ACHIEVING STRATEGIC PRIORITIES WITH REGULATORY SCIENCE Cathy L. - - PowerPoint PPT Presentation

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ACHIEVING STRATEGIC PRIORITIES WITH REGULATORY SCIENCE Cathy L. - - PowerPoint PPT Presentation

ACHIEVING STRATEGIC PRIORITIES WITH REGULATORY SCIENCE Cathy L. Backinger, PhD, MPH Deputy Director for Research Dana M. van Bemmel, PhD, MPH Assistant Deputy Director for Research Office of Science, Center for Tobacco Products, FDA September 18,


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ACHIEVING STRATEGIC PRIORITIES WITH REGULATORY SCIENCE

Cathy L. Backinger, PhD, MPH Deputy Director for Research Dana M. van Bemmel, PhD, MPH Assistant Deputy Director for Research Office of Science, Center for Tobacco Products, FDA

September 18, 2015

Disclaimer: The information in these materials is not a formal dissemination of information by FDA and does not represent agency position or policy.

NIH FOA Webinar| September 18, 2015

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| NIH FOA Webinar| September 18, 2015 2

IMPLEMENTING THE TOBACCO CONTROL ACT

CTP has authority to:

  • Regulate tobacco products intended for human consumption

to reduce harm across the population

  • Regulate the manufacture, marketing, and distribution of

cigarettes, cigarette tobacco, roll‐your‐own, and smokeless

  • Assert jurisdiction over other products that meet the definition
  • f a tobacco product, including e‐cigarettes, cigars, and hookah
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| NIH FOA Webinar| September 18, 2015 3

DEFINING A PUBLIC HEALTH STANDARD

  • Pursue a “public health” standard, as tobacco cannot be

regulated using FDA’s traditional “safe and effective” standard

  • Take into account the benefits and the risks of regulatory

actions to both users and non‐users of tobacco products

  • Assess the “net” population‐level health impacts of tobacco

products

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| NIH FOA Webinar| September 18, 2015 4

PURSUING STRATEGIC PRIORITIES BASED ON REGULATORY SCIENCE

  • Product Standards
  • Comprehensive FDA Nicotine Regulatory

Policy

  • Pre‐ and Post‐Market Controls via

Regulations and Product Reviews

  • Compliance and Enforcement
  • Public Education
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| NIH FOA Webinar| September 18, 2015 5

ACHIEVING STRATEGIC PRIORITIES

  • As a regulatory agency, FDA can only go as far as the

regulatory science can take us

  • Developing a robust regulatory science program is critical to

achieving programmatic success

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| NIH FOA Webinar| September 18, 2015 6

WHAT IS TOBACCO REGULATORY SCIENCE?

  • Tobacco regulatory science involves the application of the

best‐available science to specific regulatory questions

  • Tobacco regulatory research translates general scientific

knowledge into the specific scientific findings that serve as the guide for regulatory decisions and actions

  • To accomplish this, tobacco regulatory science evaluates

distinct situations to determine which would most benefit public health

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| NIH FOA Webinar| September 18, 2015 7

HOW IS TOBACCO REGULATORY SCIENCE USED?

  • Regulatory science allows FDA to:
  • Utilize the best science from a broad range of disciplines (e.g.,

product, nonclinical, health, and population sciences)

  • Find new tools, information, and strategies for informed

decision‐making when taking regulatory actions

  • Leverage opportunities for invention to quickly bridge the gap

between scientific discovery and improving public health

  • Bring together the best minds across academia, government,

and private sector to advance science and its public health applications

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| NIH FOA Webinar| September 18, 2015 8

EXAMPLES OF TOBACCO REGULATORY ACTIONS

  • Product Review
  • Regulations and Guidance
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| NIH FOA Webinar| September 18, 2015 9

PRODUCT REVIEW

  • Includes:
  • Investigational tobacco products
  • Pre‐market tobacco applications (PMTA)
  • Substantial equivalence (SE)
  • Exemption from SE
  • Modified risk tobacco products (MRTPs)
  • Applicant must provide adequate evidence for FDA to make

a finding

  • FDA uses scientific research to evaluate the evidence

provided by the applicant

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10 | NIH FOA Webinar| September 18, 2015

PRODUCT REVIEW – STATUTOR Y QUESTIONS

  • PMTA ‐ Is the marketing of a new product appropriate for

the protection of public health?

  • SE ‐ Do differences between a new product and a predicate

product raise different questions of public health?

