“Comparability of biotherapeutic products following manufacturing process improvement. Quality aspects and comparability issues”
Focuses on improvements in manufacturing processes of biotherapeutics
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15. Dr. Inger Mollerup - Novo Nordisk
1. Comparability of biotheurapeutic
products following manufacturing
process improvement
Quality aspects and comparability issues
Inger Mollerup
Corporate Vice President
Regulatory Affairs
Novo Nordisk A/S
2. Manufacturing of biologics: each process is
unique
Transfer
Plasmid
into Host
Cell
Cell culture or
fermentation
Purify Drug
Substance
Formulate
Product for
Use
Downstream
Processing
Clone Gene
into DNA
Vector
Biosimilar
Maybe
A different
formulation
Different
Purification
protocol
Probably
different DNA
vector
Same AA -
maybe same
genetic
sequence
Different
Recombinant
cell system
Different
In-process
controls
Slide no 213 Feb 2013
3. Specifications are linked to the entire manufacturing process (ICH
Q6B)
Cell Bank
Manuf.
process
Drug
substance
Drug
product
Q5B Genetic stab.
Q5B Cell substrate
Q5B Viral safety evaluation
Q6B Specifications of biotech product
Q5B Stability of biotech product
Tox studies
Clinical studies
Biosimilar
Slide
no 3
13 Feb 2013
4. Comparability exercise and Process changes
Change
filter
supplier
Move
equipment
different part
of facility
Move
manufacturing
to new facility
New cell line
New Process
New Formulation
Scale-up
Manufacturing
Manufacturing Change
•Low risk
•Frequent
•Supported
by:
Analytical and
Process Data
•Highest risk
•Rare
•Extensive Data:
Analytical, Process
and Human data
Biosimilars
New:
•DNA?
•Cell line
•Process Technology?
•Fermentation process
•Purification process
•Analytics
•Facilities
•Formulation?
•And - no history
Stepwise Comparability exercise:
Clinical Comparability
Nonclinical Comparability
Chemical Comparability
Character of Change
Complete Comparability
exercise:
Clinical Comparability
Nonclinical Comparability
Chemical Comparability
5. Presentation title Slide no 5Date
How is a biosimilar designed?
Target probably well defined
”Design space”?
6. The Comparability Concept for Biosimilars
Analytical data + nonclinical and clinical data
Innovator Testing Following a Process
Change
Biosimilar
Testing
Pre-change Post-change New process
In process controls
(15 – 50 tests)
In process controls
(15 – 50 tests)
No comparison possible
Process validation
(5 – 15 tests)
Process validation
(5 – 15 tests)
No comparison possible
Stability profile
(25 – 50 tests)
Stability profile
(25 – 50 tests)
No comparison possible
Degradation profile
(25 – 50 tests)
Degradation profile
(25 – 50 tests)
No comparison possible
Drug substance QC
(10 – 25 tests)
Drug substance QC
(10 – 25 tests)
No comparison possible
Drug product QC
(10 – 25 tests)
Drug product QC
(10 – 25 tests)
Drug product QC
(10 – 25 tests)
Non-clinical testing
(tox and others)
Non-clinical testing
(tox and others)
Human studies
Efficacy, safety,
immunogenicity
Human studies
Efficacy, safety,
immunogenicity
Adapted from: T. Lubiniecki (2005)
Manufacturing
Process Steps
Cell expansion
Production
Recovery
Purification
Characterisatio
n
Stability
Drug
Substance
Drug Product
Drug Product
Drug Product
7. Biosimilars, Overview of Scientific/Regulatory Guidelines and Experience, Inger Mollerup Novo Nordisk Slide no 7Oct 08 2009
Innovator examples
8. Biomass
Clear broth with secreted insulin
precursor
Purified insulin precursor
Insulin ester
Insulin ester
Human Insulin (crude)
Purified Human Insulin
Cell removal
Capture process
Purification
Hydrolysis
Purification
Enzymatic conversion
Novo Nordisk
Expression system: S. Cerevisiae
Expressed molecule:
• Insulin precursor (3 AA bridge)
No refolding needed
Different
•HCP’s
•reagents
•solvents
•pH ranges
•etc. etc. etc.
