Author byline as per print journal: Jon SB de Vlieger, PhD; Professor Stefan Mühlebach, PhD; Vinod P Shah, PhD; Scott E McNeil, PhD; Professor Gerrit Borchard, PharmD, PhD; Vera Weinstein, PhD; Beat Flühmann, PhD; Sesha Neervannan, PhD; Professor Daan JA Crommelin, PhD
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Abstract: |
Submitted: 16 September 2015; Revised: 15 October 2015; Accepted: 19 October 2015; Published online first: 2 November 2015
The concept of non-biological complex drug (NBCD) products has been presented and discussed on several occasions in the GaBI Journal [1–4]. The growing interest in this topic in academic, industrial and regulatory circles led to the establishment of an Editorial Section on Non-Biological Complex Drugs in both the GaBI Journal and GaBI Online starting in the third quarter of 2015.
In 2011, the first publication on NBCDs appeared [5] as a result of a workshop held in Leiden, The Netherlands, in 2009. For the first time this class of drug products was identified and recognized. These products are more complex than small, low molecular drugs and as complex or even more complex than biologicals; sharing many of the characteristics of the latter category but not being derived from living sources. As a consequence, the authors argued that for the equivalence testing of NBCD follow-on products a regu latory pathway should be developed that was similar to the pathways developed by the European Medicines Agency (EMA) and later the US Food and Drug Administration (FDA) for approving biosimilars. This proposal was backed up by evidence provided by a (still growing) number of published studies on NBCD follow-on versions that were authorized using a ‘standard’ but inadequate generic assessment protocol.
A working group hosted by the Dutch Top Institute (TI) Pharma in Leiden was set up to raise awareness of the challenges NBCD products present worldwide, to stimulate the publication of scientific reports and discussions and to provide a rigorous, sciencebased, regulatory policy for NBCD products [6]. These efforts led to a number of publications and a book exclusively dedicated to the NBCD concept and its regulation. These publications provide a definition for NBCD products, discuss different classes of NBCDs, propose an overarching regulatory philosophy for evaluating NBCD follow-on versions and, finally, outline what issues are still unresolved [7–9].
This paper to the GaBI Journal further explains:
A definition of NBCD products that was published earlier by the NBCD working group reads: ‘A Non-Biological Complex Drug is a medicinal product, not being a biological medicine, where the active substance is not a homo-molecular structure, but consists of different (closely related and often nanoparticulate) structures that can’t be isolated and fully quantitated, characterized and/or described by stateof-the-art (physico)chemical analytical means and where the clinical meaning of the observed differences is not known. The composition, quality and in vivo performance of NBCDs are highly dependent on manufacturing processes of both the active ingredient as well as in most cases the formulation’ [7].
Present product ‘families’ and beyond
At present the following NBCD product groups or ‘families’ have been identified and discussed in the literature: liposomes, polymeric micelles, glatiramoids, iron-carbohydrate complexes, albuminanticancer drug nanoparticles and nanocrystals. The rapidly growing group of nanomedicines will add many NBCDs to this list [9–10]. Interestingly, there are also medicinal products such as the low molecular weight heparins (LMWHs) showing similar complexity but falling under different regulatory policies, i.e. by EMA LMWHs are seen as biologicals and by FDA as non-biologicals.
Over the last few years a number of studies on these NBCD product families have been published. This list is growing and expanding beyond only parenteral drugs. Recently, the present science base, including the: (1) chemistry and structure; (2) manufacturing; (3) (physico)chemical characterization; (4) pharmacology; and (5) regulatory status, of these product groups was reviewed in a book [9]. The availability of these data in the public domain should contribute to sciencebased discussions and could serve as a model to be followed for consideration of other NBCD product families. In addition, questions regarding interchangeability and substitutability of NBCD follow-on versions have important implications for the handling of such medicinal products by healthcare professionals. Requests are being made by these healthcare professionals for education on the topic of NBCDs and for further, tailor-made, reliable information for patients.
Other candidate NBCD product families that are waiting to be identified include emulsions (parenteral or ocular), dry powder inhalers and oral bioactive polymers such as complex phosphate binders.
The regulatory landscape
In earlier publications in GaBI Online the differences between the characteristics of small, low molecular weight molecules and biologicals were listed, see Table 1 [11]. If the items in the ‘biological drugs’ column (in italics) that relate to the biological source of the product and immunogenicity are removed, what remains demonstrates that there is a striking resemblance between the characteristics of biologicals and NBCD products.
Because of this similarity in product characteristics, the NBCD Working Group has proposed on several occasions that regulators should follow the same regulatory pathway for NBCD follow-on products as for biosimilars. This proposal is schematically shown in Figure 1 where ‘Totality of evidence’ is the key phrase when assessing therapeutic equivalence of NBCD innovator and follow-on products.
Neither FDA nor EMA uses special NBCD regulatory schemes. These agencies use existing pathways for the introduction of innovative and follow-on NBCD products. FDA uses the 505(b)(1)/505(b)(2) and 505(j) pathways for innovator products and follow-on versions, respectively. However, both FDA and EMA are paying increasing attention to regulatory issues related to NBCD families [12–13].
Generally speaking, there are two clearly distinct regulatory documents for these NBCD product families. On the one hand, FDA and/or EMA published ‘draft guidance’ and/or ‘reflection papers’ on new products such as liposomes [14], polymeric micelles [15], and surface coatings [16]. On the other hand, both agencies issued documents on the development of follow-on versions of NBCD products such as EMA documents on iron-based nano-colloidal products [17–19] and on existing products [20], and FDA on iron complexes [21], ciclosporin emulsions [22] and on liposome follow-on products [23–24]. Interestingly, FDA has awarded funding to characterize and clinically compare originator and follow-on versions after approving these products [25–26]. It is clear that the present arsenal of regulatory documents from these agencies will be expanded in the years to come. Hopefully, it is not too late to reach global agreement through the World Health Organization (WHO) or perhaps the International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH) initiatives. On the pharmacopoeial side, interest is growing in dealing with NBCD families. For example, a European Directorate for the Quality of Medicines and HealthCare (EDQM) working group is developing a monograph on ‘iron sucrose concentrated solution’ as an example for non-biological complexes and the United States Pharmacopeia (USP) is currently evaluating similar actions [27]. The British Pharmacopoeia (BP) has published a new monograph on iron sucrose injections, which is basically in line with the USP existing monograph.
One interesting feature of the European legal landscape is that certain NBCD product families are not approved through the centralized procedure (EMA). Instead, approval follows either the purely national procedures or the mutual recognition procedure under the aegis of national competent authorities. This is true for iron sucrose products and for oral bioactive polymer phosphate binders [28]. Considering the complexity of these products and the problems encountered in certain countries with generic versions of NBCD products (see below), approval thro ugh the centralized procedure and the CHMP team would be preferred.
