Evolving Regulation of Biosimilars and Update on Generic Drug Regulation
Bioequivalence
1. Hanoi, 2006-19-01 1
WORKSHOP ON
PREQUALIFICATION OF ARV:
BIOEQUIVALENCE
Introduction to the Discussion
of Bioequivalence Study
Design and Conduct
Presented by
Hans Kemmler
Consultant to WHO
Swissmedic (Swiss drug regulatory authority)
2. Hanoi, 2006-19-01 2
Background:
First Product to Market
Innovator’s Product
Quality
Safety and efficacy
– Based on extensive clinical trials
– Expensive
– Time consuming
3. Hanoi, 2006-19-01 3
Background:
Other products with same
medicinal ingredient
Subsequent-entry products
Generic products
Multisource products
How do these products gain
marketing authorization?
4. Hanoi, 2006-19-01 4
Pharmaceutical equivalence
Same amount of the same active
pharmaceutical ingredient
– Salts, esters
Same dosage form
– Comparable dosage forms
– e.g., tablet vs. capsule
Same route of administration
Is pharmaceutical equivalence enough?
5. Hanoi, 2006-19-01 5
Sometimes pharmaceutical
equivalence is enough
Aqueous solutions
– Intravenous solutions
– Intramuscular, subcutaneous
– Oral solutions
– Otic or ophthalmic solutions
– Topical preparations
– Solutions for nasal administration
Powders for reconstitution as solution
Gases
6. Hanoi, 2006-19-01 6
Sometimes it is not enough
Pharmaceutical equivalence by itself
does not necessarily imply
therapeutic equivalence
Therapeutic equivalence:
– Pharmaceutically equivalent
– Same safety and efficacy profiles after
administration of same dose
7. Hanoi, 2006-19-01 7
Pharmaceutical Equivalents
Possible Differences
Drug particle size
Excipients
Manufacturing
Equipment or
Process
Site of manufacture
Test Reference
Could lead to differences in product performance in vivo
8. Hanoi, 2006-19-01 8
Additional data is required
Oral immediate release products with
systemic action
– Generally required for solid oral
dosage forms
• Critical use
• Narrow therapeutic range
• Bioavailability problems associated with
the active ingredient
• Problematic polymorphism, excipient
interaction, or sensitivity to manufacturing
processes
9. Hanoi, 2006-19-01 9
Additional data is required
Oral modified release products with
systemic action
Fixed dose combination products with
systemic action
– When at least one component requires study
Non-oral / non-parental products with
systemic action
Non-solution products with non-systemic
action
10. Hanoi, 2006-19-01 10
Marketing authorization of
multisource products
Extensive clinical trials to
demonstrate safety and efficacy
– Interchangeability?
Demonstration of equivalence to
reference (comparator) product
– Interchangeability
– Therapeutic equivalence
12. Hanoi, 2006-19-01 12
Comparative Pharmacokinetic
Studies
In vivo measurement of active
ingredient
“Some” relationship between
concentration and safety/efficacy
Product performance is the key
Comparative bioavailability
13. Hanoi, 2006-19-01 13
Bioavailability
The rate and extent to which a substance or
its active moiety is delivered from a
pharmaceutical form and becomes available
in the general circulation.”
Reference:
intravenous administration = 100% bioavailability
14. Hanoi, 2006-19-01 14
Important Pharmacokinetic
Parameters
AUC: area under the concentration-time
curve ⇒ measure of the extent of
bioavailability
Cmax: the observed maximum concentration of
drug ⇒ measure of both the rate of
absorption and the extent of bioavailability
tmax: the time after administration of drug at
which Cmax is observed ⇒ measure of the
rate of absorption
16. Hanoi, 2006-19-01 16
Bioequivalence
Two products are bioequivalent if
they are pharmaceutically equivalent
bioavailabilities (both rate and extent) after
administration in the same molar dose are
similar to such a degree that their effects
can be expected to be essentially the same
17. Hanoi, 2006-19-01 17
Therapeutic Equivalence
Therapeutic equivalence:
– Pharmaceutically equivalent
– Same safety and efficacy profiles after
administration of same dose:
bioequivalent
Interchangeability
18. Hanoi, 2006-19-01 18
Comparative
Pharmacodynamic Studies
Not recommended when:
– active ingredient is absorbed into the
systemic circulation
– pharmacokinetic study can be
conducted
Local action / no systemic absorption
19. Hanoi, 2006-19-01 19
Comparative Clinical Studies
Pharmacokinetic profile not possible
Lack of suitable pharmacodynamic
endpoint
Typically insensitive
20. Hanoi, 2006-19-01 20
Comparative in vitro Studies
May be suitable in lieu of in vivo
studies under certain circumstances
Requirements for waiver to be
discussed
Currently no “biowaiver” (waiving the
requirement for a bioequivalence
study) in prequalification project
except for additional strength
21. Hanoi, 2006-19-01 21
When are bioequivalence
studies employed?
