1AAAA PROGRPROGRPROGRPROGRAMME FOR THE DEVELOPMENT ANDAMME FOR THE DEVELOPMENT ANDAMME FOR THE DEVELOPMENT ANDAMME FOR THE...
2ContentsContents............................................................................................................
3Defining the needs from the beginning.......................................................................................
5implications for safety and function. This was spelt out in s recent report when a pharmaceutical contributor (Genentech,...
6(A) Highly similar to the reference product notwithstanding minor differences in clinically inactive components; and(B). ...
7The Fusion Alliance is a group of companies whose activities are focussed on the delivery of drug development services in...
17• 46 beds in 5 clinical investigation areas with 8 monitored beds plus 2 beds with invasive capability• Infusion pumps a...
22In collaboration with other members of the group, our regulatory and P-V partner will assess the whole programme andwill...
24Identification of the reference products.Identification of the reference products.Identification of the reference produc...
25major incentive to clients which needs to be accommodated. This approach has so far not been recognised by regulatorswho...
262. It is essential in these classes of drug to have a measure of the likelihood of the new biological or biosimilar toin...
28conducive to the performing of Phase I studies of biosimilars both in Oncology and in non-Oncology indications. Howevert...
29Fusion’s ability to deliver in the Phase III arena.Fusion’s ability to deliver in the Phase III arena.Fusion’s ability t...
30The Preparation of the MThe Preparation of the MThe Preparation of the MThe Preparation of the Marketing Dossierarketing...
31APPENDIXAPPENDIXAPPENDIXAPPENDIX 1111MINISTRY OF HEALTH MALAYSIAMINISTRY OF HEALTH MALAYSIAMINISTRY OF HEALTH MALAYSIAMI...
32The purpose of this guidance document is:• To introduce the concept of biosimilars;• To outline the basic principles to ...
332.3.3.2 Pharmacodynamic studies (PD) 142.3.3.3 Comparative PK/PD studies 142.3.3.4 Clinical efficacy trials 14-152.3.3.5...
341.0 INTRODUCTION1.0 INTRODUCTION1.0 INTRODUCTION1.0 INTRODUCTIONBiopharmaceuticals are protein molecules derived from bi...
35on the current analytical techniques, two biologicals produced by different manufacturing processes cannot be shown to b...
361.4Policy st1.4Policy st1.4Policy st1.4Policy statementsatementsatementsatementsThe following policy statements outline ...
371.4.81.4.81.4.81.4.8 Non-clinical and clinical requirements outlined for biosimilar submission inthis guidance document ...
38• CPMP/BWP/328/99 Development Pharmaceutics for Biotechnological and Biological Products . Annex to Note ofGuidance on D...
39• Annex guideline on similar biological medicinal products containing biotechnology-derived proteins as activesubstances...
402.2 QUALITY GUIDELINES2.2 QUALITY GUIDELINES2.2 QUALITY GUIDELINES2.2 QUALITY GUIDELINESThe quality part of a biosimilar...
41• Quality differences may impact the amount of non-clinical and clinical data needed, and will be a case by caseapproach...
42• Extensive state-of-the-art analytical methods should be applied to maximise the potential for detecting.slight differe...
43quality attributes for batch release should be validated in accordance with ICH guidelines (ICH Q2A, Q2B,Q5C, Q6B), as a...
44stages, much like a traditional program. Proposed indications for biosimilar must be identical or within the scope ofind...
45help assess, as part of the comparability exercise, if structural differences exist between the biosimilarand the refere...
46• Sufficient knowledge of PD parameters is available• At least one PD marker is accepted as surrogate marker fo refficac...
472.3.3.62.3.3.62.3.3.62.3.3.6 Pharmacovigilance Plan/Risk Management Plan (RMP)Pharmacovigilance Plan/Risk Management Pla...
48As regards the amount/kind of data requirements for a biosimilar application, the one size fits all. approach cannot bea...
49characteristics and pharmacological class of a product, it was decided that no distinctive INN designation should be use...
50Appendix 2.Appendix 2.Appendix 2.Appendix 2.Example of a Biosimilar programme; Erythropoeitin biosimilarExample of a Bio...
51
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This is an overview of the members of Fusion and our approach to biologicals

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  1. 1. 1AAAA PROGRPROGRPROGRPROGRAMME FOR THE DEVELOPMENT ANDAMME FOR THE DEVELOPMENT ANDAMME FOR THE DEVELOPMENT ANDAMME FOR THE DEVELOPMENT ANDREGREGREGREGISTRATION OF NEW BIOSIMILARS ANDISTRATION OF NEW BIOSIMILARS ANDISTRATION OF NEW BIOSIMILARS ANDISTRATION OF NEW BIOSIMILARS ANDBIOLOGICALS IN VBIOLOGICALS IN VBIOLOGICALS IN VBIOLOGICALS IN VAAAARIOUS GEOGRAPHIES.RIOUS GEOGRAPHIES.RIOUS GEOGRAPHIES.RIOUS GEOGRAPHIES.Dr Maurice R CrossGroup Medical Director,Veeda Clinical Research and Fusion (SE Asia)
  2. 2. 2ContentsContents.......................................................................................................................................................................................................................2Introduction...............................................................................................................................................................................................................4Biosimilars are not biological generics.........................................................................................................................................................4Structuring a development programme for maximum marketing effectiveness.............................................................................5The membership of the Fusion Alliance............................................................................................................................................................7CPR Services (Australia and Singapore)............................................................................................................................................................8................................................................................................................................................................................................................................10Pre-clinical services through CPR................................................................................................................................................................10Kitasato Medical Centre, Tokyo, Phase I Unit..................................................................................................................................................11Prince Court Hospital............................................................................................................................................................................................12Prince Court Radiology and Nuclear Medicine Services........................................................................................................................12Prince Court Clinical laboratories................................................................................................................................................................13Phase I Oncology...............................................................................................................................................................................................13Veeda Clinical Research and Bio-analytical laboratories in India and Malaysia..................................................................................14Veeda Clinical Research, Shevalik Ahmedabad.......................................................................................................................................14Veeda Clinical Research, Insignia Building...............................................................................................................................................15Veeda Clinical Research, Malaysia – The CVM Unit..............................................................................................................................16Quality Assurance Services.............................................................................................................................................................................18Galen Ventures JLT................................................................................................................................................................................................20Consultants to the Fusion Alliance...................................................................................................................................................................20Marie-Paule Derde and Leonard Kaufmann...........................................................................................................................................20The Components of the Fusion Biosimilar programme:..............................................................................................................................21
  3. 3. 3Defining the needs from the beginning....................................................................................................................................................21Gap analysis. ......................................................................................................................................................................................................22The design of the programme.......................................................................................................................................................................22Identification of the reference products....................................................................................................................................................24Physico-chemical and Pharmaceutical presentation of the biosimilar..............................................................................................25Bioanalysis and Immunogenicity.................................................................................................................................................................25Pre-clinical and safety studies......................................................................................................................................................................26Phase I studies including glucose clamp studies....................................................................................................................................26Phase I studies in Malaysia and India........................................................................................................................................................27Proof-of-Concept