Different
Expression
Systems
Eli Lilly
Expression system: E. Coli
Expressed molecule:
• Pro-Insulin (35 AA bridge)
Unfolding and refolding
Biomass
Inclusion Bodies
Trp-LE'-Met-Proinsulin
Proinsulin (unfolded)
Proinsulin-SSO3
Proinsulin (refolded)
Human Insulin (crude)
Purified Human Insulin
Cell harvesting
Cell disruption
IB recovery
IB dissolution
CNBr cleavage
Oxidative sulfitolysis
Folding, S-S bond formation
Enzymatic conversion
Purification
Biosimilar
Slide
no 8
13 Feb 2013
9. HI derivatives originating from fermentation
Asn
Cys
Tyr
Asn
Glu
Leu
GlnTyrLeuSer
Ile
Cys
Ser
Thr
Cys
Cys
Gln
Glu
Val
Ile
Gly
Pro
Lys
Thr
Tyr
Phe
Phe
Gly
Glu
Arg
Gly
Cys
Leu
Val
LeuAla Tyr
Leu
Glu
Val
His
Cys
Gly
Ser
Leu
His
Val
Gln
Asn
Phe
S
S
S
S S
S
DesPhe(B1)-HI
Thr(A8)-O-mannosyl HI
Thr
DesPhe(B1)-
Val(B2)-HI
B1
A10
A21
B30
B20
B10
A1
Arg
O-Mannosyl
B0Arg-HI
O-Glycosylation site
11. Biosimilar
Pharmacopeia compliance is not a guarantee
Test
Specification Method of Analysis
Identification A by Assay Complies Ph Eur, USP
Identification B by Peptide mapping Complies Ph Eur, USP
Bioidentity ≥15 USP U/mg USP
High molecular weight proteins ≤1.0% Ph Eur, USP
Related proteins:
Insulin human related substances
A21 desamido insulin
human
Insulin human related impurities
≤2.0%
≤2.0%
Ph Eur
Zinc
(calculated on dried basis)
≤1.0% Atomic absorption
Ph Eur
Loss on drying ≤10.0% Ph Eur, USP
Sulphated ash
(calculated on dried basis)
≤2.5% Ph Eur
Microbial control, total viable count ≤300 CFU/g Ph Eur, USP
Bacterial endotoxins ≤10 IU/mg Kinetic chromogenic method
Ph Eur method D, USP
Assay
(calculated on dried basis)
95.0 – 105.0%
≥27.5 USP U/mg
Ph Eur, USP
Slide
no 11
13 Feb 2013
12. Biosimilars, Overview of Scientific/Regulatory Guidelines and Experience, Inger Mollerup Novo Nordisk Slide no 12Oct 08 2009
An Entirely New Manufacturing Process
Novo Nordisk Case Studies
• Insulin Product
• New production cell, DNA, cell bank
• Optimised fermentation, recovery and purification processes
• New facility
• Quality:
• Full CMC + comparability:
Minute differences in impurity profile
• Clinical
• Pharmacokinetics/Dynamics
• Immunogenicity
• FDA
• No safety threshold for new impurities
• Not known when “low” is “low enough”
Even for a small product as insulin, clinical safety studies are
necessary to demonstrate the absence of clinically meaningful
differences
13. Biosimilars, Overview of Scientific/Regulatory Guidelines and Experience, Inger Mollerup Novo Nordisk Slide no 13Oct 08 2009
Haemophilia Product (rFVIIa): Innovator
Process Change Requiring New BLA
Change in host cell line led to change in glycosylation pattern
Human PK study revealed significant difference
• New cell line (CHO) evaluated post
approval and compared with original
cell line (BHK)
• Quality: Comparability data showed
differences in glycosylation
• N-acetyl-galactosamine (GalNAc)
present in BHK-rFVIIa only (~20%)
• Slightly lower content of
terminal sialic acid residues
on BHK-rFVIIa compared
with CHO-rFVIIa.
