Regulatory Open Forum

 View Only
  • 1.  Size,shape & physical attributes of Tablet-ANDA submission

    Posted 12-Feb-2018 10:05

    Dear Members,
    As per guidance on Size, Shape, and Other Physical Attributes of Generic Tablets and Capsules,

     If the RLD is less than 17 mm in its largest dimension, the generic product should be:

    • No more than 20 percent larger than the RLD in any single dimension (the resulting single dimension of the generic should not exceed 17 mm).
    • No more than 40 percent larger than the volume of the RLD.

    If the RLD is equal to or greater than 17 mm in its largest dimension, the generic product should be:

     

    • No larger than the RLD in any single dimension.
    • No larger than the volume of the RLD.

     We have conducted the physical characterization of the RLD. The shape of both RLD & Proposed Test product is same. Whereas thickness is slightly higher than the RLD. Please see the below table for more details

     

    Tablet

    RLD

    TEST PRODUCT(GENERIC)

    L(mm)

    W(mm)

    T(mm)

    V

    L(mm)

    W(mm)

    T(mm)

    V

    1

    19.14

    10.55

    6.81

    1375.12

    19.06

    10.56

    7.00

    1408.9

    2

    19.15

    10.56

    6.77

    1369.06

    19.07

    10.54

    6.98

    1402.96

    3

    19.16

    10.57

    6.80

    1377.14

    19.05

    10.54

    6.97

    1399.49

    Avg.

    19.15

    10.56

    6.79

    1373.7

    19.06

    10.546

    6.983

    1403.6

     

    L= Length, W=Width, T=Thickness, V=Volume

     Please note that calculation of volume has carried out based on Physical measurements. 

    Is it acceptable to file the ANDA with the above trade dress where the volume of Generic product is larger than the RLD?



    ------------------------------
    Thanks & Best regards

    Rajib Kumar Baishnab
    Manager, Regulatory Affairs
    The ACME Laboratories Ltd.
    Dhamrai, Dhaka-1350, Bangladesh
    Ph: +8801990-407587
    Email: rbaishnab.qo@acmeglobal.com
    ------------------------------


  • 2.  RE: Size,shape & physical attributes of Tablet-ANDA submission

    Posted 13-Feb-2018 09:48
    If length was less than 17 mm than calculated volume does not matter.

    But its more than 17 mm hence proposed product dimensions are not advisable to file as its higher in volume. 

    volume represents the over all dimensions for oral dosage form to take into consideration.

    ------------------------------
    Gaurang Bhavsar, MS, RAC
    Manager, R&D and RA
    Sunrise Pharmaceutical, Inc.
    Rahway, NJ 07065
    USA
    ------------------------------



  • 3.  RE: Size,shape & physical attributes of Tablet-ANDA submission

    Posted 20-Feb-2018 05:11
    Dear Mr. Gaurang Bhavsar,

    Thank you very much for your kind reply.
    So far I know, GPhA is also concern about the requirement of this size, shape and other physical attributes guidance of Generic tablets & Capsules and they also made comments on FDA Docket No. FDA-2013-N-1434 about this guidance that, "generic drugs must mimic the reference listed drug in size and shape, has no basis of law" & also so far I know there are no RTR issues described in the guidance due to change of size & shape with respect to RLD.

    Under the above circumstances, if the volume of the generic tablet is slightly higher (i.e. 0.71% ) than RLD, then what additional documents FDA might ask to justify this changes.Do you have any idea about the expectation from the agency? 


    ------------------------------
    Thanks & Best regards

    Rajib Kumar Baishnab
    Manager, Regulatory Affairs
    The ACME Laboratories Ltd.
    Dhamrai, Dhaka-1350, Bangladesh
    Ph: +8801990-407587
    Email: rbaishnab.qo@acmeglobal.com
    ------------------------------



  • 4.  RE: Size,shape & physical attributes of Tablet-ANDA submission

    Posted 26-Feb-2018 10:16
    In the guidance its recommended that if your size go beyond the recommendation you need to contact OGD. In this case you can to "controlled correspondence" for the size issue. this is the best approach but it time consuming as well.

    In justification you can provide
    1) your comparison table - proposed vs RLD;
    2) dissolution profile data for therapeutic equivalence;
    3) reference generic products that have more than 17 mm size;
    4) reference literature that supports same size and higher volume has minimmum impact on drug product quality and patient acceptance.

    ------------------------------
    Gaurang Bhavsar, MS, RAC
    Manager, R&D and RA
    Sunrise Pharmaceutical, Inc.
    Rahway, NJ 07065
    USA
    ------------------------------