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Regulatory Challenges for Bioabsorbable Stent Approval Ashley Boam, MSBE for: Andrew Farb, M.D. Interventional Cardiology Devices Branch Division of Cardiovascular Devices U.S. FDA/CDRH BIOABSORBABLE STENT SYMPOSIUM CRT 2010 Washington, DC February 22, 2010 DHHS/FDA DISCLOSURES Ashley Boam I have no real or apparent conflicts of interest to report. Novel DES in Development or Trials New drugs Degradable polymers DES with biologics Programmable stent lengths Dedicated bifurcation DES Bioabsorbable stents (BAS) DHHS/FDA Characterization of Biodegradable Stents (BAS) Questions that guide testing: – What are the expected advantages of the BAS? – What is the mechanism of biodegradation? – What are the degradation products and what are their biologic activities? – How does the proposed BAS balance the need for mechanical integrity with the ability to degrade over time? DHHS/FDA Preclinical Testing Objectives Complete characterization of the finished sterilized product – Coating/drug loading characteristics – drug and carrier content, coating integrity – In vitro/in vivo elution of both coating and stent substrate – Methods and specifications to allow stability testing Adequate bench & animal studies to assess safety prior to human trials DHHS/FDA BAS Preclinical Evaluation Bench Testing Standard tests such as stent and coating durability no longer as relevant Still need to test the mechanical properties in a physiologically relevant environment Need to conduct mechanical tests at multiple time points to fully characterize the impact of degradation on mechanical integrity Characterize degradation products How to assess “particulates” when the stent is meant to degrade? DHHS/FDA BAS Preclinical Evaluation Biocompatibility Testing Standard tests may need to be altered – Extraction conditions – Time exposure Separate testing of degradation products may be appropriate Discuss test methods with FDA DHHS/FDA BAS Preclinical Evaluation Animal Studies Measurement time points may need to be modified to better capture critical safety parameters – Early – when BAS is still intact – During degradation – Post-complete degradation Assess whether absence of rigid scaffold leads to adverse arterial remodeling & edge effects Evaluate potential toxicity of degradation products DHHS/FDA Animal Studies Safety and effectiveness parameters – Neointimal growth – Inflammation – Thrombus deposition – Re-endothelialization – Remodeling & edge effects Safety margin overdose studies Assessment of downstream myocardial pathology – Evaluate embolization due to bulk degradation Optional: Vasomotor function & use of disease models DHHS/FDA Clinical Trials Feasibility/FIM trial(s) – Initial assessment of device performance and safety and effectiveness Pivotal trial – RCT recommended for initial marketing approval – Superiority or non-inferiority to approved DES – Target lesion failure primary endpoint Composite of cardiac death, target vessel MI and TLR Duration of patient follow-up reflects degradation profile – To adequately capture outcomes before, during, and after stent degradation DHHS/FDA Other Important Clinical Assessments Procedural results – Device handling: Tracking, deliverability, crossing, deployment, balloon deflation, catheter withdrawal, post-dilatation – Device success: Achievement of an acceptable postdeployment angio result with the test device alone – Clinical success: Device success without in-hospital MACE If BAS visibility on fluoroscopy is an issue: – Assess frequency of geographic miss – Ability to accurately deploy overlapping stents in bailout situations DHHS/FDA Clinical Imaging Follow-up imaging to confirm absorption QCA & IVUS to address effects of loss of rigid scaffold on restenosis – In-stent & in-segment MLD, late lumen loss & %diameter stenosis – Stent area – Neointimal area and volume – Positive and negative (constrictive) remodeling – Edge effects Consider exploratory use of OCT DHHS/FDA BAS Imaging Considerations Is stent mal-apposition relevant for a biodegradable stent? Angio/IVUS assessment more challenging to identify treatment site with fully bioabsorbed stent – Blinding issues vs. a non-degradable stent – Utilize measurements that minimize bias Other targets – potential value added – Vasomotion – Plaque modification DHHS/FDA BAS Clinical Program Considerations Need adequate number of patients to detect uncommon but clinically important safety events – Not all patients need to be part of a randomized trial – Can use multiple trials (both US and OUS) Patient clinical follow-up through 5 years – Assess rates of stent thrombosis over time Assess dual antiplatelet therapy use and duration of thienopyridines following BAS implantation Plan for post-approval study – Real world use beyond labeled indication – Evaluate rates of ST, and CV death + MI DHHS/FDA Conclusions BAS add multiple levels of complexity to FDA review Discussions with FDA early in new BAS program development highly recommended DES Draft Guidance document http://www.fda.gov/downloads/Drugs/Guidance ComplianceRegulatoryInformation/Guidances/UC M072193.pdf DHHS/FDA Contact Information Interventional Cardiology Devices Branch 301-796-6343 [email protected] [email protected] DHHS/FDA