and Phase 3 studies......................................................................................................................................................28Fusion’s ability to deliver in the Phase III arena......................................................................................................................................29The Preparation of the Marketing Dossier...............................................................................................................................................30Communicating with the Regulatory Authorities..................................................................................................................................30Pharmaco-vigilance before and after the MA..........................................................................................................................................30APPENDIX 1..............................................................................................................................................................................................................31MINISTRY OF HEALTH MALAYSIA NATIONAL PHARMACEUTICAL CONTROL BUREAU GUIDANCEDOCUMENT AND GUIDELINES FOR REGISTRATION OF BIOSIMILARS IN MALAYSIA......................................................31Appendix 2...............................................................................................................................................................................................................50Example of a Biosimilar programme; Erythropoeitin biosimilar.............................................................................................................50
  4. 4. 5implications for safety and function. This was spelt out in s recent report when a pharmaceutical contributor (Genentech,owned by Roche) has taken the position that.“the properties of the biologic often depend directly on the nature of the manufacturing process. Furthermore, proteinshave unique structural organization patterns (referred to as “folding”) that affect the way that they work in the body; evenbiologics that are chemically the same may have differing biological effects due to differences in the structural folding.An example of this folding effect is the difference between a raw egg and a cooked one: chemically the two are the same, butthey are physically and biologically very different.”11 The company supports clinical trials for each biosimilar indication.In the same review. Amgen who registered the first biosimilar in the EU, in testimony before the FDA, asserted that half ofthe biosimilars developed in Europe had unexpected clinical outcomes, and therefore relying on pharmacokinetic andpharmacodynamic studies alone should never be enough.From an economic standpoint, the critical issue in biologics, as opposed to small molecules, may be in convincing doctors,patients and other healthcare stakeholders that the follow-on has demonstrated sufficient similarity to risk adopting it overthe pioneer product.Structuring a development programme for maximum marketing effectiveness.Structuring a development programme for maximum marketing effectiveness.Structuring a development programme for maximum marketing effectiveness.Structuring a development programme for maximum marketing effectiveness.Companies producing these molecules may seek optimisation of their development and regulatory programmes so as toeffectively market their pharmaceuticals to as many countries as possible with a single package which is designed from thebeginning to meet as many different regulatory authorities as possible in a single acceptable programme. Typically abiosimilar biologics manufacturing company would wish to market their pharmaceutical in the USA, EU and then asmany other jurisdictions as possible. This is further complicated by the desire of generic manufacturers to produce notonly Biosimilars but that category of Biosimilar which is regarded as ‘an interchangeable’. An interchangeable productmust meet all the same requirements as a biosimilar and in addition have the same route of administration, dosage formand strength as the reference product. An interchangeable “may be substituted for the reference product without theintervention of the health care provider who prescribed the reference product.”In 2010, the United States enacted the Biologics Price Competition and Innovation Act (BPCI) which defined the path forthe registration of Biosimilars. The European pathway had existed since 2005 and the arrival of the US brought bothjurisdictions very close together but with a number of significant differences. Within the US act, the biosimilar is welldefined as:
  5. 5. 6(A) Highly similar to the reference product notwithstanding minor differences in clinically inactive components; and(B). No clinically meaningful differences between the biological product and the reference product in terms of the safety,purity, and potency of the product.”Protection to the original manufacturer of the biological is afforded for 12 years during which time the FDA will not grant abiosimilar application until the expiry of the of the original biologic license.
  6. 6. 7The Fusion Alliance is a group of companies whose activities are focussed on the delivery of drug development services inthe APAC and South East Asian region. Working together in a manner analogous to the ‘Star Alliance’ of the airlineworld, we aim to provide our clients with a complete and seamless service of drug development, marketing and pharmaco-vigilance which will take the client from the first steps in clinical evaluation of their biosimilar through the process ofpreparing the Marketing Authorisation Dossier and then registration in various jurisdictions with a sophisticated globalpharmaco-vigilance package to support the marketing effort.The membership of theFusion Alliance.The membership of theFusion Alliance.The membership of theFusion Alliance.The membership of theFusion Alliance.The Fusion Alliance consists of a number of companies, mostly but not exclusively based in the Asian Region who are ableto offer global support in this endeavour. The geographical location of the members are represented on the following map.
  7. 7. 17• 46 beds in 5 clinical investigation areas with 8 monitored beds plus 2 beds with invasive capability• Infusion pumps and drivers to beds; GE Medical ECG equipment linked to MUSE for TQT• Located in a General Hospital with direct links to Intensive Care Unit and emergency facilities• Normal and patient populations• Quality Assurance / Quality Control, Project Management, Data Management and other support servicesprovided through Veeda’s existing operations located at India and BelgiumMalaysia is a modern Asian Country with a multi-ethnic population of approximately 28 million people. Malays andIndians amount to 63% of the population and they are pharmacogenetically similar to Europeans while Chinese consists of35% of the population. Malaysia delivers a high standard of modern health care to its citizens through 137 public and 217private hospitals in the major towns and cities. Treatment is of subsidised charge at the point of delivery at publichospitals.The Network of Clinical Research Centre is established in 2007 to coordinate the conduct of clinical research at MOHfacilities and to provide a direct route for sponsors to gain access to clinical trial populations. There are 27 hospitals withClinical Research Centre (CRC) Office specifically to act as the centre of communication and feed-back information onpatient availability. Clinical trial participating centres may be large general hospitals, public health clinics or academicinstitutions. From the CRC offices on site, integration with the Patient Registry System and access to patient populationsin all Malaysian MOH hospitals is originated and controlled. A list of GCP certified investigators is maintained at CRC.Lists of current trials are kept so that true availability of subjects can be ascertained. The regulatory processes in Malaysiaare very client friendly and transparent. Malaysia has one of the most sophisticated registries of disease in the world.Access to this registry provides for rapid and well targeted recruitment into clinical trials. This is an area which we willutilize for effective patient recruitment for the clinical trial studies.Regulatory InformationTo perform a clinical trial in Malaysia, submissions are required to be made to the following bodies:• Medical Research Ethics Committee, MOH (Central EC) for approval via an online National Medical ResearchRegister (NMRR)• CRC, MOH for institutional review via NMRR
  8. 8. 22In collaboration with other members of the group, our regulatory and P-V partner will assess the whole programme andwill investigate the needs of the programme and things which need to be included in order to achieve registration in asmany jurisdictions as possible, In collaboration with the clinical and laboratory partners, a programme of trials and filingsneeds to be spelt out and designed and the cost calculated. The impact of different geographies will have not only a costimpact but also an earnings impact and this needs to be fully evaluated in terms of potential markets. We will undertaketo evaluate your markets and assist you in defining the best selection of countries and the trials package which would beappropriate.Gap analysis.Gap analysis.Gap analysis.Gap analysis.An important part of designing the trial is the performing of a Gap Analysis. Upon client request, we will work within theAlliance to review the client dossier from manufacture through to the available studies and perform a gap analysis to revealwhere there are potential deficiencies or weaknesses which might need to be put right in order to facilitate the registrationof the product. This will be a team effort, led by Product Life, and will ensure a smoother and faster passage through theregulatory hurdles which may lie ahead.The design of the programme.The design of the programme.The design of the programme.The design of the programme.In designing the total programme for a biosimilar, there are a number of steps which will be almost the same in terms ofphases, independent of the nature of the biosimilar. The problem of biosimilars has been well expressed in the EMEAGuidance on Biosimilars (EMEA, 2005) but applies in most jurisdictions where it is stated:‘Due to the complexity of biological/biotechnology-derived products the generic approach is scientifically not appropriatefor these products. The ” similar biological medicinal products” approach, based on a comparability exercise, will then havetobe followed….’.The views of the EU and FDA with respect to biologicals and more, biosimilars have been well defined (EMEA, 2005).
