Verrica Pharmaceuticals · VP-102 · Sep – Nov 2021
What were the “Human Factor comments” the FDA's second letter said would follow separately?
The September 2021 letter deferred labeling and human factors comments to separate correspondence. Verrica's 8-K that week describes a contract manufacturer's facility; a General Advice Letter on the user interface appears in its November filings.
EphemerisX Research · Published · 6 source documents · 1 min read
Short answer
The second letter said labeling and human factors comments “will be conveyed in a separate correspondence.” Verrica's November 2021 filings identify a General Advice Letter of September 22, 2021 “with recommendations to improve YCANTH’s user interface,” and its presentation says the November resubmission also addressed those recommendations.
What the evidence shows
The thread starts in 2020. The first letter asked for device design changes to optimize applicator use along with other revisions to the product user interface
FDA · Jul 13, 2020 · p. 15 and said Please note we will need 60 days to review and provide comments on the HF validation study protocol.
FDA · Jul 13, 2020 · p. 15 By November 2020 Verrica reported We have also received feedback from the FDA on our Human Factors study protocol, and believe we have clear alignment on the path forward to resubmit the NDA
8-K · Nov 9, 2020.
The second letter, signed 09/16/2021
FDA · Sep 16, 2021 · p. 11, includes under additional comments: Labeling and Human Factor comments and recommendations will be conveyed in a separate correspondence.
FDA · Sep 16, 2021 · p. 9
Verrica's 8-K of September 20, 2021 describes the letter as identifying deficiencies at a facility of a contract manufacturing organization
8-K · Sep 20, 2021 and says The FDA did not identify any clinical, safety or product specific chemistry, manufacturing, and controls deficiencies related to the NDA.
8-K · Sep 20, 2021 The September 20, 2021 8-K does not mention human factors, the user interface, labeling or an advice letter. 8-K · searched
The quarterly report of November 12, 2021: Following the CRL, on September 22, 2021 Verrica received a General Advice Letter from the FDA with recommendations to improve YCANTH’s user interface.
8-K · Nov 12, 2021
Two descriptions of the resubmission were filed together on November 29, 2021. The 8-K: The resubmission is limited to those sections and elements of the NDA that were identified as deficiencies in the Complete Response Letter issued by the FDA in September 2021.
8-K · Nov 29, 2021 The presentation attached to it: the resubmission is limited to address the successful resolution of inspection deficiencies identified at the CMO in the CRL, as well as the recommendations included in the General Advice Letter
8-K · Nov 29, 2021.
The General Advice Letter is known here only through Verrica's filings.
Follow the thread
- What did the FDA's first letter on VP-102 object to?60 days to review the HF protocol
- Why did the FDA's second letter turn on a contract manufacturer's facility?Resubmitted November 24, 2021
- How did Verrica's account of its three FDA letters change from 2020 to 2022?“No clinical, safety or product specific” deficiencies
- What happened to the glass ampule the FDA flagged in 2020?FDA feedback on the Human Factors protocol
This investigation connects to
- What happens after a second FDA Complete Response Letter?Cross-investigation · Divergent outcome · with Aldeyra Therapeutics, CorMedix, Outlook Therapeutics, Replimune
- What happens when an FDA letter turns on a contract manufacturer, not the drug?Cross-investigation · Shared concern · with CorMedix
- What did “no efficacy or safety issues” cover in these FDA letter announcements?Cross-investigation · Shared concern · with CorMedix, Replimune
The documents, by date
The passages quoted
FDA Complete Response Letter, July 13, 2020 · page 15
We recommend you submit your revised HF validation study protocol for feedback from the Agency before commencing the study. Please note we will need 60 days to review and provide comments on the HF validation study protocol. Plan your development program timeline accordingly.Open at the source →
FDA Complete Response Letter, July 13, 2020 · page 15
