Pirfenidone - comment to FDA

On 5.26.10 I forwarded the following comment to Food and Drug Administration:
The decision of the Food and Drug Administration (FDA) not to approve pirfenidone for the treatment of idiopathic pulmonary fibrosis (IPF) was highly disappointing to all patinets suffering from this disease, their caregivers, as well as physicians who are treating IPF patients. The fact that that the Agency did not follow the advice of their Advisory Committee, which voted 9:3 for the approval of pirfenidone, is extremely disturbing. The Agency also did not listen to pleas of patients who have been waiting impatiently for any drug that could possibly offer some hope in alleviating their suffering or prolonging their life expectancy. The Agency found it impossible to deviate from the established guidelines, even though the safety of pirfenidone was not quetioned.
The request for another Phase III trial to confirm the efficacy of pirfenidone may sound reasonable, but in reality it makes the eventual marketing of pirfenidone unlikely, even if another trial confirms its efficacy. Al leaast 4 years and a few hundred millions of dollars will be needed for another trial and its evaluation. If the trial starts in 2011, FDA approval cannot be expected before 2015. The proposed use of pirfenidone in IPF is covered, however by a 1997 patent that will expire in 2014. No single pharmaceutical company can afford to pay for the development and marketing of a drug without patent protection and/or a few years of exclusivity.
No drug can be expected to produce absolutely conclusive results in patients with IPF. IPF is most probably not a single disease but a collection of fibrotic lung diseases with unknown causes, so that in respect to etiology the patient population will be heterogenous and pirfenidone cannot, therefore, be expected to help all IPF patients. The fact that pirfenidone helps some of the patients with IPF should provide an adequate basis for its approval, since the risk-benefit ratio favors the drug.
A possible solution for the FDA is to create a new category of drugs with only "conditional approval" which would not cary an approved disease indication, but would claim, like for "dietary supplements", only a possible supporting role in the maintenance of function of certain organs (lungs in the case of pirfenidone). These drugs could be conditionally appproved by FDA on the basis of their safety record and the medical profession could be responsible for their use in specific diseases. This "conditional approval" could be withdrawn after 5 years, if additional documentation is not provided. After completion of all required clinical trials a final approval would be considered. In any case, I hope that the FDA would be willing to reconsider or to modify their decision to request another Phase III trial for pirfenidone.
Sincerely, Alexander Scriabine, M.D., Guilford, CT, May 26. 2010
Pharmacologist and IPF patient