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DBL%20Hendrix%20small.png College chemistry, 1983

Derek Lowe The 2002 Model

Dbl%20new%20portrait%20B%26W.png After 10 years of blogging. . .

Derek Lowe, an Arkansan by birth, got his BA from Hendrix College and his PhD in organic chemistry from Duke before spending time in Germany on a Humboldt Fellowship on his post-doc. He's worked for several major pharmaceutical companies since 1989 on drug discovery projects against schizophrenia, Alzheimer's, diabetes, osteoporosis and other diseases. To contact Derek email him directly: derekb.lowe@gmail.com Twitter: Dereklowe

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In the Pipeline

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August 19, 2013

Is The FDA the Problem?

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Posted by Derek

A reader sends along this account of some speakers at last year's investment symposium from Agora Financial. One of the speakers was Juan Enriquez, and I thought that readers here might be interested in his perspective.

First, the facts. According to Enriquez:

Today, it costs 100,000 times less than it once did to create a three-dimensional map of a disease-causing protein

There are about 300 times more of these disease proteins in databases now than in times past

The number of drug-like chemicals per researcher has increased 800 times

The cost to test a drug versus a protein has decreased ten-fold

The technology to conduct these tests has gotten much quicker
Now here’s Enriquez’s simple question:

"Given all these advances, why haven’t we cured cancer yet? Why haven’t we cured Alzheimer’s? Why haven’t we cured Parkinson’s?"

The answer likely lies in the bloated process and downright hostile-to-innovation climate for FDA drug approvals in this day and age...

According to Enriquez, this climate has gotten so bad that major pharmaceuticals companies have begun shifting their primary focus from R&D of new drugs to increased marketing of existing drugs — and mergers and acquisitions.

I have a problem with this point of view, assuming that it's been reported correctly. I'll interpret this as makes-a-good-speech exaggeration, but Enriquez himself has most certainly been around enough to realize that the advances that he speaks of are not, by themselves, enough to lead to a shower of new therapies. That's a theme that has come up on this site several times, as well it might. I continue to think that if you could climb in a time machine and go back to, say, 1980 with these kinds of numbers (genomes sequenced, genes annotated, proteins with solved structures, biochemical pathways identified, etc.), that everyone would assume that we'd be further along, medically, than we really are by now. Surely that sort of detailed knowledge would have solved some of the major problems? More specifically, I become more sure every year that drug discovery groups of that era might be especially taken aback at how the new era of target-based molecular-biology-driven drug research has ended up working out: as a much harder proposition than many might have thought.

So it's a little disturbing to see the line taken above. In effect, it's saying that yes, all these advances have been enough to release a flood of new therapies, which means that there must be something holding them back (in this case, apparently, the FDA). The thing is, the FDA probably has slowed things down - in fact, I'd say it almost certainly has. That's part of their job, insofar as the slowdowns are in the cause of safety.

And now we enter the arguing zone. On the one side, you have the reducio ad absurdum argument that yes, we'd have a lot more things figured out if we could just go directly into humans with our drug candidates instead of into mice, so why don't we just? (That's certainly true, as far as it goes. We would surely kill off a fair number of people doing things that way, as the price of progress, but (more) progress there would almost certainly be. But no one - no one outside of North Korea, anyway - is seriously proposing this style of drug discovery. Someone who agrees with Enriquez's position would regard it as a ridiculous misperception of what they're calling for, designed to make them look stupid and heartless.

But I think that Enriquez's speech, as reported, is the ad absurdum in the other direction. The idea that the FDA is the whole problem is also an oversimplification. In most of these areas, the explosion of knowledge laid out above has not yet let to an explosion of understanding. You'd get the idea that there was this big region of unexplored stuff, and now we've pretty much explored it, so we should really be ready to get things done. But the reality, as I see it, as that there was this big region of unexplored stuff, and we set into to explore it, and found out that it was far bigger than we'd even dreamed. It's easy to get your scale of measurement wrong. It's quite similar to the way that humanity didn't realize just how large the Earth was, then how small it was compared to the solar system (and how off-center), and how non-special our sun was in the immensity of the galaxy, not to mention how many other galaxies there are and how far away they lie. Biology and biochemistry aren't quite on that scale of immensity, but they're plenty big enough.