For all NBCD product families where follow-on versions are on the market, a growing number of studies have become available in the public domain demonstrating examples of follow-on products that were approved by (national) competent authorities that differed structurally and/or in clinical practice from the originator products [9]. Often these differences were clinically relevant. Examples include publications by Rottembourg et al. [29]; Martin-Malo et al. [30]; Stein et al. [31]; Lee et al. [32] and Agüera et al. [33] for iron sucrose similars; and Weinstein et al. [34] and Towfic et al. [35] for glatiramer acetate follow-on products. These (clinical) examples raise questions to the regulatory science community in the countries mentioned in these publications about how appropriate the current systems are in ensuring equivalence in NBCD product quality, efficacy and safety. Is the current approach rigorous enough?
These examples provide lessons that should be communicated throughout the scientific community as well as to medical/pharmaceutical practitioners. More over, in the years to come, study of these examples can also help competent authorities to establish appropriate, science-based approval procedures for these complex drug products.
Expanding: The number of NBCD product families will continue to grow. It is time to pay attention to these (new) families and discuss their specific characteristics and their implications for the regulatory process at an early stage. Much information is often already available but there is a need to go through the archives and analyse these data so that scientific deficiencies are brought to the forefront.
Outstanding issues: for a list of outstanding issues concerning NBCD products one can refer to the list drawn up for biologicals. For example, labelling, comparability and attribute drift, NBCD-questionables (cf. bio-questionables [36]), extrapolation [37], interchangeability, substitution, and last but not least: a single global approach (WHO in the lead?) [38].
Facts please: For a fact-based debate on NBCD products we need to stimulate publications in the public domain. This will strengthen the science base for decisionmaking. Transparency of the regulatory process is another essential element for such a discussion. We hope that all parties (academic, industry and regulatory) involved in this debate will continue, and even step up their efforts to provide this science base.
Goal: We feel that the GaBI Journal and the GaBI Online platform offer excellent opportunities to stimulate awareness around the critical issues related to both new, innovative NBCD products and the introduction of follow-on versions. The growing science base for NBCD product legislation, e.g. in Europe and the US, and hopefully in other countries in the future, needs a non-biased publication outlet. With the GaBI publication platform we have the ambition to become the central and preferred publication hotspot for this complex topic.
Jon SB de Vlieger, PhD
Dutch Top Institute Pharma, PO Box 142, NL-2300 AC Leiden, The Netherlands
Professor Stefan Mühlebach, PhD
Vifor Pharma Ltd, 61 Flughofstrasse, PO Box, CH-8152 Glattbrugg, Switzerland; Department of Pharmaceutical Sciences, Pharmacenter, University of Basel, 50 Klingelbergstrasse, CH-4056 Basel, Switzerland
Vinod P Shah, PhD
NBCD Steering Committee member, Pharmaceutical Consultant, 11309 Dunleith Place, North Potomac, MD 20878, USA
Scott E McNeil, PhD
Director, Nanotechnology Characterization Laboratory, Frederick National Laboratory for Cancer Research, Leidos Biomedical Research Inc, PO Box B, Frederick, MD 21702-1201, USA
Professor Gerrit Borchard, PharmD, PhD
Professor, Biopharmaceutical Sciences, School of Pharmaceutical Sciences, University of Geneva, University of Lausanne 30, Quai Ernest-Ansermet, CH-1211 Geneva 4, Switzerland
Vera Weinstein, PhD
Teva Pharmaceutical Industries Ltd, Discovery and Product Development, Global Research and Development, Netanya, Israel
Beat Flühmann, PhD
Vifor Fresenius Medical Care Renal Pharma Ltd, 37 Rechenstrasse, PO Box, CH-9001 St Gallen, Switzerland
Sesha Neervannan, PhD
Senior Vice President, Pharmaceutical Development Brands R & D, Allergan Plc, RD2-3A, 2525 Dupont Drive, Irvine, CA 92612, USA
Emeritus Professor Daan JA Crommelin, PhD
Department of Pharmaceutical Sciences, Utrecht Institute for Pharmaceutical Sciences, Utrecht University, The Netherlands
Competing interest: All authors are members of the steering committee of the Non-Biological Complex Drug (NBCD) Working Group, hosted at the Dutch Top Institute Pharma (TI Pharma), Leiden, The Netherlands (http://www.tipharma.com/NBCD).
Provenance and peer review: Not commissioned; externally peer reviewed.
References
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Author for correspondence: Jon SB de Vlieger, PhD; Dutch Top Institute Pharma, PO Box 142, NL-2300 AC Leiden, The Netherlands |
Disclosure of Conflict of Interest Statement is available upon request.
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Source URL: https://gabi-journal.net/non-biological-complex-drugs-nbcds-and-their-follow-on-versions-time-for-an-editorial-section.html
Author byline as per print journal: Professor Philip D Walson, MD, Professor Stefan Mühlebach, PhD, Beat Flühmann, PhD
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Introduction: In recent years a new category of medicinal products, the non-biological complex drugs (NBCDs) emerged. They are distinct from both the small molecules and the biological therapeutics by being composed of non-homomolecular large structures, some of which may be nanoparticulate, and by not being a biological product or being chemically synthesized. Approval of their follow-on copies is problematic because like biologicals they are impossible to be fully characterized by only their physiochemical properties and both their structure and function are sensitive to small changes in the laborious and difficult to control manufacturing process. Today, requirements for authorization of follow-on NBCDs are unclear and handled on a case-by-case basis. |
Submitted: 20 January 2014; Revised: 31 January 2014; Accepted: 13 Februray 2014; Published online first: 26 February 2014
With few exceptions small molecule generic drug products provide equivalent results at lower costs and can be considered as therapeutically equivalent. However, biological follow-on products, i.e. biosimilars, are impossible to completely characterize by their physiochemical properties and even minor changes in their manufacturing processes can result in clinically meaningful differences in efficacy or safety. Therefore, biosimilars are regulated differently than are follow-on small molecule generics using a more extensive similarity approach [1].
Effective, abbreviated regulatory procedures exist for assessing follow-on ‘generic’ versions of small molecule medicinal products. Proof of pharmaceutical equivalence and comparability of bioequivalence establish therapeutic equivalence for such medicinal products (generics paradigm). Macromolecular, biological complex medicinal products however cannot be fully characterized by physicochemical tests. In addition, for many of these medicinal products bioequivalence assessment is either not possible or not indicative of clinical safety and efficacy. Therefore, a different ‘biosimilar’ approach that includes in vitro biological and clinical evaluations has been developed for follow-on biologicals and therapeutic proteins ‘manufactured’ by living organisms.
