Regulatory Open Forum

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  • 1.  Repurposing generic drugs

    Posted 10-Apr-2015 16:34
    Dear regulatory professionals,

    I hope this finds you well. Could you advise me on the differences in the pathways that are required to approve generic drugs for new indications (between rare and common diseases (>200,000 people))? Do you see financial incentives in doing so despite off-label use?

    I am working on a NSF project initiative and hope to get some guidance.

    Thank you for your advice.

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    Hoi I (Queenie) Cheong
    PhD Candidate
    Cleveland OH
    United States
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  • 2.  RE: Repurposing generic drugs

    Posted 11-Apr-2015 07:43
    The required pathway for a change or addition to indications is a 505(b)(2).

    The problem with adding indications to a generic drug you will have to have a named generic in order to get the docs to write the prescriptions with your products name. Otherwise if he writes the generic name and it can go to any company with the approved generic. If it were my money I would file a 505(b)(1) with a new CMC section, with a branded name and the new clinical indication.

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    John Lay
    Director, Regulatory and Quality
    Vistapharm Inc.
    Largo FL
    United States
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  • 3.  RE: Repurposing generic drugs

    Posted 11-Apr-2015 20:40
    505(b)(2) might help you expedite your NDA, but to be clear, generic drugs are approved under 505(j), not 505(b)(2). A 505(b)(2) application is still a New Drug Application.  http://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm079345.pdf

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    Andrea Chamblee RAC, FRAPS
    FDA
    Silver Spring MD
    United States
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  • 4.  RE: Repurposing generic drugs

    Posted 13-Apr-2015 13:04
    The advice is correct.  You cannot get a "new" indication for a drug via the 505j (ANDA) approval pathway.  A new indication -- even for an "old" drug -- makes the application "new."  Thus, you'd have to file an NDA.  In general, filing an NDA, whether via 505(b)(1) or 505(b)(2), will mean some significant investment into clinical study, the 505(b)(2) pathway simply allowing you to reference the drug product that is already on the market for information that may be supportive such that you would not have to repeat the work (e.g. pre-clinical safety).  There is an FDA guidance document regarding the 505(b)(2) pathway you may want to review.  While your approval may in fact give only you the legal right to then market your drug for this new indication (regardless of the branded name you decide to use), there is nothing to stop physicians from prescribing the drug by chemical name only such that patients could be given the generic at a much lower price.  All this to say you really need to do your homework on the return on investment.  

    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@coastalpharmaconsultants.com
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  • 5.  RE:Repurposing generic drugs

    Posted 11-Apr-2015 12:11
    Generic drugs are never approved for "new indications." They are labeled as the reference drug is labeled. To be labeled for a New Indication, an NDA would be required. Then it would no longer be a generic drug. http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm064995.htm

    This information is obtained and shared as a JOB professor in regulatory affairs, nor as as an FDA employee.
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    Andrea Chamblee RAC, FRAPS
    FDA
    Silver Spring MD
    United States
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  • 6.  RE: Repurposing generic drugs

    Posted 14-Apr-2015 11:44
    Spell check changed JHU to JOB in this message - I am a Johns Hopkins University (JHU) adjuncy professor.

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    Andrea Chamblee RAC, FRAPS
    FDA
    Silver Spring MD
    United States
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  • 7.  RE: Repurposing generic drugs

    Posted 14-Apr-2015 11:51
    Your keyboard may have changed from "adjunct" to "adjuncy" as well.

    It was fun, good to read "job professor" than JHU (Adjunct) Professor.   

    D