Now, when I mentioned that we'd surely have killed off more people by doing drug research by the more direct routes, the reply is that we've been killing people off by moving too slowly as well. That's a valid argument. But under the current system, we choose to have people die passively, through mechanisms of disease that are already operating, while under the full-speed-ahead approaches, we might lower that number by instead killing off some others in a more active manner. It's typically human of us to choose the former strategy. The big questions are how many people would die in each category as we moved up and down the range between the two extremes, and what level of each casualty count we'd find "acceptable".

So while it's not crazy to say that we should be less risk-averse, I think it is silly to say that the FDA is the only (or even main) thing holding us back. I think that this has a tendency to bring on both unnecessary anger directed at the agency, and raise unfulfillable hopes in regards to what the industry can do in the near term. Neither of those seem useful to me.

Full disclosure - I've met Enriquez, three years ago at SciFoo. I'd be glad to give him a spot to amplify and extend his remarks if he'd like one.

Comments (40) + TrackBacks (0) | Category: Drug Development | Drug Industry History | Regulatory Affairs


COMMENTS

1. Anonymous on August 19, 2013 9:05 AM writes...

FDA is certainly not the problem, they are merely responding to the requirement for greater safety and efficacy caused by new innovations raising the bar.

The main problem is in our misguided expectation that getting more data more cheaply corresponds to greater R&D productivity in terms of new patient benefits delivered per R&D spend.

Permalink to Comment

2. Anonymous on August 19, 2013 9:08 AM writes...

It's not about how many assays one can run or how many compounds one can make. It's all about how much we understand the human body. Can you recall how many drugs (and illegal drugs) were discovered based on adrenaline?

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3. Kent G. on August 19, 2013 9:23 AM writes...

I think this is a nice illustration of the distinction between data, information, and knowledge. Enriquez seems to have discovered that transforming data into information, and information into knowledge, is not straightforward. Welcome to the party.

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4. Anonymous on August 19, 2013 9:31 AM writes...

@3: ...and knowledge to understanding, and understanding to ideas, and ideas to working solutions.

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5. Bernard Munos on August 19, 2013 9:33 AM writes...

The loss of innovation culture in the industry can hardly be blamed on FDA. Poor leadership is a far more likely culprit. The CEOs who shifted "their primary focus from R&D of new drugs to increased marketing of existing drugs — and mergers and acquisitions" are the same folks who brought us six sigma, the industrialization of R&D, and the process culture that supplanted the innovation culture that made the industry great. Talk about a legacy... Thankfully, a number of companies have reacted against this nonsense, and taken steps to revive innovation. This is starting to show through more and better drugs.

FDA is doing its bit too, with breakthrough designations and an embrace of innovative therapies that must be acknowledged. To claim that it is responsible for the industry's woes is simply unfair. Management blunders must be acknowledged, and reversed.

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6. johnnyboy on August 19, 2013 9:56 AM writes...

No no no no. Enriquez is a business and finance guy, and like all business guys, he seems to be completely invested into the catechism that regulation is public enemy #1, and if only we could get rid of regulation what a wonderful world this would be (for business guys).
If FDA was really the problem, there would be a glut of NDAs but not many getting approved. That is not where the blockage is or has been. The real problem, as pointed out by others, is that, to paraphrase Barbie, Biology is Hard. Many, many thousands of times harder than any hotshot with a HBS degree could possibly fathom.

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7. Kelvin on August 19, 2013 9:57 AM writes...

@Bernard: I couldn't agree with you more.

The main barrier to innovation is that leaders need to be comfortable with uncertainty, and giving up their need to control things they cannot control.

Innovation requires a particular mindset to think big and different, start small, fail fast and often, and learn in the process. It means being willing to "let go" and explore the outliers, rather than establishing processes to avoid them and maintain the illusion of control.

http://www.linkedin.com/groups/Big-Ideas-in-Pharma-R-4322249

Permalink to Comment

8. a. nonymaus on August 19, 2013 10:59 AM writes...

We may also be running into a lack of druggable targets for diseases that are seen as potentially profitable. Take Parkinson's disease, for example. When symptoms appear, it's because vast swaths of the CNS dopaminergic neurons are already dead. Short of a breakthrough from the labs of V. Frankenstein, H. West, or others active in the field of reanimation, I don't see dead neurons as a druggable target.
If you want to see things that are amenable to drug treatment and aren't already solved, start working on TB or protozoal diseases or something.