There are a growing number of non-biological complex drugs (NBCDs) that are neither small molecules nor biologicals. NBCDs include a number of chemically synthesized, macromolecular products such as liposomal products, glatiramoids, and intravenous (IV) iron carbohydrate preparations. As for the biologicals, NBCDs cannot be fully characterized by physicochemical analysis. Even minor changes in their laborious synthetic manufacturing processes can affect composition or structure and result in meaningful differences in clinical effects. Due to their nanosize properties, some of these follow-on versions of NBCDs are also referred to as ‘nanosimilars’. In the past, these ‘nanosimilars’ have been regulated the same as small molecule generics.
The adequacy of this regulatory approval process has been questioned because therapeutic non-equivalence and non-interchangeability of authorized follow-on IV iron sucrose products have been reported [2, 3]. Therefore, authorities addressed the urgent need to define best practices for nanosimilar approval and post-approval pharmacovigilance to maximize the chances that such follow-on products provide patients with non-inferior safety and clinical outcomes [4–9]. Recently, a nanosimilar approval approach has also been proposed [1, 10–12].
On 8 October 2013, the Generics and Biosimilars Initiative (GaBI) held the First Asia-Pacific Educational Workshop on Non-Biological Complex Drugs (NBCDs) in Kuala Lumpur, Malaysia. The objectives of the workshop were to raise evidence-based awareness of the potential differences in quality as well as therapeutic and toxic effects of NBCDs including IV iron products. The goal was to promote active discussion amongst various stakeholders from the Asia-Pacific region concerning the best practice methods to approve, regulate, monitor and use follow-on (similar but not identical) NBCDs, and to identify areas of consensus, uncertainty and disagreement concerning these NBCDs best practices.
Speakers were selected by the GaBI Journal publisher and included academicians and regulators from Europe, a practising nephrologist (France) and an obstetrician/gynaecologist (South Korea) who had published research relating to NBCDs and are involved in the day-to-day use of IV iron NBCDs, as well as experts from academia and the manufacturer of the originator iron sucrose product (Venofer®). Non-speaker participants, selected in consultation with the Ministry of Health Malaysia, came from Indonesia, Malaysia, Pakistan, the Philippines, Thailand and Singapore. Prior to the workshop participants were provided a reading list and a questionnaire to complete and return covering current and perceived best practices both of which are available on request to the publisher; as are the questionnaire responses, the reading and participant lists, and copy of all presentations (www.gabi-journal.net/about-gabi/current-activities).
Speakers summarized key aspects of the manufacturing, physicochemical properties, analysis, current regulatory practice and clinical experience with NBCDs.
Drug development and regulatory approval require distinct product naming, characterization and use of the specific product in preclinical and clinical evaluation of a product, see Figure 1 [11]. While relatively straight forward for small molecule generics, the required unequivocal identification of the drug product can be impossible for NBCDs and their copies. Regulatory approval of nanosimilars is especially problematic because the understanding of which differences are clinically relevant is very limited. As summarized by Professor Gerrit Borchard, ‘The bio-disposition and activity of NBCDs is determined by their interaction with biological systems. This, in turn, is thought to be governed by their physicochemical parameters, such as size and size distribution, surface charge, and composition. However, a rationale predicting biological outcome based on NBCD properties is still lacking.’ The EU has led the US in development of regulations for biosimilars and nanosimilars and places particular emphasis on proving product efficacy and safety. In 2009, the European Medicines Agency (EMA) implemented the Ad-Hoc Nanomedicine Expert Group, which has published a number of ‘reflection papers’ on approval of NBCD nanomedicines including IV iron sucrose [4–8].
The clinical relevance of follow-on NBCD approval and use was illustrated by two clinical case studies presented by the authors of these published reports. The first was of the substitution of a follow-on iron sucrose product (Ferex, BMI Korea) for the originator (Venofer®, Vifor Pharma Ltd, Switzerland) in gynaecological patients that resulted in significantly more adverse events and higher overall costs [2]. The second was of inferior therapeutic effects and increase in costs seen after substitution of the follow-on Fer Mylan for Venofer® in French renal dialysis patients [3]. Substitutions were both based on theoretical cost savings and the clinicians were not aware of the switch until after they observed the negative effects. These cases raised concerns about both the adequacy of the follow-on NBCD approval processes and the lack of clinician involvement in pharmacy substitution practices. They also suggest that prospective double-blind therapeutic trials should be done to evaluate whether substitutions actually result in cost savings without changes in efficacy or safety. Finally, they illustrate the need for appropriate and indicative post-approval pharmacovigilance studies.
The concerns raised by these cases were mirrored in comments made by participants during the breakout sessions. There was unanimous clinician consensus that treating physicians should be asked or at least made aware before any substitution was made and that there should be adequate post-approval monitoring of such products. The majority of clinicians also felt that such products should be approved only after adequate clinical testing. Regulators indicated that regulatory pathways are being put in place in the Asia-Pacific region but there was consensus that the issues raised by NBCDs were not well understood. Because of their limited regulatory experience with these products regulators and clinicians tend to rely on information supplied by the manufacturers of such products. Follow-on products are generally being regulated as generics on a case-by-case basis. Some post-marketing surveillance procedures are in place, however, their effectiveness was questioned.
Both clinicians and regulators agreed that the NBCD concept is new and not well understood, therefore, few or no adequate regulatory pathways are in place. In order to develop such pathways, basic scientific and clinical data are needed as well as training and education of all stakeholder groups involved, i.e. patients’ organizations, nurses, pharmacists, clinicians and regulators. Feedback from practitioners to regulatory authorities and interna-tional cooperation of regulatory authorities in Asia-Pacific countries were felt to be important in the development of best practice regulatory approaches but there was general agreement with a previously published proposal, see Figure 2, for approval of NBCD similars [10].
There was consensus that the education of all stakeholders was needed but it was not clear what methods would be the most effective. It was suggested that providing EMA draft opinions to regulators in all countries could lead to greater international regulatory cooperation.
The GaBI Journal will focus on NBCDs in future publications and educational workshops/conferences. The faculty of this workshop was approached to present the topic of NBCD at the upcoming ASEAN ACCSQ PPWG (ASEAN Consultative Committee for Standards and Quality [ACCSQ] Pharmaceutical Product Working Group [PPWG]) Conference to be held on 17–20 June 2014. Also, a session on biosimilars and NBCDs will be held at the FIP meeting in Bangkok, Thailand, in September 2014.
A large and growing number of NBCDs, including IV iron sucrose preparations, are characterized by non-homologous structures, which cannot be fully characterized by physiochemical testing. Rational approval of follow-on versions is problematic because, as with biologicals, even minor changes in production methods can have major but unpredictable impact on their therapeutic profile.
