risk evaluation and mitigation strategies: manufacturer take heed

Abstract

Introduction: Enactment of the Food and Drug Administration Amendments Act of 2007 (FDAAA) authorized the FDA to require manufacturers to submit Risk Evaluation and Mitigation Strategy (REMS) when it was deemed necessary to ensure that a drug's benefit outweigh its risk. REMS apply to new drug applications (NDAs), abbreviated new drug applications (ANDAs) and biologics license applications (BLAs). The objective of this review is to describe the impact of REMS requirements on the pharmaceutical industry.

Areas covered: Articles were identified in MEDLINE searches through October 11, 2011, using the MeSH terms and keywords pharmaceutical industry, risk management, United States Food and Drug Administration, REMS, ETASU, and Medication Guide in various combinations.

Expert opinion: The new powers ascribed to the FDA are notable, as they add enforceability to safety strategies that were not part of FDA's prior risk management tools, risk minimization action plans (RiskMAPs). Failure to comply with REMS can lead to financial penalties up to $10 million, and a drug could be deemed misbranded if the REMS is not followed. The new approach to risk management via FDAAA has elevated the rigor with which manufacturers must fulfill postmarketing safety commitments.

Keywords:

• pharmaceutical industry
• risk management
• safety
• United States Food and Drug Administration

Acknowledgments

The authors would like to acknowledge medical writing support for the preparation of this article provided by I Mills, PhD, and C Ornstein, PhD, both of Embryon, LLC, Somerville, NJ. Their assistance was funded by Janssen Pharmaceuticals Scientific Affairs, LLC, Titusville, NJ, and Janssen Scientific Affairs, LLC, Raritan, NJ.

Notes

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