Permalink to Comment

9. pgwu on August 19, 2013 10:59 AM writes...

Many in this business seems to be going bottom fishing to de-risk, in effect, kicking the can down the road. FDA is just an easy target to pick for blames. Not saying there are no bureaucracies.

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10. Lola on August 19, 2013 11:20 AM writes...

@2 anonymous: one of the best comments I have read here. People should learn more about adrenaline and the discoveries it inspired, and how those programs developed and evolved. The stories of the antihistamine class and especially the H2 antagonists are particulary interesting; pay close attention to the timelines...

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11. No on August 19, 2013 11:24 AM writes...

FDA is not preventing anyone from curing cancer. They are preventing people (like Mr. Enriquez, I presume) from making money back on their investments into cancer treatments. Too bad. Prove your stuff has some benefit before you profit on it, especially since you're really only selling hope to desperate and unlucky people.

Permalink to Comment

12. Bernard Munos on August 19, 2013 12:20 PM writes...

Kelvin,

You get it. Innovation cannot thrive upon law and order. Sooner or later, HR folks will need to come to grips with this. Innovators (the real ones) are rebels at heart. They are not interested in growing and nurturing existing markets beccause they want to obliterate and replace them with something better. They don't want competitive advantage from greater efficiency, because they want to change the game. They don't want to optimize, they want to disrupt and dominate the new markets they are creating. The most damaging legacy of the process-minded CEOs who brought us the innovation crisis has been to purge disrupters from the ranks of pharma. Yes, they are tough to manage, but every innovative company needs them, and must create a climate that allows them to thrive. Ideally the CEO should double as Chief Innovation Officer, and those who do have many grateful shareholders to thank them. Think Art Levinson, Roy Vagelos, George Yancopoulos (Regeneron), John Martin (Gilead) to name a few; but also Besos, Jobs, Gates or Branson outside pharma.

Permalink to Comment

13. Kelvin on August 19, 2013 12:27 PM writes...

@Bernard: Absolutely spot on, and you can count me as one of those purged rebels and trouble makers! :-)

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14. annon2 on August 19, 2013 12:40 PM writes...

Over the years, I've observed that FDA typically tries to be helpful, for example giving advice in a general way within a given treatment approach and/or disease area based on other information they've seen without giving enough details to compromise confidentiality integrity.

If providing safety with adequate chance of efficacy to warrant patient exposure in larger numbers means FDA is the problem, then yes FDA is the problem. Personally, when experiening the types of things that some scientists and clinicians would be willing to do, I've grown more appreciative of FDA's role of oversight & review.

Permalink to Comment

15. MoMo on August 19, 2013 12:41 PM writes...

Correct assessment Bernard. Meanwhile the teat suckers and saprophytes looking to cash in on Innovators and rebels are looking hungry- all because they let the MBAs run the shop and burn it to the ground. Using the FDA as an excuse instead of pointing the finger at themselves is a form of denial, its its only a matter of time before these finance guys have their cars repossessed, their houses in foreclosure and their wives run off with Yoga instructors half their age.

The same things that happened to all the good scientists that were cast out since the 2008 Pharma purge.

Permalink to Comment

16. zmil on August 19, 2013 12:46 PM writes...

The obvious response is that the speedier advances of the past were due to picking low hanging fruit, and now all the targets are super hard. But I'm wondering if there's a way to test this hypothesis; can we control for the relative difficulty of drug targets from each era in some way?

One approach that occurs to me is to look at emerging infectious diseases, and compare the speed at which we're currently able to develop treatments vs the speed of development of treatments to infectious diseases in the past. Presumably, since they're "emerging" they wouldn't be subject to the same selection bias as diseases we've been trying to cure for ages, like cancers and whatnot. Thus the percentage of low hanging fruit should look more like the percentage of low hanging fruit in the infectious disease field from, say, half a century ago.

One specific example is the speed with which effective treatments for AIDS were developed. It's really quite extraordinary: HIV was first identified in 1983, and the first truly effective treatment, the first generation of HAART, came around 96. But of course one would want to see how the entire field of EID has done over, say, the last 10, 20 years.