Currently, there is no harmonized and uniform approach in either the EU, the US or the Asia-Pacific region as to how follow-on NBCDs are regulated, used, or monitored after authorization (pharmacovigilance).
Published scientific studies and clinical case reports raise concerns about the adequacy of the methods currently used to approve, use, substitute or monitor follow-on iron sucrose products. Studies suggest that NBCDs require a separate regulatory pathway using a similarity approach that is as, if not even more, stringent than that being used for biosimilars.
There are gaps in the understanding of the properties of NBCDs on the part of regulators, pharmacists, patients, and clinicians that should be addressed by development of guidelines and educational programmes.
The Generics and Biosimilars Initiative (GaBI) wishes to thank Ms Arpah Abas, National Pharmaceutical Control Bureau, Ministry of Health Malaysia; and Dato’ Eisah A Rahman , Senior Director Pharmaceutical Services, Pharmaceutical Services Division, Ministry of Health Malaysia, for their strong support of offering advice and information towards the preparation of the educational workshop.
The authors would like to acknowledge the help of all the workshop faculty and participants, each of whom contributed to the success of the workshop and the content of this report as well as the support by Vifor Pharma Ltd who provided unrestricted financial support for the workshop, and review of the draft manuscript.
Disclosure of financial interests: The meeting was sponsored by an unrestricted educational grant to GaBI from Vifor Pharma Ltd.
Professor Stefan Mühlebach and Dr Beat Flühmann are employees of Vifor Pharma Ltd.
Provenance and peer review: Not commissioned; externally peer reviewed.
Professor Stefan Mühlebach1,2, PhD
Beat Flühmann1,3, PhD
1Steering Committee member, NBCD Working Group, TI Pharma, Leiden, The Netherlands
2Vifor Pharma Ltd, 61 Flughofstrasse, PO Box, CH-8152 Glattbrugg, Switzerland
3Vifor Fresenius Medical Care Renal Pharma Ltd, 37 Rechenstrasse, PO Box, CH-9001 St Gallen, Switzerland
References
1. Mühlebach S, Vulto AG, de Vlieger Jon SB, Weinstein V, Flühmann B,et al. The authorization of non-biological complex drugs (NBCD) follow-on versions: specific regulatory and interchangeability rules ahead? Generics and Biosimilars Initiative Journal (GaBI Journal). 2013;2(4):204-7. doi:10.5639/gabij.2013.0204.054
2. Lee ES, Park BR, Kim JS, Choi GY, Lee JJ, Soon Lee IS. Comparison of adverse event profile of intravenous iron sucrose and iron sucrose similar in postpartum and gynecologic operative patients. Curr Med Res Opin. 2013;29(2):141-7.
3. Rottembourg J, Kadri A, Leonard E, Dansaert A, Lafuma A. Do two intravenous iron sucrose preparations have the same efficacy? Nephrol Dial Transplant. 2011;26(10):3262-7.
4. European Medicines Agency. Reflection paper on the data requirements for intravenous 4 iron-based nano-colloidal products developed with 5 reference to an innovator medicinal product data requirements for IV iron-based nano-colloidal products. EMA/CHMP/SWP/620008/2012. 25 July 2013 [homepage on the Internet]. 2013 Sep [cited 2014 Jan 31]. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/09/WC500149496.pdf
5. European Medicines Agency. Reflection paper on surface coatings: general issues for consideration regarding parenteral administration of coated nanomedicine products. EMA/325027/2013. 22 May 2013 [homepage on the Internet]. 2013 Aug [cited 2014 Jan 31]. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/08/WC500147874.pdf
6. European Medicines Agency. Reflection paper on the data requirements for intravenous liposomal products developed with reference to an innovator liposomal product. EMA/CHMP/806058/2009/Rev.02. 21 February 2013 [homepage on the Internet]. 2013 Aug [cited 2014 Jan 31]. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/03/WC500140351.pdf
7. European Medicines Agency. Joint MHLW/EMA reflection paper on the development of block copolymer micelle medicinal products. EMA/CHMP/13099/2013. 17 January 2013 [homepage on the Internet]. 2013 Jan [cited 2014 Jan 31]. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/02/WC500138390.pdf
8. European Medicines Agency. Non-clinical studies for generic nanoparticle iron medicinal product application. EMA/CHMP/SWP/100094/2011. 17 March 2011 [homepage on the Internet]. 2011 Apr [cited 2014 Jan 31]. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2011/04/WC500105048.pdf
9. U.S. Food and Drug Administration. Draft guidance for industry on bioequivalence recommendations for iron sucrose injection; availability. Federal Register. 2013 Nov 6.
10. Schellekens H, Klinger E, Mühlebach S, Brin JF, Storm G, Crommelin DJ. The therapeutic equivalence of complex drugs. Regul Toxicol Pharmacol. 2011;59(1):176-83.
11. Borchard G, Flühmann B, Mühlebach S. Nanoparticle iron medicinal products – Requirements for approval of intended copies of non-biological complex drugs (NBCD) and the importance of clinical comparative studies. Regul Toxicol Pharmacol. 2012;64(2):324-8.
12. Ehmann F, Sakai-Kato K, Duncan R, Hernán Pérez de la Ossa D, Pita R, Vidal JM, et al. Next-generation nanomedicines and nanosimilars: EU regulators’ initiatives relating to the development and evaluation of nanomedicines. Nanomedicine (Lond). 2013;8(5):849-56.
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Author for correspondence: Professor Philip Walson, MD, Editor-in-Chief, GaBI Journal |
Disclosure of Conflict of Interest Statement is available upon request.
Copyright © 2014 Pro Pharma Communications International
Permission granted to reproduce for personal and non-commercial use only. All other reproduction, copy or reprinting of all or part of any ‘Content’ found on this website is strictly prohibited without the prior consent of the publisher. Contact the publisher to obtain permission before redistributing.
Source URL: https://gabi-journal.net/first-asia-pacific-educational-workshop-on-non-biological-complex-drugs-nbcds-kuala-lumpur-malaysia-8-october-2013.html
Author byline as per print journal: Professor Stefan Mühlebach, PhD, Professor Arnold Vulto, PharmD, PhD, Jon SB de Vlieger, PhD, Vera Weinstein, PhD, Beat Flühmann, PhD, Vinod P Shah, PhD
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Introduction: Besides biologicals, a new class of complex drugs – non-biological complex drugs (NBCDs), e.g. liposomes, iron carbohydrate products and glatiramoids – has emerged. Originator NBCD products have been approved by established regulatory rules. However, their follow-on products comprise a challenge to the regulators, manufacturers, physicians and pharmacists. |
Submitted: 12 August 2013; Revised: 24 September 2013; Accepted: 27 September 2013; Published online first: 11 October 2013
The progress in pharmaceutical sciences and manufacturing techniques together with more targeted and better-tolerated pharmaceutical formulations gave rise to a new class of medicinal products with complex macromolecular (nanoparticulate) structures, the so-called non-biological complex drugs (NBCDs) [1, 2]. Amongst others, NBCDs comprise liposomes, iron carbohydrate products and glatiramoids. The complexity of these synthetic NBCDs may even exceed that of biologicals. Originator NBCDs have received regulatory approval based on proven quality, efficacy and safety and have been established for many years. Some NBCDs have already been introduced before the growing awareness about the specific issues related to the production and characterization of nanostructures. Accordingly, regulatory approval of NBCD follow-on products is subject to a lively discussion about the requirements to prove therapeutic equivalence and being eligible as substitute for the reference product.
