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      Drugs and Devices : Comparison of European and U.S. Approval Processes

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          Summary

          The regulation of medical drugs and devices involves competing goals of assuring safety and efficacy while providing rapid movement of innovative therapies through the investigative and regulatory processes as quickly as possible. The United States and the European Union approach these challenges in different ways. Whereas the United States has always relied on a strictly centralized process through 1 agency, the Food and Drug Administration (FDA), the European Commission synchronized the regulations of 28 different countries as they combined to create the European Union. The FDA historically developed as a consumer protection agency, whereas the regulations from the European Commission arose out of a need to harmonize inter-state commercial interests while preserving national “autonomy.” Thus, whereas the FDA has the advantages of centralization and common rules, the European Union regulates medical drug and device approvals through a network of centralized and decentralized agencies throughout its member states. This study explores some of the similarities and differences in European and U.S. regulation of drugs and devices, and discusses challenges facing each.

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          Publication Bias: A Problem in Interpreting Medical Data

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            Regulatory review of novel therapeutics--comparison of three regulatory agencies.

            The upcoming reauthorization of the Prescription Drug User Fee Act focuses on improving the review process for new drug applications at the Food and Drug Administration (FDA). Using publicly available information from the FDA, the European Medicines Agency (EMA), and Health Canada, we compared the time for completion of the first review and the total review time for all applications involving novel therapeutic agents approved by the three regulatory agencies from 2001 through 2010 and determined the geographic area in which each novel therapeutic agent was first approved for use. There were 510 applications for novel therapeutic agents approved from 2001 through 2010--225 by the FDA, 186 by the EMA, and 99 by Health Canada; among the applications, there were 289 unique agents. The median length of time for completion of the first review was 303 days (interquartile range, 185 to 372) for applications approved by the FDA, 366 days (interquartile range, 310 to 445) for those approved by the EMA, and 352 days (interquartile range, 255 to 420) for those approved by Health Canada (P<0.001 for the comparison across the three agencies). The median total review time was also shorter at the FDA than at the EMA or Health Canada (P=0.002). Among the 289 unique novel therapeutic agents, 190 were approved in both the United States and Europe (either by the EMA or through the mutual recognition process), of which 121 (63.7%) were first approved in the United States; similarly, 154 were approved in both the United States and Canada, of which 132 (85.7%) were first approved in the United States. For novel therapeutic agents approved between 2001 and 2010, the FDA reviewed applications involving novel therapeutics more quickly, on average, than did the EMA or Health Canada, and the vast majority of these new therapeutic agents were first approved for use in the United States. (Funded by the Pew Charitable Trusts.).
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              Regulation of medical devices in the United States and European Union.

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                Author and article information

                Contributors
                Journal
                JACC Basic Transl Sci
                JACC Basic Transl Sci
                JACC: Basic to Translational Science
                Elsevier
                2452-302X
                29 August 2016
                August 2016
                29 August 2016
                : 1
                : 5
                : 399-412
                Affiliations
                [1]Department of Anesthesiology and Pain Medicine, University of Washington, Seattle, Washington
                Author notes
                [] Reprint requests and correspondence: Dr. Gail A. Van Norman, Department of Anesthesiology and Pain Medicine, University of Washington, 2141 8th Avenue W, Seattle, Washington 98119. lbsparrow@ 123456yahoo.com gvn@ 123456uw.edu
                Article
                S2452-302X(16)30063-8
                10.1016/j.jacbts.2016.06.003
                6113412
                30167527
                a25b515d-972e-4082-b563-05cc67196779
                © 2016 The Author

                This is an open access article under the CC BY-NC-ND license (http://creativecommons.org/licenses/by-nc-nd/4.0/).

                History
                : 21 June 2016
                : 21 June 2016
                Categories
                TRANSLATIONAL TOOLBOX

                device approval,drug approval,ema,european commission,fda,bmj, british medical journal,ce, conformité européenne,dad, drugs and devices,ec, european commission,ema, european medicines agency,eu, european union,fda, food and drug administration,mhra, medicines and healthcare products regulatory agency,nb, notified bodies,pma, pre-market approval

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