Guidance Document: International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH): Studies in Support of Special Populations: Geriatrics, Questions and Answers ICH Topic E7 Q&A

June 16, 2015

Our file number: 15-107057-839

Notice: Adoption of ICH Guidance: E7 Q&A: Studies in Support of Special Populations: Geriatrics, Questions & Answers

Health Canada is pleased to announce the adoption of the ICH guidance E7 Q&A: Studies in Support of Special Populations: Geriatrics, Questions & Answers.

This guidance has been developed by the appropriate ICH Expert Working Group and has been subject to consultation by the regulatory parties, in accordance with the ICH Process. The ICH Steering Committee has endorsed the final draft and recommended its adoption by the regulatory bodies of the European Union, Japan and USA.

In adopting this ICH guidance, Health Canada endorses the principles and practices described therein. This document should be read in conjunction with this accompanying notice and with the relevant sections of other applicable Health Canada guidances.

It is recognized that the scope and subject matter of current Health Canada guidances may not be entirely consistent with those of the ICH guidances that are being introduced as part of our commitment to international harmonization and the ICH Process.  In such circumstances, Health Canada adopted ICH guidances take precedence.

Health Canada is committed to eliminating such discrepancies through the implementation of a phased-in work plan that will examine the impact associated with the adoption of ICH guidances. This will result in the amendment or, depending on the extent of revisions required, withdrawal of some Health Canada guidances.

This and other Guidance documents are available on the Health Canada website.

Should you have any questions or comments regarding the content of the guidance, please contact:

Office of Regulatory Affairs
Biologics and Genetic Therapies Directorate
Phone: (613) 957-1722
Fax: (613) 946-9520
Email: BGTD_ORA@hc-sc.gc.ca

Foreword

This guidance has been developed by the appropriate ICH Expert Working Group and has been subject to consultation by the regulatory parties, in accordance with the ICH Process. The ICH Steering Committee has endorsed the final draft and recommended its adoption by the regulatory bodies of the European Union, Japan and the United States of America.

In adopting this ICH guidance, Health Canada endorses the principles and practices described therein. This document should be read in conjunction with the accompanying notice and the relevant sections of other applicable guidances.

Guidance documents are meant to provide assistance to industry and health care professionals on how to comply with the policies and governing statutes and regulations. They also serve to provide review and compliance guidance to staff, thereby ensuring that mandates are implemented in a fair, consistent and effective manner.

Guidance documents are administrative instruments not having force of law and, as such, allow for flexibility in approach. Alternate approaches to the principles and practices described in this document may be acceptable provided they are supported by adequate scientific justification. Alternate approaches should be discussed in advance with the relevant program area to avoid the possible finding that applicable statutory or regulatory requirements have not been met.

As a corollary to the above, it is equally important to note that Health Canada reserves the right to request information or material, or define conditions not specifically described in this guidance, in order to allow the Department to adequately assess the safety, efficacy or quality of a therapeutic product. Health Canada is committed to ensuring that such requests are justifiable and that decisions are clearly documented.

E7 Geriatric Studies : Questions and Answers
Date of Approval Questions Answers
1 Sept. 2009 Why do we need an adequate representation of geriatric patients in the clinical database? Geriatric patients can respond differently from younger patients to drug therapy in a number of ways and such differences can be greater in patients 75 years and older:

a) The geriatric population has age-related physiological changes that can affect the pharmacokinetics of the drug, and the pharmacodynamic response to the drug, both of which can influence the drug-response and the dose response relationship.

b) Geriatric patients are more prone to adverse effects since they often have co-morbidities and are taking concomitant therapies that could interact with the investigational drug. The adverse effects can be more severe, or less tolerated, and have more serious consequences than in the non-geriatric population.

With the increasing size of the geriatric population (including patients 75 and older) and in view of the recent advances in pharmacokinetics and pharmacodynamics since the ICH E7 guideline was established in 1993, the importance of geriatric data (from the entire spectrum of the geriatric patient population) in a drug evaluation program has increased.

Not all potential differences in pharmacokinetics, pharmacodynamics, disease-drug, drug-drug interactions and clinical response that can occur in the geriatric population can be predicted from non-geriatric populations, as the geriatric patients are far more likely to have multiple illnesses and to be receiving multiple drugs. Therefore, to assess the benefit/risk balance of a drug that will be used in the geriatric population, these patients should be appropriately represented in clinical trials.