The Non-Biological Complex Drugs Working Group at Dutch Top Institute Pharma, a public–private partnership in The Netherlands, is a network of scientific and clinical experts from academia, industry, regulatory bodies, and knowledge institutes to discuss specific aspects of the development and evaluation of NBCDs and give its expert opinion. This paper briefly summarizes the key discussion points of a closed workshop at the FIP (International Pharmaceutical Federation) Centennial Congress in 2012, organized by the FIP Board of Pharmaceutical Sciences, in order to assist the understanding of the regulatory challenges associated with NBCD follow-on products such as the definition of science-based policies for interchange and substitution. The closed workshop on invitation only was followed by an open discussion symposium the following day at the FIP Centennial Congress about the proposed terminology and a planned paper on points to consider for regulation [3, 4].
NBCD are defined as a medicinal product of non-biological origin with an active substance that is not a homo-molecular structure, but consists of different closely related and mostly nanoparticulate structures. Accordingly, there is not a single substance that can be isolated, quantitated and fully characterized or described by state-of-the-art physicochemical analytical means [4]. Changes in the composition and morphology of an NBCD can substantially influence the quality, biological properties and therapeutic profile of the medicinal product and result from minute variations in the manufacturing process [1, 2, 5]. However, not all structural changes and mechanisms that affect the therapeutic profile are fully understood. Notably, the complexity of NBCD prevents establishing full proof of pharmaceutical equivalence by state-of-the-art analytical means, which comprises one of the two pillars in the evaluation of a generic medicinal product, see Figure 1.
In contrast to the mainly direct and systemic drug-target interaction of small molecules with defined receptors in a concentration-dependent manner, most NBCDs comprise nanoparticles from which the active ingredient has to be released or formed and then transported to certain biological compartments where the intended activity should be performed. Even a slightly different release or formation rate of the active ingredient, e.g. due to differences in higher order structure of the precursor molecules, can negatively affect the safety and efficacy profile of an NBCD or its follow-on product. For example, in products for intravenous iron therapy such as iron carbohydrate nanoparticles, the highly reactive iron is bound in a polynuclear core, which in turn is stabilized by a carbohydrate shell. After intravenous administration, this complex is first phagocytized by monocytes where the iron is released and transiently stored before it is bound to transferrin and transported to the target tissue where it exerts its action, e.g. incorporation into newly synthesized erythrocytes in the bone marrow; or is stored in an accessible compartment for later physiological use [6, 7]. Hence, the biological activity of an NBCD is not necessarily correlated to its serum pharmacokinetics (central compartment), the generics pathway’s second pillar to show bioequivalence.
In the case of glatiramoids, products that comprise a complex mixture of polypeptides for the treatment of relapsing-remitting multiple sclerosis, even no pharmacokinetic profile and no validated biomarker for efficacy are available. However, although the originator, Copaxone®, and a follow-on product are similar in many physiochemical properties, e.g. size distribution, molar ratio of amino acids; sensitive chemical and biological analyses demonstrated differences between those products, e.g. gene expression patterns of glatiramoid-primed murine splenocytes [8].
In contrast to follow-on compounds of biologicals that are evaluated according to distinct biosimilar guidelines (originally established in the EU), some NBCD follow-on products are classified as generics although the two prerequisites for the generics approach cannot be fulfilled. As outlined above, the inability to fully characterize an NBCD prevents proof of pharmaceutical equivalence or clinically meaningful differences between a follow-on NBCD and its reference product. Moreover, bioequivalence assessment in healthy volunteers does not necessarily reflect the biological fate of and therapeutic response to an NBCD as outlined by the example of the iron sucrose complex below. Notably, this lack in proof of therapeutic equivalence and potential differences in tolerability or safety of NBCD follow-on products can easily become a concern since these products are often used as chronic treatment and in patients with already poor health states, e.g. iron carbohydrate products for haemodialysis patients, liposomal formulations of cytotoxic agents for cancer patients and glatiramoids for multiple sclerosis patients [1, 9, 10]. In such patients, even slight but clinically meaningful differences between the products may interfere with clinical success and thus the feasibility for interchange with the innovator’s product.
The potential clinical consequences of the above-mentioned differences could be illustrated by comparative clinical and non-clinical studies of a well-established NBCD (iron sucrose, Venofer®) and different follow-on preparations (iron sucrose similars, ISS). One study evaluated the effects of switching iron treatment from the iron sucrose originator to an ISS in 75 consecutive stable, haemodialysis-dependent chronic kidney disease patients who underwent at least 60 dialysis sessions before and after the switch at a French dialysis centre [11]. After the switch to an ISS, haemoglobin levels decreased rapidly and anaemia medication had to be increased to return to targeted haemoglobin levels after quite a lengthy re-adjustment period. In addition to this apparent lack of therapeutic equivalence of an ISS, other ISS were associated with an increased risk of adverse events (658 patients at a South Korean centre who had been treated with the iron sucrose originator or an ISS) [12], even if the originator iron sucrose has been well tolerated before (three case reports in Germany) [13]. Furthermore, non-clinical studies showed not only differences between ISS and the originator product [14] but also among different ISS [15], particularly with respect to off-target iron disposition from ISS and induction of oxidative stress and inflammation.
In many countries generics approval of follow-on products allows automatic substitution at the pharmacy level. Since the International Nonproprietary Names of the innovator’s and follow-on products are the same, clinicians, caregivers and patients are often not aware of the change in medication. In contrast to the substitutability and interchangeability of fully characterized small molecule generics with well-established therapeutic equivalence, approval for substitution or interchange of NBCD products should only be granted on the basis of appropriate non-clinical and/or clinical comparisons. Together with the comparability of physicochemical quality this would allow to exclude clinically meaningful differences between the NBCD follow-on products and the reference product [1, 2]. Lacking information in case of insufficient response or intolerance can lead to unnecessary diagnostic tests and use of potentially more invasive and more expensive treatment options [8, 10]. Overall, drug product replacement that is guided by acquisition cost only may increase other costs and not be cost-effective from the patient’s and payer’s perspective.
