Taking a Drug Rx
to OTC


Expert tips from
scientists and marketers

  • Prepare early for the Advisory Committee hearing; listen closely to what the FDA is telling you; anticipate all negative questions and formulate data-based answers;
  • Frankly analyze the issues and concerns raised by the switch;
  • Develop a clear, compelling story and the data to support it–taking into account that the switch needs to be positioned as addressing a public health need;
  • Solicit outside expertise and views, including negative ones, to broaden perspective and strengthen your arguments;
  • Reach out to thought leaders and stakeholders: listen to their issues, explain your approach, collaborate on solutions;
  • When applicable prepare a public health education program to provide behavioral support for your product; and
  • Consider a plan for surveillance and behavioral issues management.



Advisory Committee Votes
Orlistat “Approvable”


GlaxoSmithKline recently received an “approvable” letter from the FDA for OTC orlistat – a huge coup for GSK Consumer Healthcare. Alli (OTC orlistat’s brand name) will be the only FDA-approved weight loss drug available without a prescription and the first Rx drug to go OTC since Procter & Gamble’s Prilosec in 2003.

On the morning of January 23, 2006, Dr. Vidhu Bansal, Director of Medical Affairs for GlaxoSmithKline Consumer Healthcare, prayed for strength and wisdom. Boston University obesity expert Dr. Caroline Apovian prayed she wouldn’t pass out on the podium. And GSK’s Vice President of Marketing, Steve Burton, arrived at 5AM, surveyed the room, tested the microphones and carefully arranged four cans of diet soda under his chair.

The three were among the presenters for GSK Consumer Healthcare at the FDA Advisory Committee hearing on GSK’s bid to market an over-the-counter version of Roche’s prescription weight loss drug orlistat.

“OTC orlistat is potentially the biggest commercial opportunity ever for GSK Consumer Healthcare,” said Dr. John Dent, Sr. VP of Research and Development , OTC orlistat project leader and lead presenter at the hearing. “Naturally we were feeling quite a bit of pressure.”

“In today’s climate of heightened concern about drug safety and risk versus benefit, getting approval to take an Rx drug over-the-counter is pretty difficult in general and every project has its own unique challenges,” said Dr. Dent.

Recognizing the challenges, Dent began to prepare for the Advisory Committee hearing seven months before the scheduled date, building a strong team that integrated both internal and external experts in a variety of disciplines: scientific, regulatory, marketing and communications.

“It’s really important to have many different perspectives every step of the way,” said Burton. “You need to reach early agreement on a strategy and messaging but be willing to continually anticipate arguments and be challenged by people who can tell you when you are ‘drinking your own kool-aid’ too much.”

Challenging sponsors on their messages and their answers to tough questions is part of what 3D Communications does for pharmaceutical and consumer healthcare clients who are appearing before the FDA or its advisory committees. 3D helped GSK formulate communications strategy, messages, presentations and answers to difficult Q&A for the Advisory Committee hearing, coached presenters on effective delivery, and - working with Healthstar Public Relations - trained a variety of orlistat spokespeople for media outreach.

Dr. Saul Shiffman, who presented the data on how consumers would use orlistat in the real world, said the team’s early outreach to thought leaders and stakeholders was key to its success.

“GSK acknowledged every concern and addressed each one with data, expert opinion and plans for education, surveillance and management,” said Shiffman.

It paid off. The Advisory Committee voted 11-3 to recommend for approval. Orlistat was the only first-in-class compound to win a positive recommendation on its first try before an advisory committee in more than a decade.

“Ultimately, given the obesity crisis and orlistat’s outstanding safety profile, the panel concluded that the risk-benefit with orlistat was overwhelmingly on the side of benefit,” said Dent.

So what did they do to celebrate?

Vidhu Bansal went on vacation. Saul Shiffman went to sleep. Steve Burton went out to dinner with his family. And John Dent? He retired -- and will steer his newly purchased 1970-vintage Lotus Elan around a racetrack.

“My retirement was long planned, but what a way to end my 25-year career at GSK,” said Dent. “It’s a wonderful way to move on to the next phase of my life.”

For more information on 3D Communications’ FDA Communications services, contact Cindy DiBiasi at cdibiasi@3dcommunications.us.


Want More Info? Contact us by phone: 917.270.4401
or via email:
jdibiasi@3dcommunications.us


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