The obvious problem I see is that trends in that field might not apply in other areas, since antimicrobials are rather distinct in many ways from other drugs. But maybe there are other potential natural experiments of the same sort?

Permalink to Comment

17. annonie on August 19, 2013 1:02 PM writes...

As said earlier under another topic, we don't know nearly as much as we think we know about disease and it's underlying biochemistry and biology. The assumptions here are that imporved technology such as cheaper technology, access to more compounds, faster high-throughput screening, more gene sequences etc is what makes a drug. While these are steps along the way of the technical processes toward discover of a new drug, none really get down to the understanding of basic biology and what biochemical processes may underly given disease states. THAT is today's biggest problem in a nut-shell, full stop.

Permalink to Comment

18. Anonymous on August 19, 2013 1:04 PM writes...

#5 Bernard; #7 Kevin. An eloquent summary in your brief discussions


Bernard..."The loss of innovation culture in the industry can hardly be blamed on FDA. Poor leadership is a far more likely culprit.
Kevin..."The main barrier to innovation is that leaders need to be comfortable with uncertainty, and giving up their need to control things they cannot control. Innovation requires a particular mindset to think big and different, start small, fail fast and often, and learn in the process. It means being willing to "let go" and explore the outliers, rather than establishing processes to avoid them and maintain the illusion of control".


One of finest collection of reminiscences and honest analysis of, at times risk leadership and persistence, is contained in Vol 1 of Chronicles of Drug Discovery (1982),when scientists and science still ruled up to Phase I development. The tome contains the accounts, some scientifically turgid, others insightfully analyzing the professional and career risks taken by brave science leaders to champion their cause. The book is a frank revealation on the development of small molecule drugs and therapeutic areas encompassing Cimetidine, Clozapine, Clonidine, Atenolol, Ibuprofen, Rifampin, Cefoxitin and other standout (then) new therapies that ushered in the halcyon Era of drug development. This is an absolute must read to give perspective and credence to how strong leadership and persistence on the basic research level paid off
ROGI

Permalink to Comment

19. Anonymous on August 19, 2013 1:15 PM writes...

Although I do agree that there is truth in his statement about "bloated process and downright hostile-to-innovation climate for FDA drug approvals" I think his conclusion on that being answer for lack of drug innovation is going way too far. While a significant contributing factor to assign as major cause is too reductionist (or bottom-line with faulty weighting). The FDA bureaucracy has indeed grown largely unchecked while the mission has expanded and resources inadequate or unfocused. The often mentioned high costs of Phase 3s probably is due to "extreme" FDA requirements. I am less sure about "this day and age" portion as I hope the many words and promises in recent times will help streamline demands and enable cooperation between the industry and FDA. It is too soon to tell and I remain skeptical that either side can really take positive advantage because of past antagonism, public pressures and general nature of the tasks and relationship.

I would suggest there are a number of elements that have made R&D cost so high or weakened innovation that to point only to a single item as being responsible will never capture essence of the issue. #5 BM makes an important observation about lack of leadership and change of focus from science as major issue inhibiting progress and also think others have well pointed out we have been able to increase the knowledge without understanding or effective translations. In many cases R&D became over enamored with the latest shinny new "tools", expected them to give sufficient answers all by themselves, and started to get myopic where ignored other critical aspects or continuing with older models. At the same time no one likes to talk about "Litigation" and although very hard to quantify the Torts/Legal situation has become a definite barrier at times to new drugs being developed.

Permalink to Comment

20. gwern on August 19, 2013 2:04 PM writes...

It's very easy to refute people who claim the FDA is solely the problem and who don't accept any claims about low-hanging fruit or saturation: simply ask why we do not see thousands of blockbuster drugs coming from low-regulation countries like China.

Permalink to Comment

21. Anonymous on August 19, 2013 2:09 PM writes...

@20: Well they did discover the benefits of melamine as an additive to baby milk powder in China. If only the FDA would allow such breakthroughs to pass through in the US.

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22. Bernard Munos on August 19, 2013 2:24 PM writes...

Kelvin,

You can wear it as a badge of honor, because it is.

Permalink to Comment

23. daen on August 19, 2013 2:59 PM writes...

