Regulatory Aspects of Phase 3 Endpoints for New Inhaled Antibiotics for Cystic Fibrosis Patients with Chronic Pseudomonas aeruginosa Infections

Available regulatory guidelines for developing inhaled anti-infective therapies offer general advice, but specific guidance often provides conflicting and outdated advice in regard to clinical trial design. For instance, the availability of two approved drugs makes the conduct of placebo-controlled trials longer than 28 days problematic. Comparator drugs require use per the product label, making comparator trials difficult to blind as taste, foaming, regimen, device, and delivery time differences are present. Currently, there is no consensus on the most appropriate endpoints for evaluation of aerosolized antimicrobials. FEV1 is a surrogate endpoint that it is a predictor of mortality-it is standardized, reproducible, noninvasive, simple, and inexpensive to perform but small statistically significant changes may not be clinically important. FEV1 improvement also has a ceiling effect in patients with mild lung function impairment and spirometry cannot be reliably done in patients under the age of 6 years. A patient-reported outcome is a promising clinical endpoint. However, there is not currently an accepted tool that can be used as a primary endpoint for the FDA or the EMA, although the latter recognizes the CFQ-R as a validated secondary endpoint and the FDA grandfathered acceptance of the CFQ-R respiratory domain in the pivotal aztreonam for inhalation study. Exacerbations are an important clinical endpoint that reflects morbidity and are a major driver of cost of care, but they occur infrequently and a standardized definition has not been reached. Furthermore, an exacerbation endpoint may fail even with an otherwise effective antibiotic therapy. Regulatory authorities will have a difficult time approving any new inhaled antibiotic based on one clinical endpoint alone.