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Hi,
Whether we need to tighten the BE limits for Narrow Therapeutic Index drug
intended for US submission and MCC.?
Regards,
Narasimha Reddy
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The following message was posted to: PharmPK
You will need to consult Guidance for Industry for BE requirements (if any) for
your specific product. If not, you need to check if your product qualifies as
High Variability Product - the BE criteria might be different for them. Else,
the regular BE criteria would apply.
Joga Gobburu, PhD, FCP, MBA | Professor | School of Pharmacy | School of
Medicine
Executive Director |Center for Translational Medicine
N407, 20 N Pine, Baltimore, MD-21201
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The following message was posted to: PharmPK
Dear Narasimha,
EMA: See the BE GL (2010), Section 4.1.9.
The limits may have to be tightended to 90.00-111.11 but there is no list of
NTDIs (like e.g. in Canada), the decision must be done on a case by case basis.
In doubt go for a scientific advice. Only tacrolimus and ciclosporine were taken
through a referral procedure and a decision was already made by the PK working
party. See the Q&A document from Feb 2012:
http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2009/09/WC500002963.pdf
Tacrolimus: 90-111% for AUC and 80-125% for Cmax.
Ciclosporine: 90-111%, both for AUC and Cmax.
FDA: See the general BE guidance (2003), Section VI. F.
Check the product specific guidances at:
http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm075207.htm
Currently FDA is considering a scaling approach narrowing the acceptance range
based on the intra-subject CV of the reference (requires a replicate design).
For details see the 'Slides for the July 26, 2011 Meeting of the Advisory
Committee for Pharmaceutical Science and Clinical Pharmacology' at:
http://www.fda.gov/AdvisoryCommittees/CommitteesMeetingMaterials/Drugs/AdvisoryCommitteeforPharmaceuticalScienceandClinicalPharmacology/ucm266768.htm
Best regards,
Helmut
-
Ing. Helmut Schuetz
BEBAC - Consultancy Services for
Bioequivalence and Bioavailability Studies
Neubaugasse 36/11
1070 Vienna, Austria
e-mail helmut.schuetz.at.bebac.at
web http://bebac.at/
forum http://forum.bebac.at/
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I think it is right to take cases individually as Helmut says it is in the US.
What would be the purpose of tightening these limits? =46rom a regulatory point of
view it would have to be to stop inadequate formulations getting to the market.
But if they are inadequate I would not expect them to be put onto the market
anyway...the dose response would be too erratic; by which I mean poor efficacy
in some patients and excess adverse effects in others. So what company would
take on such a product?
It raises the question of whether we are satisfied with the current limits. Do
they really mean that absorption is as predictable as it should be?
It's interesting that the Canadians haven't left it to industry ... to make this
mistake?
Andrew Sutton
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