  9. 9. 24Identification of the reference products.Identification of the reference products.Identification of the reference products.Identification of the reference products.In preparing a trial of a biosimilar, great thought has to go into the definition of the reference product. Generally whenconsidering a market, the reference product should be chosen from those which are already available in that market. Insome cases such as insulins, this is fairly easy whereas in other cases it is much more difficult. This is again well describedin the EMEA document (EMEA, 2005) which states specifically that;2.22.22.22.2 CHOICE OF REFERENCE PRODUCTCHOICE OF REFERENCE PRODUCTCHOICE OF REFERENCE PRODUCTCHOICE OF REFERENCE PRODUCT....The chosen reference medicinal product must be a medicinal product authorised in the Community, on the basis of acomplete dossier in accordance with the provisions of Article 8 of Directive2001/83/EC, as amended.The chosen reference medicinal product, defined on the basis of its marketing authorisation in the Community, should beused throughout the comparability program for quality, safety and efficacy studies during the development of a similarbiological medicinal product in order to allow the generation of coherent data and conclusions.Data generated from comparability studies with medicinal products authorised outside the Community may only providesupportive information.The active substance of a similar biological medicinal product must be similar, in molecular and biological terms, to theactive substance of the reference medicinal product. For example, a medicinal product containing interferon alfa-2amanufactured by Company X claimingto be similar to another biological medicinal product should refer to a referencemedicinal product containingas its active substance interferon alfa-2a. Therefore, a medicinal product containinginterferon alfa-2b could not be considered as the reference medicinal product.The pharmaceutical form, strength and route of administration of the similar biological medicinal product should be thesame as that of the reference medicinal product. When the pharmaceutical form, the strength or the route ofadministration is not the same; additional data in the context of the comparability exercise should be provided. Anydifferences between the similar biological medicinal product and the reference medicinal product will have to be justifiedby appropriate studies on a case-by-case basis.Consultation with the EMEA is highly recommended to discuss all those issues.A particular challenge to the industry now is the desire for manufacturers to produce progressively cleaner formulationswhich reduce the risk of safety concerns. This has given rise to the term ‘Biobetter’Biobetter’Biobetter’Biobetter’ and we recognise that this may be a
  10. 10. 25major incentive to clients which needs to be accommodated. This approach has so far not been recognised by regulatorswhose guidelines focus on the biosimilar being the same or ‘not worse’. The concept of the biobetter is important whenselecting the reference compound. How, for instance, would a reference compound be regarded if a ‘biobetter’ really werebetter?PhysicoPhysicoPhysicoPhysico----chemical and Pharmaceutical presentation of the biosimilar.chemical and Pharmaceutical presentation of the biosimilar.chemical and Pharmaceutical presentation of the biosimilar.chemical and Pharmaceutical presentation of the biosimilar.At the very beginning of the project, a full physic-chemical and pharmaceutical description of the biosimilar must beavailable. This would normally be provided by the Pharma/maurfacturer of the biosimilar and should include:• Comparability exercise versus reference product Comparison against official data is essential. Data frompharmacopoeial monographs or against other published scientific data) is not sufficient• Quality attributes: The Biosimilar is not expected to be identical to the reference however,o Limits: not wider than the range of variability of the reference producto Differences: to be justified in relation to safety and efficacy of the Reference product:• Comparability for medicinal product + active substance• Same reference for all three parts of the dossier (Q/S/E)• The pharmaceutical should be clearly identified (brand name, pharmaceutical form, formulation• and strength …)• Shelf life of the reference product and new biosimilar to be consideredBioanalysis and ImmunogenicityBioanalysis and ImmunogenicityBioanalysis and ImmunogenicityBioanalysis and Immunogenicity.1. Firstly, we need to have an analytical method both for the biosimilar and when necessary for the referencecompound against which its potency is being tested. These may be similar assays but subtle differences in thestructure of each biosimilar will mean that all assays used have to be fully validated both for the test substanceand for the reference product or endogenous compound within the body. The assays will most commonly beimmune-based assays such as ELISA however advances in LC-MS/MS technology have meant that some smallerbiologicals and biological molecules can also be assayed by these techniques. Once validated assays have beenworked out for the molecules under test than clinical trials may begin.A special consideration in designing the programme is the lead time to develop these special bespoke assays. Aconsideration of these timelines needs to be early in the programme design process.