2 Sept. 2009 What should be taken into account when estimating an adequate representation of geriatric patients to be included in the clinical database? It is very important to ensure, to the extent possible, that the population included in the clinical development program is representative of the target patient population. As stated in the current ICH E7 guideline, estimates of the prevalence of the disease to be treated by age or examination of the age distribution of usage for other drugs of the same class or for the same indication, should be provided by the applicant. This will indicate the expected use of the drug and should influence the number of geriatric patients to be included in the marketing application.

The current guideline states, "for drugs used in diseases not unique to, but present in the elderly, a minimum of 100 patients would usually allow detection of clinically important differences". Given the increasing prevalence and the growing recognition of the complexity of the geriatric population, including concomitant therapies and co-morbidities, it would usually be appropriate to include more than 100 geriatric patients in the Phase 2 and 3 databases and include patients over the entire spectrum of the geriatric patient population.

In the marketing application, depending on the numbers of patients, data should be presented for various age groups (for example <65, 65-74, 75-84 and > 85) to assess the consistency of the treatment effect and safety profile in these patients with the non-geriatric patient population.

As single trials may not have sufficient numbers of geriatric patients to allow such analyses, these will often need to be carried out on pooled data. Any such analyses will need to consider consistency across studies.

3 Sept. 2009 Are there any special patient populations or characteristics that are particularly important to address in the planning of the clinical development program? Geriatric patients often have co-morbidities and concomitant therapies that could interact with the investigational drug and make patients more likely to have undesirable effects and interactions. Therefore, it is important to assess the safety and efficacy of a drug in such patients, and to design a study with inclusion/exclusion criteria that allows their participation. There may exist a reluctance to include vulnerable geriatric patients at high risk of adverse outcomes (so-called "frail" geriatric patients). However, care in randomization should allow the appropriate attribution of findings either to the investigational drug or to other factors.

This applies both to drugs intended for the geriatric patient population and for drugs used in diseases present in, but not unique to, the geriatric population.

4 Sept. 2009 What should be considered for the clinical development program to adequately characterize the safety and efficacy of a drug for a marketing application? An appropriate representation of the geriatric population (including patients with concomitant therapies and co-morbidities) should be enrolled in the clinical development program to adequately characterize efficacy and safety in the geriatric population and allow for comparisons with the non-geriatric population. This information would ordinarily be expected in a marketing application.

In general it is preferable to include both non-geriatric and geriatric patients in the same study(ies), which can facilitate observation of age-related differences. In some cases a separate study in the geriatric population can be preferable.

Every effort should be made to include geriatric patients using concomitant therapies and with co-morbidities in the premarketing clinical development program. In some cases, enrolment of these patients can be challenging and it could be appropriate to collect data post-marketing. However, the adequacy of, and the need for, data in these patients should be considered during drug development and discussed in the marketing application submission. Where enrolment of geriatric patients has been insufficient despite the efforts of the applicant, a specific plan to collect data post-marketing should be discussed during development and presented in the marketing application.

Information relevant to the geriatric patient population, including any limitations, should be reflected in the product labeling.

5 Sept. 2009 Are there concerns related to the data specific to the geriatric population that could be considered in the planning of the clinical studies? Depending on the mechanism of action of the drug and/or the characteristics of the disease, certain specific adverse events and age-related efficacy endpoints should be actively sought in the geriatric population, e.g. effects on cognitive function, balance and falls, urinary incontinence or retention, weight loss and sarcopenia. This may require specific testing, e.g. for cognitive function. Applicants should also refer to disease specific guidelines for specific recommendations concerning the evaluation of both efficacy and safety in geriatric patients.
6 Sept. 2009 In light of recent advances in the field of pharmacokinetics and assessment of drug-drug interactions since the ICH E7 guideline was established, what studies should be considered when developing a drug that will be used in geriatric patients? The pharmacokinetics in geriatric patients (over the entire spectrum of the geriatric patient population) should be evaluated to identify age-related differences that are not explained by other factors such as reduced renal function or weight differences. The potential influence of impaired renal/hepatic function as well as potential drug interactions is often assessed in studies with non-geriatric subjects.

Population pharmacokinetic analysis could provide the requested data if a sufficient number of patients in different age ranges (including patients >65 and >75 years) are included in the clinical trials. The applicability of population pharmacokinetics is dependent on several factors, e.g. the representation of the target population, the pharmacokinetics of the drug, dosing regimens and analytical requirements.

A specific pharmacokinetic study comparing non-geriatric and geriatric subjects in the same study (matched for relevant covariates, e.g. weight, sex) could achieve the same goals.

More details on the pharmacokinetic approach (population pharmacokinetics, the appropriate design of a specific pharmacokinetic study) and assessment of drug-drug interactions can be discussed with the regulatory agencies.

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