At the NBCD workshop in the course of the FIP Centennial Congress 2012, experts from academia, industry, regulatory bodies and knowledge institutes agreed that there is a need for a globally harmonized approach to authorize NBCD follow-on products. This approach should be linked to an accepted common terminology [4]. Also the requirements for an abbreviated procedure showing comparability between different types of NBCD follow-on products and feasible reference products should be clear. In order to approve an NBCD follow-on product that will be interchangeable with the innovator’s product, relevant and comparative clinical and/or non-clinical trials should be performed. Aims of these studies will be an appropriate characterization of the NBCD with up-to-date analytical techniques and to identify the extent of similarity with the originator product. Clinical trials should be sufficiently powered, conducted in patients rather than healthy volunteers to cover for disease-associated changes in pharmacokinetics (PK) and pharmacodynamics (PD). Furthermore, trials should include suitable biological tests to evaluate the similarity of PK, PD and safety/tolerability in populations with similar aetiology of the disease as for the aimed indication. For these means also surrogate efficacy and safety markers may be used. Based on the degree of similarity that could be confirmed by the results of such trials and markers, approval of an NBCD follow-on product can be gradually extended to allow for interchange or even automatic substitution in newly diagnosed patients or those on existing chronic treatment. Such a stepwise similarity approach towards totality of evidence can help manufacturers of follow-on products in the development of safe and effective products and to make a realistic prediction of development costs and timelines.
Furthermore, the expert panel indicated that post-approval pharmacovigilance for NBCD and follow-on products should be based on specific brand names as already proposed earlier [16]. An information exchange among treating healthcare professionals and eventually the patient is mandatory to allow for appropriate treatment and drug product traceability in the individual patient.
An increasing number of NBCDs including nanomedicines become target for development and introduction of follow-on products. Recent clinical data with NBCD follow-on products (iron sucrose) that were approved like small molecule generics revealed significant differences in efficacy and tolerability compared to the originator product. Accordingly, regulators are prompted to establish a global regulatory framework that considers the structural complexity and specific biological properties of NBCD and provides clear guidance for the development and documentation of safe and effective follow-on products. The experts from academia, industry, regulatory bodies and knowledge institutes at the FIP 2012 workshop suggest a stepwise similarity approach that includes appropriate clinical and/or non-clinical studies that evaluate markers of PK, PD (if applicable) and safety/efficacy in relevant patient populations. As long as proof of therapeutic equivalence and similar safety profiles by appropriate studies is missing, interchange and automatic substitution between NBCDs and their follow-on products should be discouraged. Overall, a critical review of the current and emerging regulation of NBCDs and NBCD follow-on products encourage further multidisciplinary research and consensus discussions among all stakeholders to develop guidance towards the definition of an NBCD and the development of NBCD follow-on products [3].
Medical writing support was provided by Mr Walter Fürst, SFL Regulatory Affairs and Scientific Communication, Switzerland, and funded by Vifor Pharma Ltd.
Disclosure of financial and competing interests: This manuscript was written within the framework of the Non-Biological Complex Drugs Working Group, hosted at Dutch Top Institute Pharma. The NBCD Working Group is currently supported by Sanofi, Teva Pharmaceutical Industries Ltd and Vifor Pharma International Inc. Professor Stefan Mühlebach is an employee of Vifor Pharma Ltd, Dr Vera Weinstein is an employee of Teva Pharmaceutical Industries, and Dr Beat Flühmann is an employee of Vifor Fresenius Medical Care Renal Pharma.
Provenance and peer review: Not commissioned; externally peer reviewed.
Professor Stefan Mühlebach1,2, PhD
Professor Arnold Vulto3, PharmD, PhD
Jon SB de Vlieger4, PhD
Vera Weinstein1,5, PhD
Beat Flühmann1,6, PhD
Vinod P Shah1, PhD
1Steering Committee member, NBCD Working Group, TI Pharma, Leiden, The Netherlands
2Vifor Pharma Ltd, Glattbrugg, Switzerland
3Erasmus University Medical Center, Hospital Pharmacy, Rotterdam, The Netherlands
4TI Pharma, PO Box 142, NL-2300 AC Leiden, The Netherlands
5Teva Pharmaceutical Industries, Petach Tikva, Israel
6Vifor Fresenius Medical Care Renal Pharma, St Gallen, Switzerland
References
1. Borchard G, Fluhmann B, Muhlebach S. Nanoparticle iron medicinal products—requirements for approval of intended copies of non-biological complex drugs (NBCD) and the importance of clinical comparative studies. Regul Toxicol Pharmacol. 2012;64(2):324-8.
2. Schellekens H, Klinger E, Mühlebach S, et al. The therapeutic equivalence of complex drugs. Regul Toxicol Pharmacol. 2011;59(1):176-83.
3. Schellekens H, Stegemann S, Weinstein V, et al. How to regulate nonbiological complex drugs (NBCD) and their follow-on versions: points to consider. AAPS J. 2013 Sep 25. doi:10.1208/s12248-013-9533-z
4. Crommelin DJ, de Vlieger JS, Weinstein V, et al. Different pharmaceutical products need similar terminology. AAPS J. 2013 Sep 25. doi:10.1208/s12248-013-9532-0
5. Ehmann F, Sakai-Kato K, Duncan R, et al. Next-generation nanomedicines and nanosimilars: EU regulators’ initiatives relating to the development and evaluation of nanomedicines. Nanomedicine (Lond). 2013;8(5):849-56.
6. Evstatiev R, Gasche C. Iron sensing and signalling. Gut. 2012;61(6):933-52.
7. Geisser P, Burckhardt S. The pharmacokinetics and pharmacodynamics of iron preparations. Pharmaceutics. 2011;3(1):12-33.
8. Bakshi S, Chalifa-Caspi V, Plaschkes I, et al. Gene expression analysis reveals functional pathways of glatiramer acetate activation. Expert Opin Ther Targets. 2013;17(4):351-62.
9. Mamidi RN, Weng S, Stellar S, et al. Pharmacokinetics, efficacy and toxicity of different pegylated liposomal doxorubicin formulations in preclinical models: is a conventional bioequivalence approach sufficient to ensure therapeutic equivalence of pegylated liposomal doxorubicin products? Cancer Chemother Pharmacol. 2010;66(6):1173-84.
10. Varkony H, Weinstein V, Klinger E, et al. The glatiramoid class of immunomodulator drugs. Expert Opin Pharmacother. 2009;10(4):657-68.
11. Rottembourg J, Kadri A, Leonard E, et al. Do two intravenous iron sucrose preparations have the same efficacy? Nephrol Dial Transplant. 2011;26(10):3262-7.