Multisource product vs. Innovative
product
Pre-approval changes
– Bridging studies
Post-approval changes
Additional strengths of existing
product
22. Hanoi, 2006-19-01 22
Bioequivalence Studies:
Basic Design Considerations
Minimize variability not attributable to
formulations
Minimize bias
REMEMBER: goal is to compare
performance of the two products
23. Hanoi, 2006-19-01 23
“Gold Standard” Study
Design
Single-dose, two-period, crossover
Healthy volunteers
Subjects receive each formulation
once
Adequate washout
25. Hanoi, 2006-19-01 25
Multiple-dose Studies may be
employed when:
Drug is too potent/toxic for
administration in healthy volunteers
– Patients / no interruption of therapy
Extended/modified release products
– Accumulation using recommended
dosing interval
– In addition to single-dose studies
26. Hanoi, 2006-19-01 26
Multiple-dose Studies may be
employed when:
Non-linear pharmacokinetics at
steady-state (e.g., saturable
metabolism)
Assay not sufficiently sensitive for
single-dose study
27. Hanoi, 2006-19-01 27
Crossover vs. Parallel
Designs
Crossover design preferred
– Intra-subject comparison
– Lower variability
– Generally fewer subjects required
Parallel design may be useful
– Drug with very long half-life
– Crossover design not practical
28. Hanoi, 2006-19-01 28
Parallel Design
Considerations
Ensure adequate number of subjects
Adequate sample collection
– Completion of Gastrointestinal
transit / absorption process
– 72 hours normally sufficient
29. Hanoi, 2006-19-01 29
Fasted vs. Fed Designs
Fasted study design preferred
– Minimize variability not attributable to
formulation
– Better able to detect formulation
differences
30. Hanoi, 2006-19-01 30
Fed Study Designs may be
employed when:
Significant gastrointestinal (GI)
disturbance caused by fasted
administration
Product labeling restricts
administration to fed state
31. Hanoi, 2006-19-01 31
Fed Study Design
Considerations
Fed conditions depend on local diet
and customs
Dependent on reason for fed design
– Avoiding GI disturbance
• Minimal meal to minimize impact
– Required due to drug substance /
dosage form
• Modified-release products
32. Hanoi, 2006-19-01 32
Fed Study Design
Considerations cont.
– Required due to drug substance /
dosage form
• Complicated pharmacokinetics
• Known effect of food on drug substance
Fed conditions designed to promote
maximal perturbation
– High fat
– High Calorie
– Warm
33. Hanoi, 2006-19-01 33
Replicate vs. non-replicate
designs
Standard approach
– Non-replicated
– Single administration of each product
– Average bioequivalence
34. Hanoi, 2006-19-01 34
Replicate Designs
Typically four-period design
– Each product administered twice
Intra-subject variability
Subject X formulation interaction
Different approaches possible
– Average bioequivalence
– Individual bioequivalence
35. Hanoi, 2006-19-01 35
Replicate Designs
Advantages
– More information available
– Different approaches to assessment
possible
Disadvantages
– Bigger commitment for volunteers
– More administrations to healthy
volunteers
– More expensive to conduct
36. Hanoi, 2006-19-01 36
Helpful Guidelines
FDA - Guidance for Industry: “Bioavailability and
Bioequivalence Studies for Orally Administered Drug
Products – General Considerations” (Oct. 2000)
Canadian Guidance for Industry: “Conduct and Analysis of
Bioavailability and Bioequivalence Studies – Part A: Oral
Dosage Formulations used for systemic effects.” (1992)
EU “Note for Guidance on the Investigation of
Bioavailability and Bioequivalence”
– CPMP/EWP/QWP/1401/98 and related guidances and documents
(www.emea.eu.int/pdfs/human/ewp )
Many other related guidances,
consider current scientific discussion
Two products that are considered pharmaceutical equivalents can still differ to such an extent that it will influence the product performance in vivo, which may make the two products bioinequivalent. Possible differences include:
Drug particle size (especially important for poorly soluble drugs)
Excipients (can influence both solubility and permeability of the active ingredient)
Manufacturing Equipment or Process (e.g. differences in blending time, differences in granulation method)
Site of manufacture (same product manufactured at different sites within the same company)
Note that bioequivalence standards are applied to the pharmacokinetic parameters AUC and Cmax but not to Tmax.
This is an example of a plasma concentration time profile following extravascular administration of a drug. The parameters often used in bioequivalence assessments are here marked as AUC, Cmax and Tmax. For definitions, see next page.