ATA continues dialog with FDA on dose precision

By October 1, 2003 July 7th, 2017 Bioequivalence

ATA Continues Dialog With FDA on Levothyroxine Dose Precision and Bioequivalence Standards

ATA

2003-2004

President
Clark T. Sawin, M.D.
Washington, D.C.

Secretary
Gregory A. Brent, M.D.
Los Angeles, California

Treasurer
Charles H. Emerson, M.D.
Worcester, Massachusetts

President-Elect
Paul W. Ladenson, M.D.
Baltimore, Maryland

Directors
Peter A. Singer, M.D.
Los Angeles, California

Jeffrey R. Garber, M.D.
Boston, Massachusetts

Stephanie L. Lee, M.D., Ph.D.
Boston, Massachusetts

John C. Morris, III, M.D.
Rochester, Minnesota

Rebecca S. Bahn, M.D.
Rochester, Minnesota

Donald L. St. Germain, M.D.
Lebanon, New Hampshire

Steven I. Sherman, M.D.
Houston, Texas

Bryan R. Haugen, M.D.
Denver, Colorado

Sandra M. McLachlan, Ph.D.
Los Angeles, California

Executive Director
Barbara R. Smith, CAE

Headquarters Office
American Thyroid Association
6066 Leesburg Pike, Suite 550
Falls Church, Virginia 22041
Phone: 703 998-8890
Fax:: 703 998-8893
E-mail: bsmith@thyroid.org
Web: www.thyroid.org

October 1, 2003

Janet Woodcock, M.D.
Director, Center for Drug Evaluation and Research
Food and Drug Administration
5600 Fishers Lane, HFD-240
Rockville, MD 20857

Dear Dr. Woodcock:

I am writing on behalf of Dr. Peter Singer, Immediate Past President of the American Thyroid Association; Dr. E. Chester Ridgway, President of the Endocrine Society; and Dr. Donald Bergman, President of the American Association of Clinical Endocrinologists. We thank you for the thoughtful manner in which you and your staff recently listened to the concerns of our societies, physician members, and patients regarding dose precision and bioequivalence standards for levothyroxine sodium formulations.

We are heartened by the commitment that you made to plan and hold a workshop of sufficient depth and duration to address all of the relevant issues: bioequivalence testing baseline correction, optimal test subjects, and acceptable confidence limits; and TSH as a pharmacodynamic measure. We also support your interest in designing a crossover chronic thyroxine therapy trial with serum TSH as an outcome. We agree with you that a properly designed and executed study could address the fundamental concerns that physicians and their patients have about optimizing the safety and effectiveness of thyroxine therapy. We offer our assistance in designing, implementing, and interpreting the results of such a study.

Because of the concerns that we all share regarding thyroxine dose precision and limitations in the current bioequivalence standard, we ask that 1) FDA suspend approval of new formulations until these matters are resolved, and 2) FDA not make a final decision regarding equivalence testing until it has received further input from experts at the workshop that you proposed.

As you requested, we will send to you a draft agenda and list of potential contributors to the workshop program that you have proposed.

Although I am no longer Secretary of the American Thyroid Association, I have become president-elect and our new president, Dr. Clark Sawin, has asked me to remain the primary point of contact between the three societies and FDA. We look forward to hearing from you.

Sincerely,


Paul W. Ladenson, M.D.
President-Elect, American Thyroid Association

PWL:sr


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