12. Lee ES, Park BR, Kim JS, et al. Comparison of adverse event profile of intravenous iron sucrose and iron sucrose similar in postpartum and gynecologic operative patients. Curr Med Res Opin. 2013;29(2):141-7.
13. Stein J, Dignass A, Chow KU. Clinical case reports raise doubts about the therapeutic equivalence of an iron sucrose similar preparation compared with iron sucrose originator. Curr Med Res Opin. 2012;28(2):241-3.
14. Toblli JE, Cao G, Oliveri L, et al. Comparison of oxidative stress and inflammation induced by different intravenous iron sucrose similar preparations in a rat model. Inflamm Allergy Drug Targets. 2012;11(1):66-78.
15. Toblli JE, Cao G, Giani J, et al. Different effects of European iron sucrose similar preparations and originator iron sucrose on nitrosative stress, apoptosis, oxidative stress, biochemical and inflammatory markers in rats. NDT Plus 2011;4 [abstract]:SuO028.
16. Wysowski DK, Swartz L, Borders-Hemphill BV, et al. Use of parenteral iron products and serious anaphylactic-type reactions. Am J Hematol. 2010;85(9):650-4.
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Author for correspondence: Professor Stefan Mühlebach, PhD, Vifor Pharma Ltd, CH-8152 Glattbrugg, Switzerland |
Disclosure of Conflict of Interest Statement is available upon request.
Copyright © 2013 Pro Pharma Communications International
Permission granted to reproduce for personal and non-commercial use only. All other reproduction, copy or reprinting of all or part of any ‘Content’ found on this website is strictly prohibited without the prior consent of the publisher. Contact the publisher to obtain permission before redistributing.
Source URL: https://gabi-journal.net/the-authorization-of-non-biological-complex-drugs-nbcds-follow-on-versions-specific-regulatory-and-interchangeability-rules-ahead.html
Author byline as per print journal: Jon SB de Vlieger1, PhD; Professor Daan JA Crommelin2, PhD; Beat Flühmann3, PhD; Professor Imre Klebovich4, PharmD, PhD, DSc; Professor Stefan Mühlebach3,5, PhD; Vinod P Shah6, PhD
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Abstract: |
Submitted: 28 August 2019; Revised: 9 September 2019; Accepted: 10 September 2019; Published online first: 23 September 2019
The 3rd International Symposium on Scientific and Regulatory Advances in Biological and Non-Biological Complex Drugs: A to Z in Bioequivalence was organized in Budapest, Hungary on 12–14 November 2018 by the Department of Pharmaceutics of Semmelweis University with other Hungarian science organizations under the auspices of the International Pharmaceutical Federation (FIP), European Federation of Pharmaceutical Sciences (EUFEPS) and the NBCD Working Group hosted by Lygature [1]. The aim of the conference was to provide an update on the progress in the field by experts and to discuss recent developments in the regulatory status of nanomedicinal drug products in moderated panels with stakeholders. A widespread international group of experts from originator and generic drug companies, regulatory authorities, academia and contract research organizations participated in the meeting and discussion sessions. The conference introduced and discussed in detail the US Government Accountability Organization (GAO) report [2] on non-biological complex drugs (NBCDs) together with the US Food and Drug Administration (FDA) draft guidance on drug products containing nanomaterials [3] and the possibility of global harmonization of regulatory policies regarding NBCD products. This report highlights the main conclusions of the meeting and lists a number of topics that would benefit from further debate within the scientific and regulatory community.
The meeting was structured to discuss the following key questions:
– What is equivalence and why does it need our attention?
– Will recent technology developments solve the challenges in determining Critical Quality Attributes (CQAs) of complex drug products?
– Can the successful biosimilar development approach inspire the development of nanosimilars?
– Is there a possibility for global harmonization of regulatory policies for NBCD products and other complex drug products?
In the sections below, we summarize the discussions held during the meeting, in an attempt to answer these key questions.
What is equivalence and why does it need our attention?
Generic drug manufacturers are generally seeking therapeutic equivalence (TE) designation for their drug, as this is a prerequisite for substitution and/or interchangeability with the reference drug product (Orange Book in the US [4). Therapeutic equivalence means that the product is pharmaceutically equivalent (PE) and bioequivalent (BE) to the brand-name product, i.e. PE + BE = TE. Drug products are considered pharmaceutically equivalent if they contain the same active ingredient(s) in the same dosage form, are taken via the same route of administration and are identical in dose. Bioequivalence can be demonstrated using pharmacokinetic, or pharmacodynamic approaches, comparative clinical trials or an in vitro bioequivalence method. Already for decades, these approaches are successfully applied to small molecule drug products for drug approval. Because of the complexity of biological and NBCD products, developers encounter challenges in applying the TE concept.
For follow-on versions of biological products (biosimilars), extensive comparative characterization and preclinical studies are required followed by a limited set of clinical studies to demonstrate safety and efficacy. This may demonstrate similarity but not ‘automatically’ therapeutic equivalence. This biosimilar approach has been introduced and regularly evaluated and updated by the European Medicines Agency (EMA) and is currently considered an established, science-based regulatory approach. FDA has introduced its biosimilar approach as well, which essentially follows the EMA principles.
Determination of TE, through PE and BE, of NBCD products, including nanomedicines, can be a significant challenge. The first discussion on this issue in Budapest in 2014 identified the problem and indicated that CQAs are key to determine TE [5]. The preferred regulatory pathways to establish TE for NBCDs was debated during a number of meetings, including at the New York Academy of Sciences in 2016 [6] and subsequently at the second conference in Budapest in 2016 [7]. Because of the difficulties involved in assessing equivalence with the originator NBCD products, concerns have been raised about safety and efficacy that might appear only after the follow-on versions are introduced on the market.
During the discussions, the topic of consistent terminology has also been raised. Earlier in 2014, a terminology paper was released by the NBCD Working Group [8]. Since then, several new items popped up and the most recent discussion on terminology has evolved around using the terms ‘generic’, ‘follow-on’ and ‘similar’. In a recent publication, Marden et al. make an important statement that terminology in the regulatory field should be used correctly and consistently [9]. As the word ‘generic’ implies therapeutic equivalence and substitutability, this report refers to follow-on products and similars for complex drug products that cannot be fully characterized by physicochemical characterization. The term complex generic is mainly used by FDA and EMA tends to use follow-on, and/or similar.
Will recent technology developments solve the challenges in determining Critical Quality Attributes of complex drug products?