• Clinical
• Pharmacokinetic (BE) study
• Further data required
• Safety/Efficacy
• Immunogenicity
• FDA:
• Requires new BLA and substantial
clinical studies
Comparative Human PK*
Mean AUC for CHO 30%> than for BHK
* Submitted for publication
14. Biosimilars, Overview of Scientific/Regulatory Guidelines and Experience, Inger Mollerup Novo Nordisk Slide no 14Oct 08 2009
Myozyme® (rhGAA) Example: Scale Up
Resulted in Different Product Characteristics
• Orphan drug produced in CHO cells, both 160 litre and 2000 litre
cell culture scale needed for supply
• EMEA:
• Concerns with regard to the potential levels of process impurities and
possible immunogenicity of CHO cell impurities for the 160L scale
• Impurity profile of 2000L process improved compared to 160L process
• Clinical experience from the 2000L process was taken into account
• The 2000L product (only) was granted market authorisation
• New facility recently approved
• FDA:
• FDA decided that batches manufactured in the two scales are different
(incl. differences in glycosylation) and therefore constitute distinct
products that must be licensed separately (separate BLA’s) and
marketed under different trade names
• Genzyme submitted Lumizyme® for FDA approval
Not yet possible to link quality attributes to clinical S&E
15. Biosimilars, Overview of Scientific/Regulatory Guidelines and Experience, Inger Mollerup Novo Nordisk Slide no 15Oct 08 2009
Biosimilar Case Studies
16. Product class-specific Guidelines
EU „Biosimilarity“ Guidelines
EMA Guidelines
Biosimilar
Guideline on similar biological medicinal product
Guidelines on similar biological medical products containing
biotechnology derived proteins as active substances
Quality Non-clinical/Clinical
Rh
Insulin
Somatropin rG-CSF Epoetin Interferonα LMWH mAbs
2013 review
Analogues
HM long
acting 2013
review
2013
finalise
2013
finalise + β
2013
review
Slide
no 16
13 Feb 2013
17. Bundesinstitut für Arzneimittel
und Medizinprodukte
Principles of Biosimilar Approach
„Similarity“ in terms of quality, safety and efficacy
To a reference product licensed in the EU
(Reference product: licensed based on full application,
data protection expired)
Same reference product for all aspects of the
comparability exercise
18. Biosimilar Approvals In Europe to Date:
Negative opinions and withdrawals
Trade Name Common Name
International
Nonproprietary
Name
Biosimilar
Sponsor(s)
Reference
Product
Decision Decision Date
Alpheon®
Interferon alfa-2a BioPartner
s
Roferon-A®
Negative Opin. Jun 2006
Insulin Rapid Marvel Soluble Insulin Marvel Humulin®
Withdrawn Jan 2008
Insulin Long Marvel Isophane Insulin Marvel Humulin®
Withdrawn Jan 2008
Insulin 30/70 Mix
Marvel
Biphasic Insulin Marvel Humulin®
Withdrawn Jan 2008
Epostim® Epoietin Reliance
Genemedi
x
Eprex®
Withdrawn Apr 2011
Insulin Solumarv Soluble Insulin Marvel Humulin®
Withdrawn Dec 2012
Insulin Isomarv Isophane Insulin Marvel Humulin®
Withdrawn Dec 2012
Insulin Combimarv Biphasic Insulin Marvel Humulin®
Withdrawn Dec 2012
EMA Public Assessment Report
19. Marvel Insulins: Human Long, Rapid and Mix (2008)
• Not possible to conclude that purity is comparable to reference
product
• Clinical (PK/PD) data: Significant differences in bioavailability compared to
reference products
• Products were not biosimilar, file withdrawn from EMA
PD data/Long
PD studies demonstrated clinically meaningful differences
Clinical safety and efficacy study confirmed difference
PD data/Mix
* Source: European Public Assessment Report
Biosimilar
Slide
no 19
13 Feb 2013
20. Marvel Insulins: Human Long, Rapid and Mix (2012)
• Company reason:
• Sufficient time to repeat and
submit bioequivalence T1D PK/PD
data on each clamp study
• Comply with the planned new
insulin guideline
• Validated CRO
• CHMP
• Manufacturing concerns
• Similarity was questioned
Biosimilar
Slide
no 20
13 Feb 2013
21. Biosimilar Approvals In Europe to Date
Trade Name Common Name
International
Nonproprietary
Name
Biosimilar
Sponsor(s)
Reference
Product
Decision Decision Date
Omnitrope®
somatropin Sandoz Genotropin®
Approved Apr 2006
Valtropin®
somatropin BioPartners Humatrope®
Approved Apr 2006
“Sandoz EPO”
Abseamed®
Epoetin alfa Hexal
Binocrit®
epoetin alfa
Medice
Hexal
Sandoz
Eprex®
Approved Aug 2007
“Hospira EPO”
Silapo®
Retacrit®
epoetin zeta
Stada
Hospira
Eprex®
Approved Dec 2007
“Teva G-CSF”
Tevagrastim®
Ratiograstim®
Filgrastim
ratiopharm (MA
withdrawn July
2011)
Biograstim®
Filgrastim
Teva
Ratiopharm
CT
Arzneimittle
Neupogen®
Approved Sep 2008
“Sandoz G-CSF”
Filgrastim Hexal
Zarzio®
Filgrastim
Hexal
Sandoz
Neupogen® Approved Feb 2009
Nivestim® Filgrastim Hospira UK Neupogen®
Approved Jun 2010
EMA Public Assessment Report
22. Biosimilars, Overview of Scientific/Regulatory Guidelines and Experience,
Inger Mollerup Novo Nordisk
Slide
no 22
Oct 08 2009
EU: Early version of Omnitrope® (somatropin)
