Posts Tagged ‘contingency plan’

Organizing for REMS Effectiveness: A View from the Field

Tuesday, March 30th, 2010

- Guest blog by Andrea J. Simon, PhD -

This blog by Andrea Simon, PhD, a corporate anthropologist, is one in a series that ParagonRx has initiated to help our readers better understand some of the trends taking place in the field of Risk Evaluation and Mitigation Strategies (REMS) and risk management under the FDA  draft guidance.  We know you will find them of value and encourage you to comment on them.

In April, ParagonRx is hosting its Wednesday FoREMS webinar on the topic of organizing to effectively manage Risk Evaluation and Mitigation Strategies (REMS).  And, in May, the Wednesday FoREMS will host a panel of industry leaders discussing how their organizations are building REMS capabilities and resourcing them in their product development and commercialization functions.  In preparation for these upcoming webinars, I thought I would share with you some of my observations from the field and encourage you to share your own company’s perspectives on how you are reorganizing to create and effectively manage REMS. (more…)

Contingency Planning: Strategies to Negotiate the Barriers to Product Approval

Wednesday, September 2nd, 2009

In a constantly changing regulatory environment, having a well planned contingency strategy is vital for successful Food and Drug Administration (FDA) negotiations. Today, this is more important than ever. The FDA is asking companies to prepare Risk Evaluation and Mitigation Strategies (REMS) to help ensure patient safety, and has issued a documentation template, but has yet to provide further guidance to the industry on how such REMS should be developed. (more…)

Big Lessons Learned in this New World of REMS

Monday, July 20th, 2009

Today we want to focus on key lessons learned from our clients’ experiences. We are very grateful to these clients for allowing us to share their experiences with you so that you can do a better job in your REMS process.

Let’s begin with something that happened recently as we were working with a client during the tight 90-day period before they presented their PDUFA.

Expect the Unexpected

As we work with our clients on their REMS process, we are learning a lot about the uncertainties of interfacing with an internal FDA process that is itself a work in process. One thing that has become very apparent is that no matter how much advanced preparation you believe you have done, the FDA might just surprise you. (more…)

Pharmaceutical Safety Risk Management

Wednesday, April 8th, 2009

What a difference a year makes…

In early 2008, the topic of risk management was greeted with aversion by most pharmaceutical managers responsible for commercial activities.  “If I encounter a drug with genuine safety concerns, I’ll call you” was a frequent response.

Today, everyone is talking about risk management… and for good reason.  The FDA Amendment Act (FDAAA) of 2007 granted FDA sweeping new authority to require Risk Evaluation and Mitigation Strategies (REMS) of any product at any stage of lifecycle.  In response to FDAAA, industry had three immediate questions:

  • What determines if REMS will be necessary?
  • How actively will FDA implement the REMS provisions?
  • Who should be thinking about risk management?

(more…)