  11. 11. 262. It is essential in these classes of drug to have a measure of the likelihood of the new biological or biosimilar toinduce the formation of antibodies in patients prescribed the compound. This is not just a short term event butalso may happen over time, and hence the development of an immunogenicity testing system has to be able toprovide assays for several months and even years after the introduction of the drug into clinical practice. This islaid down in many of the guidance documents relating to biosimilars.3. Separate immunogenicity assays may need to be developed for both the reference product and the new biosimilaras secondary and tertiary differences in molecular structure may preclude a single assay for both. Considerablemethod development may be required.Fusion’s laboratory scientists are experts in these studies and have the capability to develop the assays and theimmunogenicity techniques in the laboratories in Adelaide, Ahmedabad and Singapore. The location of the assaydevelopment will be determined by a number of factors including the location of the major trials however the coreexpertise in method development resides in Adelaide with the capacity to do a method/technology transfer to the otherlaboratories once the validated method is shown to have the right specificity, sensitivity and is robust.PrePrePrePre----clinical and safety studies.clinical and safety studies.clinical and safety studies.clinical and safety studies.The emphasis of the pre-clinical studies is that they should be comparative in nature and designed to detect differencesbetween the new biosimilar and the reference compound. In every case, the nature of the disease targeted, the route ofadministration and the proposed dosage should be taken into account in determining the nature of the pre-clinicalstudies.There should be at least one pharmacodynamic (if possible) and one repeat dose toxicity study.Generally, full safety pharmacology, reproduction toxicity and mutagenicity /cardinogenicity testing are not required.Phase I studies including glucose clamp studies.Phase I studies including glucose clamp studies.Phase I studies including glucose clamp studies.Phase I studies including glucose clamp studies.The first study to be performed with a biosimilar is likely to be a simple Phase I study in healthy volunteers wheneverpossible. The value of this study will depend to a large extent upon the ability of the laboratory to measure the biosimilaror biological in the volunteers blood. In the case of a test molecule which is a similar to a naturally occurring hormone orpeptide within the body this simplistic approach may not be available. If a distinct assay for the biological or biosimilar
  12. 12. 28conducive to the performing of Phase I studies of biosimilars both in Oncology and in non-Oncology indications. Howeverthe Malaysian regulatory authorities have adopted an approach which is essentially that of the EU Regulatory authoritiesand in proposing a Phase I study in Malaysia it is to be anticipated that the Malaysian regulations will be applied withinthe context of the Phase of the trial. For the convenience of clients, we have appended the Malaysian Guidance on theRegistration of Biosimilars to provide guidance on the anticipated dossier which will need to be produced. Appendix Icontains an abbreviated guideline. The whole guideline may be found at Malaysian Biosimilars GuidelineProofProofProofProof----ofofofof----ConceptConceptConceptConcept andandandand Phase 3 studiesPhase 3 studiesPhase 3 studiesPhase 3 studiesThe regulatory requirement is for one or more (usually two) Phase 3-type studies which demonstrate the therapeuticequivalence of the new biosimilar from the reference products. In some instances this is relatively easy – insulins are a casein point. However in the case of some other molecules such as Human Growth Hormone, the design of the trial todemonstrate equivalency is challenging. Most challenging is the demonstration of efficacy in a very slow moving endpointand in some cases, a surrogate and more easily measured end-point may be acceptable but only if there is a sound scientificreasoning behind the selection of the surrogate whose relationship to the desired clinical endpoint is properly understood.A review of the EU process for the registration of an erythropoietin product provides us with an insight into the complexityof the biosimilar registration.The details are provided in Appendix (2)A Phase III study will be required with eacheacheacheach of the reference compounds chosen for each geography for which thebiosimilar is to be marketed. Skilled negotiation with the Regulatory agencies of each country may produce adesirable result in one country agreeing to accept the reference compound of another country as being acceptable,thereby bringing down the size and cost of the whole programme.
  13. 13. 29Fusion’s ability to deliver in the Phase III arena.Fusion’s ability to deliver in the Phase III arena.Fusion’s ability to deliver in the Phase III arena.Fusion’s ability to deliver in the Phase III arena.Key to the ability to perform this component of the programme is the ability of the Fusion Alliance to deliver in terms ofpatient populations. Although the members of the Fusion Alliance have different core functions, nevertheless they all havethe capacity to recruit and deliver patients and each Fusion member takes local responsibility for this part of the process.This means that we have a reach for clinical trials recruitment acrossAPAC, through SE Asia and into India. Through other relationshipsnested in the Fusion Alliance we have the capacity to recruit and runsites in Europe and in Eastern Europe.Fusion can also support the clinical trials in these regions with theassistance of its members. Thus, Prince Court Hospital can service theclinical trials needs of the Alliance from Malaysia and has performed inthis role. Similarly the Safety Laboratory requirements and centralreading for Scans and Radiographs can be provided digitally from thissite. Electrocardiographic Central reading is provided by cardiologist inIndia working through the MUSE system in Veeda Clinical Research.Geographieswhere FusiGeographieswhere FusiGeographieswhere FusiGeographieswhere Fusion can recruiton can recruiton can recruiton can recruitPhase IIIpatientsPhase IIIpatientsPhase IIIpatientsPhase IIIpatientsAustraliaNew ZealandSE Asia including:MalaysiaSingaporeThailandIndonesiaPhilippinesIndo-ChinaIndia and Sri LankaUAENorthern EuropeScandinaviaEastern EuropeUSA
  14. 14. 30The Preparation of the MThe Preparation of the MThe Preparation of the MThe Preparation of the Marketing Dossierarketing Dossierarketing Dossierarketing DossierThe Marketing Dossier is best prepared by experts who understand the regulatory nuances of each country to which theBiosimilar is to be presented. In the vast majority of instances, the chosen principal countries will include the EU, the US–FDA domain and possibly (but not invariably) Japan.Communicating with the Regulatory Authorities.Communicating with the Regulatory Authorities.Communicating with the Regulatory Authorities.Communicating with the Regulatory Authorities.Many problems will arise when the dossier is compiled. The major hurdle is that most countries will require the biosimilarto be compared with a reference compound which is actually on the formulary of that country. Hence considerable skill isrequired to negotiate acceptable alternative approaches with each regulator so as to reduce the number of trials which needto be performed and consideration here needs to be given to pharmaco-economics for if the market for a particular countryis too small then additional requirements to market in that country may make the operation un-viable for that particularcountry. A skilled and knowledgable negotiator may enable a country to become available in spite of early problems.PharmacoPharmacoPharmacoPharmaco----vigilance before and after the MA.vigilance before and after the MA.vigilance before and after the MA.vigilance before and after the MA.A comprehensive product profile is the basis for a biosimilar entering the market. Pharmacovigilance will be required forall studies conducted during the evaluation process of the biosimilar. Previously. Pharmacovigilance has been a voluntaryactivity after marketing of a drug however with biosimilars this is practically not the case for the applicant for a marketinApproval in the EU and the FDA territories, and many others, is required to produce a full Pharmacovigilance and RiskManagement Plan for the biosimilar for a minimum of one year. Such a plan should be in place prior to the approval ofthe product. This includes regular pre- and post- authorisation comparative testing and the manufacturing process mustbe continuously monitored to ensure comparability between production batches. The Risk Management plan, submittedas part of the Pharmaco-Vigilance package needs to guarantee immediate reaction in case of rising numbers of anyspecific, but rate, disorder with suspected relation to the biosimilar product.Concern has been expressed that the traditional concepts of pharmacovigilance as applied to small molecules may not beentirely appropriate for biosimilars which may induce hitherto unexplored disease processes. An example of this is thedisease of Pure red Cell Aplasia which was induced by a biosimilar equivalent of erythropoietin. The proboem for thetraditional pharmaco-vigilance approach is that the assessors need to be able to identify small clusters of rare orunexpected diseases against the general ‘noise’ of the background.