A slight tangent here.

I have quite a lot of sympathy for the FDA, especially the CDRH.

I came to the Bay Area three years ago since when I have mainly worked in regulatory compliance, initially for a company developing a thyroid test which wanted to go the 510(k) route to ensure that whatever happened in the IVDMIA LDT arena would allow their test to be grandfathered in once the dust had settled.

However, it didn't work out; at a meeting in SF in 2011, the 2007 draft guidance document was deemed to not be useful or complete enough to progress and was effectively shelved. Worse, a CDRH-instigated independent review of 510(k) and PMA procedures by the Institute of Medicine effectively declared the process irredeemably broken and suggested a complete overhaul. The company I worked for invested a lot of effort with an end-goal in mind which simply didn't materialize.

Now, I certainly don't blame the FDA. It's been clear that the 510(k) and PMA processes are hopelessly outdated. No-one want to go the PMA route, so you have this rather absurd situation where iPhone apps are going through 510(k) on the basis of equivalency. Really?

The solution is a comprehensive overhaul of the CDRH's remit, and to a certain extent (more pertinent to Derek's initial post) the FDA overall. I stress that I am a big fan of the FDA, but it is severely limited by the FDC Act and its amendments, very few of which, in my opinion, have materially altered the drug or medical device submissions process in a positive way.

Permalink to Comment

24. exGlaxoid on August 19, 2013 3:46 PM writes...

The problem is clearly very complex, but I see many factors. There are MUCH higher expectations of drugs now, once-a-day dosage, no side effects, no herg or P450 effects, high potency, high selectivity, cost, patentability, and more. Also, the long trial time and generic laws have lead to the idea that a drug must make tremendous profits in a short time to be worth developing.

Yet many drugs in the past were approved with major issues: aspirin, acetominophen, naproxen, tagamet, penicillin, AZT, sulfonyl ureas, valium, benedryl, seldane, etc.

Those first generation drugs are either still used or lead to second or third generation drugs that are much better. But now no one can get the first generation drug approved in new categories, so it is nearly impossible to find the 2nd or 3rd generation improved drugs now. AIDS and cancer were the only ones to get there.

I think that there needs to be a shorter, faster way to phase 1 drugs which would allow for some risk, but faster iterations. Also, in the past, death row inmates were used to run phase 1 trials within weeks of making a compound. now it takes years to get there. Also, the commercial people only want to develop block buster drugs-they have killed many great programs due to insufficient profit, long before the concept could really be tested.

Examples of this are drugs against the cold (rotaviruses), obesity, diabetes, and others that never made it to the clinic, but might have lead to better ones once they were used, but the tight regulatory environment killed them long before they had a chance. Maybe as people start ordering unapproved drugs from overseas more often, via the internet, we will see a new version of phase 1 trials occurring. The recreational drugs makers have already been doing this for years, encouraged by Shulgin.

Permalink to Comment

25. srp on August 19, 2013 3:49 PM writes...

One would think chemists would be familiar with the concept of the rate-limiting step. Reforming regulatory policy (the FDA as an organization is mostly an epiphenomenon) is a necessary though not sufficient condition for improving research productivity. Furthermore, much of the managerial risk aversion decried by commenters here is likely caused by the regulatory regime.

It is understandable that the members of a regulated industry fear criticizing the regulator who controls their livelihood, but the attitudes expressed here are disturbingly similar to Stockholm or Battered Spouse syndrome. Everyone has so nicely adapted to the regime, internalized it, and tried to convince himself that all is for the best in this best of all possible regulatory worlds. But you all know better.

Derek himself has written that aspirin would not be approved today and in fact would probably never even be forwarded for clinical trials. To a civilian, that conclusion is devastating to the legitimacy of current regulatory policies and institutions, but none of the insiders seem to bat an eye.

Fairly strong evidence shows that off-label uses of drugs are not worse on safety and efficacy than on-label uses, but the obvious conclusion is never drawn, at least in public, by the pharmaceutical industry.

Everybody knows that "me-too" drugs that get rejected because they test out no better than the standard therapy averaged across the whole population actually have better side-effects and/or efficacy on clinically accessible sub-populations (e.g. by prescribing different drugs when the first one is unsatisfactory). But no one calls BS.

