Regulatory Open Forum

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  • 1.  505(b)(2) pathway with a different dosage strength from RLD

    Posted 27-Jan-2015 11:10

    I have question regarding product development for mucosal delivery where the comparator (RLD) is an injectable. The intended regulatory pathway is 505(b)(2). Since the comparator is an injectable dosage form, the new dosage strength will be different from the comparator. The plan is to develop appropriate dosage strength to match the PK of the comparator. Is the FDA BE criteria applicable for 505(b)(2) NDA approval when the molar strength of the new dosage form is different from the RLD? Does it require efficacy studies for 505(b)(2) NDA approval of the new film dosage strength?

     Thanks so much for your response to my question.

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    Mercy James PHD, RAC, SCD
    Warren NJ
    United States
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  • 2.  RE: 505(b)(2) pathway with a different dosage strength from RLD

    Posted 27-Jan-2015 17:30
    Mercy,

    injectable vs. tablets/capsules, etc.

    It may be subject to BA differences given the different formulations. It is expected that appropriate BE studies may be needed. It is also possible that a pivotal study may be needed depending upon the drug/formulations/dosage forms.  

    Here are three cases for your consideration at http://wp.me/p4xpOK-IN 

    You may want to communicate with the FDA early in the process with your plan of action.





  • 3.  RE: 505(b)(2) pathway with a different dosage strength from RLD

    Posted 28-Jan-2015 09:06
    A 505(b)(2) requires a pharmacokinetic comparison, but not necessarily BE.  However, you must support the differences in your product from the RLD.  In this case, that would include things like preclinical support on local toxicities and, depending on how much you "match" the PK of the RLD, you indeed may need some clinical support of differences (that would include not just Cmax, Cmin and AUC, but might also include pattern of exposure, depending on the drug in question).


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    Robert Meyer
    Director, Virginia Center for Translational and Regulatory Sciences
    University of Virginia, School of Medicine
    Charlottesville VA
    United States
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  • 4.  RE: 505(b)(2) pathway with a different dosage strength from RLD

    Posted 28-Jan-2015 09:33
    I agree with the previous 2 respondents but carefully consider the route of administration and the the local exposure that might be needed going from an injection to a mucosal exposure.  If this is an acute single administration local non clinical tox might be sufficient but if there is a possibility of repetitive administration by the mucosal route then a clinical safety study in addition to a PK study might be necessary. 

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    John McLane
    VP Clinical Development
    Tolmar, Inc
    Fort Collins CO
    United States
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  • 5.  RE: 505(b)(2) pathway with a different dosage strength from RLD

    Posted 28-Jan-2015 12:41

    The below should be helpful.


    http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2010/01/WC500070039.pdf
    Non-oral immediate release dosage forms with systemic action

    This section applies to e.g. rectal formulations. In general, bioequivalence studies are required. A

    biowaiver can be considered in the case of a solution which contains an active substance in the same

    concentration as an approved solution and with the same qualitative and similar quantitative

    composition in excipients (conditions under oral solutions may apply in this case).

    Parenteral solutions

    Bioequivalence studies are generally not required if the test product is to be administered as an

    aqueous intravenous solution containing the same active substance as the currently approved product.

    However, if any excipients interact with the drug substance (e.g. complex formation), or otherwise

    affect the disposition of the drug substance, a bioequivalence study is required unless both products

    contain the same excipients in very similar quantity and it can be adequately justified that any

    difference in quantity does not affect the pharmacokinetics of the active substance.

    In the case of other parenteral routes, e.g. intramuscular or subcutaneous, and when the test product is

    of the same type of solution (aqueous or oily), contains the same concentration of the same active

    substance and the same excipients in similar amounts as the medicinal product currently approved,

    bioequivalence studies are not required. Moreover, a bioequivalence study is not required for an

    aqueous parenteral solution with comparable excipients in similar amounts, if it can be demonstrated

    that the excipients have no impact on the viscosity.


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    Jim Bonner PHD
    The One When
    Collegeville PA
    United States
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  • 6.  RE: 505(b)(2) pathway with a different dosage strength from RLD

    Posted 29-Jan-2015 16:09
    Mercy,

    I just lived through this scenario for a product that was a change in formulation from an RLD.  In the end, we decided to abandon the 505(b)(2) approach because the work needed to "bridge" the differences in drug substance and drug product from the RLD was significant and challenging. In the end we had to do pivotal clinical studies to support safety and efficacy and could not rely on the RLD  for all or even part of the required information for approval.   As you know, the 505(b)(2) approach is to support modification of an RLD so as indicated a PK/PD study or studies is more likely than a BA/BE used for generic equivalence.  Typically for a 505(b)(2) as indicated,  every change from the RLD has to be demonstrated to be comparable to the RLD.  If your drug substance profile is not the same (impurities) you will need a head to head toxicology study in an appropriate species or studies with both products.  Then you have to link these results to the product;  if the DS differences translates to drug product difference, you'll need a head to head comparability study CMC and then bridge the difference is a head to head clinical study (PK/PD and pivotal) in order to use the RLD information, if at all.  Then you need to look at your label and the RLD label and modify the information as appropriate from all the information you generated. You may be better off as a stand-alone program or find a way to use the nonclinical data (if Drug substance is the same and same profile) for which you are still a 505(b)(2) and conduct a stand alone clinical program relying on your own data for S&E. 

    I would discuss the 505(b)(2) pathway with your review division as early as possible as identifying the data required to use the RLD data vs. not is important.  Key is to identify which data you plan to rely on how.  FDA will help you identify the types of studies and provide feedback on the pathway.  Luckily we received FDA feedback early in our development plan before we initiated our Phase 3 pivotal studies.

    We had to conduct our own PK/PD and pivotal studies along with key toxicology studies.  As you already know the CMC section will be different and not part of the 505(b)(2) approach.

    Hope this is helpful along with the other comments, Good luck@!

    Dar

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    Darlene Rosario RAC
    Principal Consultant RA, Quality and Compliance
    Velocity Consulting
    Ventura CA
    United States
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  • 7.  RE: 505(b)(2) pathway with a different dosage strength from RLD

    Posted 30-Jan-2015 11:23
    I have worked on many 505(b)(2) projects and essentially agree with all the comments thus far shared and caution to particularly pay attention to this last one from Darlene.  Some of the projects have gone very smoothly with the pathway proving to be fairly straightforward and "quick" while some have died along the way sort of as Darlene has shared.  One has been what the sponsor thought would be a fairly easy development of an oral form of an injectable RLD with the FDA Division wanting significant clinical study with lots of debate (even within the Division) of how best to design the studies.  Lay out a plan and go meet with FDA to get input for sure. 

    Chris

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    Christopher Smith, CQE, RAC
    Coastal Pharmaceutical Consultants, Inc.
    7950 Old River Road
    Burgaw, NC 28425, USA
    910.259.8877 (land)
    910.789.1232 (mobile)
    chrissmith@ec.rr.com
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