Identification and a thorough (physicochemical) characterization of CQAs is an important step towards the development of a follow-on or similar complex drug product. According to ICH ‘a CQA is a physical, chemical, biological, or microbiological property or characteristic that should be within an appropriate limit, range, or distribution to ensure the desired product quality’. In other words, a critical attribute is a property of which its variation will adversely impact the quality and the clinical profile of the product. At present, both EMA and FDA have adopted a stepwise approach in similarity determination of biosimilars. The development of a biosimilar product therefore requires a thorough comparative in vitro (physico-)chemical characterization of (critical) quality attributes of the test product with the reference product. These thorough analytical comparability studies are followed by non-clinical and clinical studies.
Acknowledging the present challenges to assess CQAs for NBCD products and their design space (DS) that would lead to PE, attention should be paid to further research on elucidating mechanisms of action and on the development and validation of relevant analytical techniques.
This is broadly recognized as, in the meeting, recent developments in state-of-the-art technologies were presented. More importantly, examples were presented how these technologies were applied in the process of characterizing complex drug products. Although the relevance of application of such advanced technologies is to be seen on a product-by-product basis, the progress in technology development for sure impacts the efficiency of characterization activities and brings CQA/DS information closer by.
Can the successful biosimilar development approach inspire the development of nanosimilars?
In a report on an earlier meeting in the SRACD Conference series, the similarities between the complexity of biological and non-biological complex drug products and the implications for TE assessment [5] were pointed out. These discussions continued and the idea of applying the biosimilar paradigm to other complex drug products gained traction. Very concretely, following a publication by authors from EMA, a nanosimilar evaluation process was suggested using the ‘totality of evidence’ concept with a stepwise procedure [10]. This stepwise procedure includes physicochemical structural characterization, animal toxicity studies, in vivo comparative equivalence studies (PK/PD).
For example, in a series of reflection papers for intravenous iron-based nano-colloidal products EMA (proposes a stepwise procedure and ‘totality of evidence’ approach [11].
The success of a new drug modality concept is depending on more factors than appropriate regulatory frameworks alone. In the end, the adoption of new technology and its related products needs multi-stakeholder support. A major effort by different stakeholders was made to explain the scientific background of the biosimilar concept and clinical experience with these biosimilars to healthcare professionals [12]. The EMA brochure on biosimilars from 2017 is a good example of such an effort [13]. Stakeholders in the nanomedicine field should use this successful example of a policy to inform healthcare professionals about the specific challenges encountered with nanosimilars, now and in the future. A first step has already been made by Astier et al. by publishing a list of factors to consider when selecting a nanosimilar [14].
Is there a possibility for global harmonization of regulatory policies for NBCD products and other complex drug products?
The success of harmonization efforts can be judged when comparing the content of guidance documents and reflection papers by the regulatory authorities. A prominent example of guidance documents that could be harmonized are those concerning the approval of follow-on doxorubicin liposome formulations.
Liposomes are one of the most important classes of NBCD products that are used since years in patients. The complexities of liposomal drug products are recognized and dealt with in the FDA and EMA guidance reflection documents. Major efforts were undertaken through the Global Bioequivalence Harmonization Initiative, with participation of EMA and FDA, to align the approaches by the two regulators. It is important to differentiate between nice-to-know and need-to-know requirements. At present, and despite the harmonization exercise, FDA and EMA have taken different decisions on essentially the same follow-on formulation of Doxil®. Moreover, very recently, a case study was published describing the authorization of a generic version Copaxone® in Europe and the US. Whilst EMA requested a full clinical assessment programme, US FDA approved a follow-on version of Copaxone without any clinical data supporting therapeutic equivalence. The approval of these follow-on versions evaluated through different approaches by both agencies leaves open questions on the equivalence of these drug products [15].
In response to concerns raised by the scientific community, the US Government Accountability Office (GAO) was asked to assess FDA’s process of reviewing follow-on versions of NBCD products. In the conclusion and recommendations section, the GAO report underlined the scientific challenges involved when demonstrating equivalence between brand and generic NBCD products [2]. One of the main conclusions was that although all stakeholders agreed that demonstration of equivalence of follow-on NBCDs is scientifically challenging, no agreement could be found on how to move forward and whether the current legislation is sufficient. See Table 1 for a list of conclusions distilled from the full report.
Of note, shortly after the release of the GAO report, FDA issued a draft guidance for industry in December 2017 on ‘Drug products including biological products that contain nanomaterials’ [3]. The agency identified 11 key factors for the assessment of drug products containing nanomaterials. To discuss this draft guidance, an AAPS Guidance Forum workshop was held in September 2018 in Washington DC and the report of that workshop was published earlier in 2019 [16].
In Europe, the debate on whether similar versions of NBCD products should follow the centralized approval procedure are ongoing. A recent approval of an iron carbohydrate similar through the hybrid 10(3) pathway instead of earlier 10(1) generic drug approvals indicates that the field is moving. An overview of all NBCD products and their follow-on versions approved in Europe was recently published by Klein et al., presenting an interesting view on how these products were approved over the years and where the regulatory system may be improved [17].
Just before resigning from office, the former FDA Commissioner Scott Gottlieb voiced his opinion in support of an ICH approach in the area of complex generic drug products [18]. It is to be seen how this will develop, but the scientific and regulatory community should be ready to engage in discussions to increase coherence in the regulatory approach for this type of products.
The meeting successfully brought together experts from all relevant stakeholders, including regulatory authorities, academic institutes, generic and innovative pharmaceutical companies. Participants came from all over the world (five continents, 44 countries) and actively participated in the debates. It is important to note that compared to previous SRACD meetings, significant progress was made in formulating answers to the above four questions. Progress may have been made, but there was also a clear call for action to take the international discussions around alignment and harmonization to the next level.
This paper may include opinions of the authors and not necessarily the opinions of their employers. Authors JdV, DC, BF, IK, SM, VS are members of the Non-biological Complex Drugs Working Group, hosted at Lygature, The Netherlands (www.lygature.org/NBCD).
The authors declare that there is no funding received to prepare this manuscript.
Competing interests: BF and SM are employees of Vifor Pharma Ltd, Glattbrugg, Switzerland.
Provenance and peer review: Not commissioned; externally peer reviewed.
1Foundation Lygature, 6 Jaarbeursplein, NL-3521 AL Utrecht, The Netherlands
2Department of Pharmaceutics, Utrecht University, Utrecht, The Netherlands
3Vifor Pharma Ltd, Glattbrugg, Switzerland
4Semmelweis University, Department of Pharmaceutics, Budapest, Hungary
5Department Pharmaceutical Sciences, Unit of Clinical Pharmacy and Epidemiology, University of Basel, Basel, Switzerland
6VPS Consulting LLC, North Potomac, MD, USA
References
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Author for correspondence: Jon SB de Vliegr, PhD, Coordinator, NBCD Working Group, p/a Foundation Lygature, 6 Jaarbeursplein, NL-3521 AL Utrecht, The Netherlands |
Disclosure of Conflict of Interest Statement is available upon request.
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