  • MRTP ‐ Will the product as it is actually used by consumers

significantly reduce the harm and risk of tobacco‐related disease to individual tobacco users and benefit the health of the population as a whole?

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11 | NIH FOA Webinar| September 18, 2015

PRODUCT REVIEW CONSIDERATIONS

Information

  • Materials
  • Ingredients
  • Design
  • Composition
  • Constituents
  • Other

features

  • Marketing

Impact

  • Appeal
  • Addictiveness
  • Behavior/use
  • Exposure
  • Pharmacokinetics
  • Toxicity
  • Perception
  • Initiation
  • Cessation

Public Health

  • Morbidity
  • Mortality
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12 | NIH FOA Webinar| September 18, 2015

REGULATION AND GUIDANCE

  • Through rulemaking, the Tobacco Control Act allows

adoption of “…tobacco product standards… appropriate for the protection of public health.” (Sec 907)

  • Nicotine yields
  • Reduction or elimination of constituents, including smoke

constituents

  • Construction, components, ingredients, additives, constituents,

and properties of the tobacco product

  • Provisions for testing or measuring product characteristics
  • Restrictions on sale and distribution
  • Form and content of labeling
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13 | NIH FOA Webinar| September 18, 2015

PRODUCT STANDARDS – STATUTOR Y QUESTION

  • Is a product standard appropriate for the

protection of public health, considering:

  • The risks and benefits to the population as a

whole

  • The increased or decreased likelihood that

existing users of tobacco products will stop using such products

  • The increased or decreased likelihood that

those who do not use tobacco products will start using such products

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14 | NIH FOA Webinar| September 18, 2015

PRODUCT STANDARDS – EXAMPLE S OF USEFUL RESEARCH INFORMATION

  • Data that describe the current situation
  • The impact of the current situation on public health
  • Data that describe an alternate situation
  • The quantitative public health benefits of the alternate

situation

  • Secondary or unintended effects of the alternate situation
  • The feasibility of achieving the alternate situation
  • Whether other situations could accomplish the target health

benefit at lower risk or cost

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15 | NIH FOA Webinar| September 18, 2015

IMPLEMENTING ONE OF THE LAW’S MOST POWERFUL TOOLS

  • Advancing a product standard strategy that yields strong

standards to improve public health

  • Exploring potential standards for:
  • Addictiveness
  • Toxicity
  • Appeal
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16 | NIH FOA Webinar| September 18, 2015

COMPREHENSIVE FDA NICOTINE REGULATORY POLICY

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17 | NIH FOA Webinar| September 18, 2015

LOOKING AT NICOTINE DIFFERENTLY

  • Establish an integrated, FDA‐wide policy on nicotine‐

containing products that is public‐health based

  • Recognize that there is a continuum of nicotine‐

containing products…and the reality that people smoke for the nicotine but die from the toxins in tobacco

  • Evaluate the implications for tobacco, drug, and device

regulatory policy

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18 | NIH FOA Webinar| September 18, 2015

PRE‐ AND POST‐MARKET CONTROLS: REGULATIONS AND PRODUCT REVIEWS

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19 | NIH FOA Webinar| September 18, 2015

SETTING PRE‐ AND POST‐MARKET POLICY

  • Explore developing rules and guidances for:
  • Product review pathways (SE, PMTA, MRTP)
  • Tobacco Product Manufacturing Practices (TPMP)
  • Analytic test method validation
  • Continue to establish and then meet performance

standards for product reviews

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20 | NIH FOA Webinar| September 18, 2015

MAXIMIZING USE OF OUR AUTHORITY FOR A HEALTHIER TOMORROW Utilize The Tools Given To Us By Congress To Maximize Their Potential And Positively Impact Public Health

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21 | NIH FOA Webinar| September 18, 2015

RFA RELEVANCE TO FDA

Waterpipe Funding Opportunity Announcement (FOA) Anticipating the final deeming rule that includes waterpipe tobacco, this FOA is focused on the following CTP priorities related to waterpipe tobacco:

  • Harmful and potentially harmful constituents (HPHCs) present in

waterpipe tobacco smoke

  • Types of in vitro and/or in vivo assays that can be used to

distinguish toxicity of waterpipe tobacco smoke

  • Impact of constituents, compounds, design features, and tobacco

use behaviors on the toxicity of waterpipe tobacco products and smoke

  • Impact of waterpipe tobacco characteristics and experimentation