BIO submitted comments to the Office of the United States Trade Representative (USTR) and the inter-agency Section 301 Committee regarding the investigation, initiated on August 18, 2017, by USTR under section 302(b) of the Trade Act of 1974, as amended, to determine whether acts, policies, and practices of the Government of China related to technology transfer, intellectual property, and innovation are unreasonable or discriminatory and burden or restrict U.S. commerce.

BIO submitted comments on the Food and Drug Administration’s (FDA) Draft Guidance, Formal Meetings Between the Food and Drug Administration and Sponsors or Applicants of Prescription Drug User Fee Act Products. The Prescription Drug User Fee Act (PDUFA) meeting structure fosters robust communication between the FDA and industry and promotes biomedical innovation. Formal, face-to-face meetings – along with other types of communication like well-written responses, phone calls, and emails – are critical for aligning on complex scientific matters throughout the drug development process. With clarifications, this guidance could be a helpful tool for sponsors to engage in more productive discussions with the FDA. BIO requests clarifications on surrogate endpoint/biomarker Type C meetings, background package contents, whether FDA welcomes discussion of emerging data sources (patient experience data, novel trial designs, real-world evidence), preliminary responses to sponsors, and meeting timelines, among other issues.  

BIO is greatly concerned by the Department of Justice's and Environmental Protection Agency's proposed Settlement Agreement to resolve a dispute about the PES Holdings' obligations under the Renewable Fuel Standard.

BIO submitted comments on the Food and Drug Administration’s (FDA) Draft Guidance, Chemistry, Manufacturing, and Controls Changes to an Approved Application: Certain Biological Products. BIO supports the FDA’s efforts to update and replace the 1997 version of this guidance, and suggests the FDA revise the guidance entitled Changes to an Approved Application for Specified Biotechnology and Specified Synthetic Biological Products, which is also dated July 1997. BIO appreciates the inclusion of cellular, gene, and cell-based gene therapy products in the scope but notes some of these products are excluded as exceptions in certain examples in the appendix. BIO’s comments include suggested changes to promote the longevity of the guidance, make terminology more consistent, and promote continuity and consistency across various guidelines.

BIO submitted comments on the Food and Drug Administration’s (FDA) public meeting on Promoting the Use of Complex Innovative Designs in Clinical Trials. BIO supports the development and launch of this initiative. BIO shares the FDA’s goals for the pilot program to promote public learning about Innovative Clinical Trial Design (ICTD) and to demonstrate the use of novel designs to increase the efficiency and/or feasibility of clinical development. The pilot program will present multiple opportunities for public learning and the advancement of ICTD. To advance the successful implementation of the ICTD Pilot Program, BIO developed recommendations on the timelines, communication, and disclosure of information, among other issues. BIO’s comments also include high-level case studies of innovative clinical trial designs which have historically shown low levels of regulatory, in an effort to provide insight into the general types of innovative clinical trial designs BIO would like to see in the pilot program.