  15. 15. 31APPENDIXAPPENDIXAPPENDIXAPPENDIX 1111MINISTRY OF HEALTH MALAYSIAMINISTRY OF HEALTH MALAYSIAMINISTRY OF HEALTH MALAYSIAMINISTRY OF HEALTH MALAYSIA NATIONAL PHARMACEUTICAL CONTROL BUREAUNATIONAL PHARMACEUTICAL CONTROL BUREAUNATIONAL PHARMACEUTICAL CONTROL BUREAUNATIONAL PHARMACEUTICAL CONTROL BUREAUGUIDANCE DOCUMENTGUIDANCE DOCUMENTGUIDANCE DOCUMENTGUIDANCE DOCUMENT AND GUIDELINES FOR REGISTRATIONAND GUIDELINES FOR REGISTRATIONAND GUIDELINES FOR REGISTRATIONAND GUIDELINES FOR REGISTRATION OF BIOSIMILARS IN MALAYSIAOF BIOSIMILARS IN MALAYSIAOF BIOSIMILARS IN MALAYSIAOF BIOSIMILARS IN MALAYSIAPREPARATION OF DRAFT GUIDANCE 1 March 2008DISCUSSION/DISSEMINATION OF DRAFTGUIDANCE 23 April 2008COLLATION OF FEEDBACK AND COMMENTS 23 May 2008FINAL GUIDANCE 30 July 2008CONSIDERATION FOR ADOPTION 4 August 2008FOREWORDFOREWORDFOREWORDFOREWORDGuidance document is meant to provide assistance to applicants (industry) on how to comply with the governing acts andregulations. It also clearly outlines the registration requirements and/or process to applicants, and elaboration of thepolicy decisions such as regulatory approach and position on .interchangeability. and substitutability with the referenceproduct. Guidance document also provides assistance to staff on how National Pharmaceutical Control Bureau.s (NPCB)mandates and objectives should be implemented in a manner that is fair, consistent and effective.It is important to note that NPCB reserves the right to request information or material, or define conditions not specificallydescribed in this document, in order to ensure the safety, efficacy or quality of a therapeutic biologic product. NPCBis committed to ensure that such requests are justifiable and that decisions are clearly documented.A variety of terms, such as .similar biological medicinal products., .follow-onprotein products., .subsequent-entry biologics.or .biogenerics. have been coined by different jurisdictions. For the purpose of this document, a biosimilar.medicinal product (a short designation for similar biological medicinal product.) is considered as a new biologicalmedicinal product developed to be similar in terms of quality, safety and efficacy to an already registered, well established,medicinal product.So far, the European Union (EU) through the European Medicines Agency (EMEA) has the most well developed regulatoryframework for biosimilars andwhich is supported by specific guidelines. The information in this guidance isadopted from the EMEA guidelines in particular the Guidelines on similar biological medicinal products containingbiotechnology-derived proteins as active substances, with some adaptations for Malaysian application.
  16. 16. 32The purpose of this guidance document is:• To introduce the concept of biosimilars;• To outline the basic principles to be applied;• To provide applicants with a user guide. for the relevant scientific information, in order to substantiate the claimof similarity.TABLE OF CONTENTSTABLE OF CONTENTSTABLE OF CONTENTSTABLE OF CONTENTS1.0 INTRODUCTION 11.1 Concept of biosimilars 21.2 principles 21.3 and application 31.4 statements 3-51.5 51.6 Scientific guidelines 5-71.7 Harmonisation with other international regulators 72.0 GUIDANCE FOR IMPLEMENTATION 72.1 General 72.2 Quality guidelines 7-82.2.1 exercise considerations 8-92.2. Manufacturing process considerations 92.2.3 Reference product considerations 92.2.4 Analytical/technique considerations 102.2.5 Characterisation considerations 10-112.2.6 specifications 112.2.7 Stability considerations 112.3 -clinical and Clinical guidelines 122.3. General 122.3.2 Non-clinical requirements 12-132.3.3 Clinical requirements 132.3.3.1 studies (PK) 13-14
  17. 17. 332.3.3.2 Pharmacodynamic studies (PD) 142.3.3.3 Comparative PK/PD studies 142.3.3.4 Clinical efficacy trials 14-152.3.3.5 Clinical safety and Immunogenicity 152.3.3.6 Pharmacovigilance & RMP 15-163.0 POST MARKET REQUIREMENTS 164.0 ORGANISATION OF DATA/DOSSIER 16-175.0 INTERCHANGEABILITY AND SUBSTITUTION 176.0 NAME OF PRODUCTS 177. LABELING 188.0 APPENDICES (I,II,III & IV) 18-27________________________________________________________________________
  18. 18. 341.0 INTRODUCTION1.0 INTRODUCTION1.0 INTRODUCTION1.0 INTRODUCTIONBiopharmaceuticals are protein molecules derived from biotechnology methodsor other cutting-edge technologies. Theywere introduced on the market in theearly 1980s, setting new milestones in modern pharmaceutical therapy thatimprove quality of life for many patients with life-threatening, serious, chronic anddebilitating diseases Today, the so-called .similar. biological medicinal products also known as biosimilars), their first-generation successors, are poised to gointo medical application. Biologics are large, highly complex molecular entities manufactured using living cells and areinherently variable. The manufacturing process is highly complex and critical to defining the characteristics of the finalproduct. Maintaining batch to-batch consistency is a challenge. Subtle variations in the production or eventransport or storage conditions may potentially result in an altered safety and efficacy profile of the final product in somecases. Hence, the dogma .the process is the product. is often used in reference to biologics. Based on the current analyticaltechniques, two biologicals produced by different manufacturing processes cannot be shown to be identical, but similar atbest. Therefore, the term .biosimilar. is appropriate and conversely .biogeneric. is felt by many National RegulatoryAuthorities (NRAs) to be misleading in this context.Immunogenicity of biotherapeutics is of concern from clinical and safety aspects. Clinical trials and a robust postmarketing pharmacovigilance are essential to guarantee the product.s safety and efficacy over time. Biosimilars are animportant issue for all parties concerned . from patients to and innovative industries, to healthcare authorities. However,delivering these medicines to the patients involves complex technical and regulatory challenges as well as experience withthese medicines is limited. Understandably, there is pressure from patients to make biotherapeutics more widely availableand cheaper. The existence of divergent approaches to the regulatory oversight of biosimilars in different countries,revealed a need fordefining principles and regulatory expectations for these products on a global level. The World HealthOrganisation (WHO) shall develop a global regulatory guideline for biosimilar products. Meanwhile, this guidancedocument and guideline were developed to meet the challenges in biotherapeutics and describe the regulatory oversight forbiosimilars in Malaysia, and which will be made to align/harmonise with the global regulatory guideline once available.1.1 Concept of biosimilars1.1 Concept of biosimilars1.1 Concept of biosimilars1.1 Concept of biosimilarsThe rationale for creating the new regulatory paradigm for biosimilars is that biotherapeutics/biologics similar to areference product .do not usually meet all the conditions to be considered as a generic.. The term .generic medicine. refersto chemically-derived products which are identical and therapeutically equivalent to the originator product, For suchgenerics, demonstration of bioequivalence with the originator product is usually appropriate to infer therapeuticequivalence. However, it is unlikely that biotherapeutics can generally follow this standard approach for generics because oftheir large and complex molecular structures, which are more difficult to adequately characterise in the laboratory. Based