Instead we get battered spouse excuses: "It's our fault for not keeping a tidy NDA," "The real problem is MBAs meddling in our marriage," "We need to try harder to make the relationship work," "When he's in a good mood he's really nice." If it were only the spouse (shareholders and industry members) suffering the abuse, the spectacle wouldn't be so nauseating. But the children (patients) are also affected by this failure to leave and find a shelter.

Permalink to Comment

26. TheScarletPimple on August 19, 2013 3:52 PM writes...

Dilbert, as always, says it all about Six/Lean Sigma, Keizen and other such afflictions:


http://www.leanblog.org/2011/06/a-collection-of-dilbert-cartoons-on-lean-andor-six-sigma/

Permalink to Comment

27. Nuclear Option on August 19, 2013 9:24 PM writes...

The cure for these diseases will not be found on Easy Street, where most drug discovery efforts reside. Who would dare innovate in a corporate structure that so rewards incremental progress (think PFS as an endpoint and the nature of the druggability colloquialism) and so abjectly fires discovery scientists (site by site)? Our community must own up to its foreshortened discovery horizons, among other noted barriers above. But it is surely the pervasive culture of risk aversion that is most ironic and responsible for the slow path to cure.

Permalink to Comment

28. Kaleberg on August 19, 2013 10:56 PM writes...

Whenever I see the argument that all sorts of diseases are being left untreated because of a failure of regulation or business practice, I start wondering exactly what compounds, treatments or ideas are sitting unused due to FDA meddling, unimaginative executives or overly cautious marketing concerns. Is there a list? Surely someone has published something, perhaps on the internet, like the early 1960s DMSO classic, A Remarkable Drug Has Beeb Overlooked. (I may have misremembered the title, but I'm pretty sure it was self published. A friend of the family, a pharmacist, says some guy walked in and gave him a copy.)

I often hear of great new targets and great new ideas, and piles of cash and years of effort seem to follow. Usually the noble seed seems to wither as it sprouts. Sometimes a new drug or treatment emerges, but with limited applicability. Usually the problem is that getting the approach to work is hard. Tumors fight back. Small molecules are too fussy and not fussy enough. Bacteria are nasty pieces of work. The situation is more complicated than it appeared. Sometimes there are troubling side effects.

We're at that awkward stage, still discovering elements, but miles from a periodic chart, and even farther from an even basic understanding of what we are learning. Still, we do seem to be moving forwards, at least for now.

Permalink to Comment

29. Anonymous on August 20, 2013 5:07 AM writes...

@28: I would imagine the number of "false negatives", good drugs which are lost in discovery and development, greatly outweigh the number of approved drugs, purely by statistics. But, without better, more reliable and cost effective ways to demonstrate their potential before the seeds of management doubt set in, what else can we do? Surely nobody would suggest trying to push every potential drug as far as it will go, we simply couldn't afford it, and efficiency would drop much further.

The problem with picking out examples (as some commenters have done above) of great drugs that made it despite management decision to stop development, is that this is anecdotal, and there will be many more examples where the decision to stop was the right one. Thus, we need to look at the bigger picture with a statistical approach.

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30. kemist on August 20, 2013 7:11 AM writes...

We are "very much further along". We've discovered that we can't throw the kind of poisonous crap into the market that we did before.

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31. kemist on August 20, 2013 7:12 AM writes...

We are "very much further along". We've discovered that we can't throw the kind of poisonous crap into the market that we did before.

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32. CP_Future on August 20, 2013 9:21 AM writes...

Most people here don't seem to understand, that innovation comes from innovators, not big pharma companies, which have to earn the 5 billion they just invested per drug because of FDA regulation.

In 1917 we isolated e. coli Nissle from a soldier in WW I. Mutaflor is still used today for treatment of ulcerative colitis. You might think, that 100 years later we know most things about every bacterial strain in our body and have access to dozens of other therapeutic strains. But nothing happened. Instead of this we fill poo from one person into another and call it fecal transplant. These transplants unfortunately work damn well so one might ask: What the hell have drug developers been doing the last century? Have they been sleeping? Why can't a scientist isolate strains on his own and sell them on a free market? Regulation is the culprit, not in this field alone but in most other fields as well. You can buy batteries and drink battery acid but you are not allowed to develop drugs, that actually could help people. A free human being can decide on his own, if he takes a new drug or not. He doesn't need FDA regulation to tell him.

