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Comments on FDA Draft Guidance on Postmarketing Studies and Clinical Trials (HRG Publication #1894)October 13, 2009 Division of Dockets Management (HFA-305) Comments on FDA Draft Guidance “Postmarketing Studies and Clinical Trials--Implementation of Section 505(o) of the Federal Food, Drug, and Cosmetic Act.” (Docket No. FDA-2009-D-0283) Public Citizen has reviewed the draft guidance in detail and supports its purpose and approach. The guidance makes a sensible distinction between studies that are for efficacy purposes only (“postmarketing commitments”; these may be recommended but not required) and those that have any significant safety element (“postmarketing requirements”; these may be required). The categories of studies that can fall under postmarketing requirements (observational studies, clinical trials, animal studies, in vitro studies, pharmacokinetic studies, and interaction/bioavailability studies) are appropriately broad. We urge you to resist any efforts to weaken the draft guidance. Peter Lurie, MD, MPH Sidney M. Wolfe, MD
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