Reference product: Genotropin (Pfizer)
• Early version of the product: 57% of patients developed
antibodies against Omnitrope
• Problem was residual host-cell protein
• Re-developed purification process
• Conducted a second phase 3 study
• Antibody levels reduced (comparable)
• Approved by EMEA, FDA, TGA – and recently by Health Canada
and PMDA in Japan
Link between quality parameter (HCP) and clinical safety
(immunogenicity) found in clinical studies
* Source: European Public Assessment Report
23. Biosimilars, Overview of Scientific/Regulatory Guidelines and Experience,
Inger Mollerup Novo Nordisk
Slide
no 23
Oct 08 2009
EU: Alpheon (alpha interferon)
Reference product: Roferon (Roche)
• Differences in impurity profile were observed
• Key Clinical Data
• PK (3 studies):
supra-bioavilability(early study); comparable; inconclusive
• PD (2 studies): PD equivalence/no PD equivalence
• Safety&Efficacy:
• Clinically and statistically significant difference in
virological relapse rate found: more patients on
Alpheon had relapse
• Different rate of adverse events and laboratory-
related events judged as clinically relevant
Clinical studies evaluating efficacy and safety demonstrated
clinically meaningful differences leading to Rejection by EMEA
* Source: European Public Assessment Report
24. Biosimilars, Overview of Scientific/Regulatory Guidelines and Experience, Inger Mollerup Novo Nordisk Slide no 24Oct 08 2009
Other products - not approved under biosimilar
framework
25. Biosimilars, Overview of Scientific/Regulatory Guidelines and Experience, Inger Mollerup Novo Nordisk Slide no 25Oct 08 2009
”Ex-EU” Somatropin: New Thioether Variant
Identified
• Thioether variant found in some
hGH products (up to ~30%)
• Hormotrop®, Yelit®, Cryotropin®
• Thioether variant not identified in
• Saizen®
• International standards:
NIBSC 98/574 (r), NIBSC 80/505 (p),
EP r-hGH CRS
• Thioether variant:
• Not detected by compendial and other
existing chromatographic methods –
new methods required
• Generated by high pH at elevated temparature (40 deg C)
• Significantly reduced biopotency in rat model
• Analytical methods must be ”tailor made”
* Lispi, M. et al, J. Pharm. Sciences, DOI 10 1002/jps 21774, 2009
New impurity identified with reduced biopotency
Change in Clinical efficacy & safety cannot be excluded
26. Biosimilars, Overview of Scientific/Regulatory Guidelines and Experience, Inger Mollerup Novo Nordisk Slide no 26Oct 08 2009
Conclusion: Quality Aspects and Comparability
• Products must have highly similar molecular structural
features
• Amino acid sequence must be the same
• Glycosylation patterns must be highly similar
• Same host cell type system
• Impurity profiles must be highly similar
• Analytical methods extremely important
• Only way to exclude clinically meaningful differences in
efficacy, safety and immunogenic potential – is from clinical
data
• Multiple examples illustrate close link between chemical and
clinical comparability
• Can’t be predicted from structure
• Full comparability exercise needed – quality, nonclinical
and clinical – as outlined in EMEA guidance documents
Notes de l'éditeur
The Bottom Line:
The data required by FDA to ensure that a product is safe and effective after a manufacturing change varies with the change. Significant manufacturing changes require significant supporting data.
Comparability following a process change is a different technical exercise to a comparison that an FOB manufacturer might make. Innovators who make process changes will not only compare the DP, they will also test and provide regulators with data from hundreds of other tests that have been conducted during the manufacturing process. Results from each step will be compared in order to understand the impact of the process change. An FOB manufacturer cannot perform these tests as they do not have access to the data – thus making their exercise of comparing the FOB to the innovator fundamentally different in the type and number of tests performed, to those undertaken by an innovator following a process change. Examples: The “light bulb” example would have been picked up in the in-process controls The California to Colorado change in site and consequent change in oxygen partial pressure would have been picked up in in-process controls and process validation Even though the FOB manufacturer can test against the drug product of the innovator, these tests are sometimes limited by the excipients. For example, components of the drug substance can “interfere” with the analytical tests. This means that it is not always possible to draw definitive conclusions from this comparison about similarity of the FOB and the innovator.
a lot of authorities elute to the standards made in EU how does it relate to IO
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