In summary, we remain concerned that your proposed cantharidin combination product is not safe for use by HCPs. We are concerned that the risk of accidental exposure will outweigh the benefit of the treatment with this combination product. Inherent design issues exist with this product that may contribute to serious harm if accidental exposure occurs during use. Thus, additional mitigation strategies are needed and could include the need for device design changes to optimize applicator use along with other revisions to the product user interface taking into consideration our previously identified concerns and the data collected from your HF validation study. After you implement additional risk mitigation strategies/modifications, we recommend you conduct an additional HF validation study to ensure that these modifications address the observed use errors and use difficulties and do not introduce any new risks.Open at the source →
Verrica Pharmaceuticals Form 8-K, filed November 9, 2020
We have also received feedback from the FDA on our Human Factors study protocol, and believe we have clear alignment on the path forward to resubmit the NDA, which we anticipate in the first quarter of 2021.Open at the source →
FDA Complete Response Letter, September 16, 2021 · page 9
ADDITIONAL COMMENTS Labeling and Human Factor comments and recommendations will be conveyed in a separate correspondence.Open at the source →
FDA Complete Response Letter, September 16, 2021 · page 11
KENDALL A MARCUS 09/16/2021 02:20:43 PMOpen at the source →
Verrica Pharmaceuticals Form 8-K, filed September 20, 2021
The September 20, 2021 8-K does not mention human factors, the user interface, labeling or an advice letter.
Open the document →Verrica Pharmaceuticals Form 8-K, filed September 20, 2021
announced that it received a complete response letter from the U.S. Food and Drug Administration (the “ FDA ”) identifying deficiencies at a facility of a contract manufacturing organization for its New Drug Application (the “ NDA ”) for VP-102 for the treatment of molluscum contagiosum. The identified deficiencies do not specifically relate to the manufacturing of VP-102, but instead raise general quality issues at the facility. The FDA did not identify any clinical, safety or product specific chemistry, manufacturing, and controls deficiencies related to the NDA.Open at the source →
Verrica Pharmaceuticals Form 8-K, filed November 12, 2021
On September 20, 2021, Verrica announced that the U.S. Food and Drug Administration (“FDA”) issued a Complete Response Letter (“CRL”) regarding its New Drug Application (“NDA”) for VP-102 (cantharidin 0.7% Topical Solution) for the treatment of molluscum contagiosum (“molluscum”). According to the CRL, the FDA identified deficiencies at a facility of a contract manufacturing organization (“CMO”), which were not specifically related to the manufacturing of VP-102 but instead raised general quality issues at the facility. The FDA did not identify any clinical, safety or product specific Chemistry, Manufacturing, and Controls (“CMC”) deficiencies related to VP-102. Following the CRL, on September 22, 2021 Verrica received a General Advice Letter from the FDA with recommendations to improve YCANTH’s user interface.Open at the source →
Verrica Pharmaceuticals Form 8-K, filed November 29, 2021
On November 29, 2021, the Company announced that it has resubmitted the New Drug Application (the “ NDA ”) for VP-102 for the treatment of molluscum contagiosum to the U.S. Food and Drug Administration (the “ FDA ”). The resubmission is limited to those sections and elements of the NDA that were identified as deficiencies in the Complete Response Letter issued by the FDA in September 2021.Open at the source →
Verrica Pharmaceuticals Form 8-K, filed November 29, 2021
Verrica received a Complete Response Letter (CRL) from the FDA on September 17, 2021 due to open general inspection items at a contract manufacturer (CMO) that were not specific to VP-102. The Company received a General Advice Letter (GAL) from the FDA on September 22, 2021 with recommendations to improve VP-102’s user interface. On November 5, 2021 Verrica was notified that the inspection of the CMO was classified as “voluntary action indicated” (“VAI”), is now closed and that the VAI classification will not directly negatively impact FDA’s assessment of the Company’s NDA. Verrica resubmitted the NDA for VP-102 on November 24, 2021; the resubmission is limited to address the successful resolution of inspection deficiencies identified at the CMO in the CRL, as well as the recommendations included in the General Advice Letter.Open at the source →