  19. 19. 35on the current analytical techniques, two biologicals produced by different manufacturing processes cannot be shown to beidentical, but similar at best. For these reasons, the standard generic approach is scientifically not applicableto development of biosimilar products and additional non-clinical and clinical data are usually required.Based on the comparability approach and when supported by state-of-the-art analytical systems, the comparabilityexercise at the quality level may allow a reduction of the non-clinical and clinical data requirements compared to a fulldossier. This in turn, depends on the clinical experience with the substance class and will be a case by case approach.The aim of the biosimilar approach is to demonstrate close similarity of the .biosimilar. product in terms of quality, safetyand efficacy to one chosen reference medicinal product, subsequently referring to the respective dossier.1.2 Guiding Principles1.2 Guiding Principles1.2 Guiding Principles1.2 Guiding PrinciplesOur primary objective is public health protection and patient safety. Biosimilars should meet the same standards ofquality, safety and efficacy as any other registered biotechnological product. Regulation of biosimilars is based on stateof-the-art science. The regulatory paradigm for biosimilars is not intended to be .too onerous., .too stringent or too loose.rather we undertake a cautious and balanced approach and avoiding over-regulation.finally, our experience demonstrates that transparent and open dialogue with relevant stakeholders is key to put in place arobust and adapted regulatory framework in this emerging field whilst creating and promoting a patient-oriented,innovative and favourable regulatory environment. In corollary this will further enhance and promote a dynamic andcompetitive knowledge-based economy for healthcare biotechnology in Malaysia.1.3 Scope and application1.3 Scope and application1.3 Scope and application1.3 Scope and applicationThe concept of a biosimilar applies to biological drug submission in which the manufacturer would, based ondemonstrated similarity to a reference medicinal product, rely in part on publicly available information from a previouslyapproved biologic drug in order to present a reduced non-clinical and clinical package aspart of submission. The demonstration of similarity depends upon detailed and comprehensive product characterisation,therefore, information requirements outlined within this document apply to biologic drugs that contain, as the activesubstances, well characterised proteins derived through modern biotechnological methods such asrecombinant DNA, into microbial or cell culture. Conversely, the biosimilar approach is more difficult to apply to othertypes of biologics which by their nature are more complex, more difficult to characterise or to those for which little clinicalregulatory experience has been gained so far. Therefore, it does not cover complex biologics such as blood-derivedproducts, vaccines, immunologicals and gene and cell therapy products. Whether a product would be acceptable using thebiosimilar paradigm depends on the state-of-the-art of analytical procedures, the manufacturing processemployed, as well as clinical and regulatory experiences.
  20. 20. 361.4Policy st1.4Policy st1.4Policy st1.4Policy statementsatementsatementsatementsThe following policy statements outline the fundamental concepts and principles constituting the basis of the regulatoryframework for biosimilars:1.4.11.4.11.4.11.4.1 The principles within the existing regulatory framework for biologics, biotechnology drugs and genericpharmaceutical drugs shall be the basis of the regulatory framework for biosimilars.1.4.21.4.21.4.21.4.2 In implementing this guidance document, all the relevant Guidelines on biological products containingbiotechnology-derived proteins as active substance and the Guidelines on similar biological medicinal products (alsoknown as biosimilars), will be used as the basis for defining the registration requirements and/or process for registration ofbiosimilars in Malaysia. (See 1.6 )1.4.31.4.31.4.31.4.3 Biosimilars are not .generic biologics/biogenerics.. Thus, the classicgeneric paradigm (i.e demonstration ofbioequivalence of the generic drug with the reference product is usually appropriate to infer therapeuticequivalence) and many characteristics associated with approval process used for generic drugs do not apply to biosimilars.1.4.41.4.41.4.41.4.4 Approval of a product through the biosimilar pathway is not an indication that the biosimilar may beautomatically substituted with its reference product. The decision for substitutability with the reference product shallbe based on science and clinical data.1.4.51.4.51.4.51.4.5 A biosimilar product cannot be used as a reference product by anothermanufacturer because a reference producthas to be approved on thebasis of a complete/full quality and clinical data package.1.4.61.4.61.4.61.4.6 Eligibility for a biosimilar pathway hinges on the ability to demonstrate similarity to a reference product. Productemploying clearly different approaches to manufacture than the reference product (for example use oftransgenic organisms versus cell culture) will not be eligible for the regulatory pathway for biosimilars.1.4.71.4.71.4.71.4.7 The manufacturer must conduct a direct and extensive comparabilityexercise between its product and thereference product, in order todemonstrate that the two products have a similar profile in terms of quality,safety and efficacy. Only one reference product is allowed throughout thisexercise. The rationale for the choice of referenceproductshould be provided by the manufacturer to the NRA.