Permalink to Comment

33. daen on August 20, 2013 1:05 PM writes...

@32: "A free human being can decide on his own if he takes a new drug or not. He doesn't need FDA regulation to tell him."

True enough. But if, and only if, he has full access to every piece of information available on that drug. In a world without regulation, no company is compelled to release that information in full, so our hypothetical free human being is unable to make a fully informed choice and your Libertarian Wonderland (unsurprisingly) falls apart at the simplest challenge.

Permalink to Comment

34. sgcox on August 20, 2013 4:13 PM writes...

So according to the original postulate, FDA is an evil force that stops new drugs. Fine, but surely nothing can stop this miracle cure to become a wonder drugs outside of the FDA land. Europe ?, China ? India ? on and on. Please can anybody give me a single example of a medicine rejected by FDA which became a wonder drug for the rest of 91% of humankind ?
Not a single one ? No ? Pity.

Permalink to Comment

35. srp on August 20, 2013 4:33 PM writes...

@34: A reasonable regulatory regime is a necessary but not sufficient condition for innovation to improve. You also need an affluent market of private payers who would be the demand for these innovative products. Unfortunately, the current world situation accompanies the only suitable markets with unsuitable regulations.

@33: The informational standard you propose is so rigorous that not even the present system meets it. A system of certification rather than licensing could accomplish all the informational tasks you want without the coercion side-effects.

Permalink to Comment

36. Doug on August 21, 2013 3:48 AM writes...

So why does the FDA exist?
Bad/Junk products and contaminated food were freely available and foisted on the public.
We used the products (mostly because we believe advertising and magic thinking).
Bad things happened.
We the People were outraged and asked our congresscritters to 'fix the problem'.
Poof...FDA (*)
As each new 'bad thing' happens, the cycle repeats with new regs and more restrictive practices.
We the People can either accept more risk and ask for a reduction in regulatory oversight, OR companies can stop trying to sell crap that harms people.

Guess what I'm betting (continues to) happen?

(*) see also TSA...

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37. Anonymous on August 21, 2013 6:02 AM writes...

What amazes me is how many people consider the FDA as a barrier, and approvals as the ultimate goal of drug development.

Our ultimate goal is to create value by delivering safe and effective medicines to patients. In that regard, we are completely aligned with the goals of the FDA, and vice versa.

One day, we might just learn to appreciate this, and work more closely in partnership with the FDA to focus on doing something useful for patients.

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38. Fred on August 21, 2013 12:21 PM writes...

The FDA, surely, is the biggest problem with the industry. Poor management in pharma, in part, is a response to the FDA' s CYA (instead of help the patient) attitude. Chicken or egg-- which came first?

You KNOW the FDA is the problem by just looking at the obesity TA. They set the safety bar so incredibly high nobody wants to be in that space anymore.

That said, appropriate regulation is a must; you need some oversight to keep toxic/ ineffective junk off the market. We just deserve much better than what we've got now.

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39. kez on August 21, 2013 12:27 PM writes...

@5. Bernard Munos, you say that a reaction against the "process culture" led to increased innovation and "more and better drugs". I don't believe that the majority of late-stage drug candidates in the public domain now could possibly have been discovered within the last 5 years, at which time this process culture you decry was in full flow. Your criticism may be justified to some extent, but don't try to use recent drug discoveries as part of that argument.


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40. CP_Future on August 24, 2013 3:42 PM writes...

@#33: "In a world without regulation, no company is compelled to release that information in full, so our hypothetical free human being is unable to make a fully informed choice and your Libertarian Wonderland (unsurprisingly) falls apart at the simplest challenge."

My "Libertarian Wonderland" still exists but thanks for your opinion. In a free world no patient can be forced to take new drugs. If a patient feels, that the information provided by a pharma company is not enough, he will not take the drug. I don't know about you, but in a libertarian world, I would only take new drugs, if the pharma company has my trust or my level of suffering is high enough and there are no lower risk alternatives.

As I said before, if you start noticing that filling poo from one person into another works better that most approved drugs, something clearly is wrong. Especially when we have the year 2013. What have we been doing the last 50 years?

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