  21. 21. 371.4.81.4.81.4.81.4.8 Non-clinical and clinical requirements outlined for biosimilar submission inthis guidance document areapplicable to biosimilars that have demonstrated to be similar to the reference product, based on results ofthe comparability exercises from chemistry, manufacturing and control (CMC) perspectives. When similarity of abiosimilar cannot be adequately established, the submission of such a product should be as a stand-alone.biotechnological product with complete non-clinical and clinical data.1.4.91.4.91.4.91.4.9 Non-clinical and clinical issues of specific products are further elaboratedin the Committee for MedicinalProducts for Human Use (CHMP) productclass specific guidelines which appears as Annexes to the general nonclinicaland clinical guidelines for biosimilar.1.4.101.4.101.4.101.4.10 It should be recognised that there maybe subtle differences betweenbiosimilars from different manufacturers orcompared withreference products, which may not be fully apparent until greaterexperience in their use have beenestablished. Therefore, in order to support pharmacovigilance monitoring, the specific biosimilar given topatient should be clearly identified.1.4.111.4.111.4.111.4.11 It was acknowledged that although International Non-proprietary Names(INNs) served as a useful tool inworldwide pharmacovigilance, for biologicals they could not be relied upon as the only means of productidentification, nor as an indicator of the interchangeability of biologicals inparticular biosimilars.1.4.121.4.121.4.121.4.12 For a biosimilar manufacturer from countries that is not from Pharmaceutical Inspection Convention/Scheme(PIC/S)Member Countries or from the 8 Reference Countries, a Good Manufacturing Practice (GMP) on-site audit of themanufacturing facilities is required.1.5 Definitions1.5 Definitions1.5 Definitions1.5 Definitions (Refer t(Refer t(Refer t(Refer to APPENDIX IV : Glossary ofterms )o APPENDIX IV : Glossary ofterms )o APPENDIX IV : Glossary ofterms )o APPENDIX IV : Glossary ofterms )1.61.61.61.6 Scientific Guidelines applicable to all biosimilar products:Scientific Guidelines applicable to all biosimilar products:Scientific Guidelines applicable to all biosimilar products:Scientific Guidelines applicable to all biosimilar products:Committee for Medicinal Product for Human Use (CHMP) Guidelines areavailable at the following websites EMEA:http://www.emea.europa.eu and International Conference of Harmonisation (ICH) Guidelines: http://www.ich.org1.6.11.6.11.6.11.6.1 Guidelines on Biological products cGuidelines on Biological products cGuidelines on Biological products cGuidelines on Biological products containing biotechnologyontaining biotechnologyontaining biotechnologyontaining biotechnology----derivedderivedderivedderived proteins as active substanceproteins as active substanceproteins as active substanceproteins as active substance1.5.1While developing a biosimilar product and carrying out the comparability exercise to demonstrate that the product issimilar to the reference medicinal product, some existing biotechnological product guidelines may be relevant and shouldtherefore be taken into account. For example:
  22. 22. 38• CPMP/BWP/328/99 Development Pharmaceutics for Biotechnological and Biological Products . Annex to Note ofGuidance on Development Pharmaceutics (CPMP/QWP/155/96)• Topic Q5A, Step 4 Note for Guidance on Quality of Biotechnological Products: Viral safety evaluation ofBiotechnological Products derived• from Cell Lines of Human or Animal Origin (CPMP/ICH/295/95) Topic Q5B Note for Guidance on Quality ofBiotechnological Products:• Analysis of the Expression Construct in Cell Lines used for Production of r-DNA derived Protein Products.(CPMP/ICH/139/95)• Topic Q5C, Step 4 Note for Guidance on Quality of Biotechnological Products: Stability Testing ofBiotechnological/Biological Products (CPMP/ICH/138/95)• Topic Q5D, Step 4 Note for Guidance on Quality of Biotechnological : Derivation and Characterisation of CellSubstrates Used for Production of Biotechnological/Biological Products (CPMP/ICH/294/95)• Topic Q5E, Step 4 Note for Guidance on Biotechnological/Biological Products Subject to Changes in TheirManufacturing Process (CPMP/ICH/5721/103)• Topic Q6B, Step 4 Note for Guidance on Specifications: Test Procedures and Acceptance Criteria forBiotechnological/Biological Products (CPMP/ICH/365/96)• Topic S6, Step 4 Note for Preclinical Safety Evaluation of Biotechnology-Derived Products (CPMP/ICH/302/95)1.6.2 Guidelines on similar biological medicinal products ( also known as1.6.2 Guidelines on similar biological medicinal products ( also known as1.6.2 Guidelines on similar biological medicinal products ( also known as1.6.2 Guidelines on similar biological medicinal products ( also known as ....Biosimilar GuidelinesBiosimilar GuidelinesBiosimilar GuidelinesBiosimilar Guidelines .... ))))It should be noted that the CHMP has or may develop additional guidancedocuments addressing both the quality, non-clinical and clinical aspectsfor the development of biosimilars. Product-class specific documents on non-clinical andclinical studies to be conducted for the development of defined biosimilar product will be made progressively available.• Guideline on similar biological medicinal products (EMEA/CHMP/437/04)• Guideline on similar biological medicinal products containing biotechnology-derived proteins as activesubstances: Quality issues(EMEA/CHMP/BWP/49348/2005)• Guideline on similar biological medicinal products containing biotechnology-derived proteins as activesubstances: Non-clinical and Clinical issues (EMEA/CHMP/42832/2005)
  23. 23. 39• Annex guideline on similar biological medicinal products containing biotechnology-derived proteins as activesubstances: Non-clinical and Clinical issues - Guidance on similar medicinal products containing recombinanthuman soluble insulin (EMEA/CHMP/32775/2005)• Annex guideline on similar biological medicinal products containing biotechnology-derived proteins as activesubstances: Non-clinical and Clinical issues - Guidance on similar medicinal products containing somatropin(EMEA/CHMP/94528/2005)• Annex guideline on similar biological medicinal products containing biotechnology-derived proteins as activesubstances: Non-clinical and Clinical issues - Guidance on similar medicinal products containing recombinanterythropoietins (EMEA/CHMP/94526/2005)• Annex guideline on similar biological medicinal products containing biotechnology-derived proteins as activesubstances: Non-clinical and Clinical issues - Guidance on similar medicinal products containing recombinantgranulocyte-colony stimulating factor. (EMEA/CHMP/31329/2005)• Guideline on Immunogenicity Assessment of Biotechnology-derived Therapeutic Proteins(EMEA/CHMP/14327/2006)• Guideline on Risk Management Systems for Medicinal Products for human Use (EMEA/CHMP/96268/2005)1.7 Harmonisation with other international regulators1.7 Harmonisation with other international regulators1.7 Harmonisation with other international regulators1.7 Harmonisation with other international regulatorsIt is National Pharmaceutical Control Bureau.s (NPCB) intention to harmonise asmuch as possible with other competentregulators and international organisationssuch as World Health Organisation (WHO) and the International Conference ofHarmonisation (ICH). It would be expected that guidance on scientific principlesthat should be involved in evaluatingbiosimilars would help harmonise requirements worldwide and lead to greater ease and speed of approval andgreater assurance of the quality, safety and efficacy of these products worldwide.2.0 GUIDANCE FOR IMPLEMENTATION2.0 GUIDANCE FOR IMPLEMENTATION2.0 GUIDANCE FOR IMPLEMENTATION2.0 GUIDANCE FOR IMPLEMENTATION2.1 General2.1 General2.1 General2.1 GeneralBiosimilars can be approved based in part on an exercise to demonstrate similarity to an already approved referenceproduct. The same reference product should be used throughout the comparability program in order to generatecoherent data and conclusions. Comparative quality, non-clinical and clinical studies are needed to substantiate thesimilarity of structure/composition, quality, safety and efficacy between the biosimilar and the reference product. Thepharmaceutical form, strength and route of administration should be the same as that of the reference product. Anydifferences between the biosimilar and the reference product should be justified by appropriate studies on a case-by-casebasis.
  24. 24. 402.2 QUALITY GUIDELINES2.2 QUALITY GUIDELINES2.2 QUALITY GUIDELINES2.2 QUALITY GUIDELINESThe quality part of a biosimilar, like all other biologics will comply with establishedscientific and regulatory standards.A biosimilar product is derived from a separate and independent master cellbank, using independent manufacturing andcontrol method, and should meet thesame quality standards as required for innovator products. A full quality dossier isalways required.In addition the biosimilar manufacturer is required to submit extensive datafocussed on the similarity, includingcomprehensive side-by-sidephysicochemical and biological characterisation of the biosimilar and thereference product. The base requirement for a biosimilar is that it is demonstrated to be .highly similar. to the referenceproduct. Due to the heterogenous nature of therapeutic proteins, the limitations of analytical techniques and theunpredictable nature of clinical consequences to structure/biophysical differences, it is not possible to define the exactdegree of biophysical similarity that would be considered sufficiently similar to be regarded as biosimilar, and this has tobe judged for each product independently.Applicants should note that the comparability exercise for a biosimilar versus the reference product is an additionalelement to the requirements of the quality dossier and should be dealt with separately when presenting the data.Information on the development studies conducted to establish the dosage form, the formulation, manufacturing process,stability study and container closuresystem including integrity to prevent microbial contamination and usageinstructions should be documented.2.2.1 Comparability exercise considerations:2.2.1 Comparability exercise considerations:2.2.1 Comparability exercise considerations:2.2.1 Comparability exercise considerations:• The goal of comparability exercise is to ascertain if the biosimilar and thereference products are similar in terms of quality, safety and efficacy.Comparability program/exercise todemonstrate similarity should involve all aspects of development, full analytical comparability of quality, studiesfor the non-clinical and clinical components same reference product to be used throughout the comparabilityprogram.• Comparability with the chosen reference product should be addressed forboth the active substance and drugproduct.• It is not expected that the quality attributes in the biosimilar and the reference product will be identical. Forexample, minor structural differences in the active substance such as variability in post-translationalmodifications may be acceptable, however, should be justified.
  25. 25. 41• Quality differences may impact the amount of non-clinical and clinical data needed, and will be a case by caseapproach.• If the reference drug substance used for characterisation is isolated from a formulated reference drug productadditional studies should be carried out to demonstrate that the isolation process does not affect the importantattributes of the drug substance/moiety.1.2.21.2.21.2.21.2.2 Manufacturing process considerations:Manufacturing process considerations:Manufacturing process considerations:Manufacturing process considerations:• The biosimilar product is defined by its own specific manufacturing process for both active substance andfinished product.• The process should be developed and optimised taking into account stateof- the-art science and technologyon manufacturing processes and consequences on product characteristics.• A well.defined manufacturing process with its associated process controls assures that an acceptableproduct is produced on a consistent basis.• A separate comparability exercise, as described in ICH Q5E, should be conducted whenever change isintroduced into the manufacturing process during development.1.2.31.2.31.2.31.2.3 Reference product considerations:Reference product considerations:Reference product considerations:Reference product considerations:• Appropriate comparative tests at the level of the isolated active substance from the formulated referenceproduct are generally needed, except in some cases when quality attributes of the active substance can betested on the finished product.• The manufacturer should demonstrate that the active substance used in the comparability studies is.representative of the active substance. of the reference product.• Comparisons of the active substance in the biosimilar product made against public domain information e.gpharmacopoeial monographs are not sufficient to demonstrate similarity. Reference standards arenotappropriate for use as a reference product.• The same reference product should be used for all three parts of thedossier (i.e Quality, Safety and Efficacy)• The chosen reference product should have a suitable duration and volumeof marketed use such that thedemonstration of similarity will bring into relevance a substantial body of acceptable data dealing withsafety and efficacy.• The brand name, pharmaceutical form, formulation and strength of the reference product used in thecomparability exercise should be clearly identified.• The shelf life of the reference product and its effect on the quality profile adequately addressed, whereappropriate.- 10 -1.2.41.2.41.2.41.2.4 Analytical procedure/techniques considerations:Analytical procedure/techniques considerations:Analytical procedure/techniques considerations:Analytical procedure/techniques considerations:
  26. 26. 42• Extensive state-of-the-art analytical methods should be applied to maximise the potential for detecting.slight differences. in all relevant quality attributes.• Methods used in both the characterisation studies and comparability studies should be appropriatelyqualified and validated [as in ICH Q2(R1)] available, standards and international reference materials [e.gfrom European Pharmacopeia (Ph.Eur), WHO etc.] should be used for method qualification and validation.1.2.51.2.51.2.51.2.5 Characterisations considerations:Characterisations considerations:Characterisations considerations:Characterisations considerations:• Characterisations of a biotechnological/biological product by appropriate techniques, as described in ICHQ6B, includes the determination of physicochemical properties, biological activity, immunochemicalproperties if any), purity, impurities, contaminants, and quantity.• Key points in the conduct of characterisation program/exercise:- Physicochemical properties: determination of composition, physical properties and shouldconsider the concept of the desired product (and its variants) as defined in ICH Q6B. Thecomplexity of the molecular entity with respect to the degree of molecular heterogeneity shouldalso be considered and properly identified.- Biological activity: include an assessment the biological properties towards confirmation ofproduct quality attributes that are useful for characterisation and batch analysis, and in somecases, serve as a link to clinical activity. Limitations of biological assays could prevent detection ofdifferences. A set of relevant functional assays should be considered to evaluate the range ofactivities.- Immunochemical properties: When immunochemical properties are part of characterisation, the manufacturershould confirm that the biosimilar product is comparable to the reference product in terms of specific properties.- Purity, impurities and contaminants: Should be assessed both qualitatively and quantitatively using state-of-the-art technologies and firm conclusion on the purity and impurity profiles be made.• A complete side.by-side characterisations is generally warranted to directly compare the biosimilar and thereference product. However, characterisations may be indicated in some cases.• Accelerated stability studies of the reference and of the biosimilar product can be used to further define andcompare the degradation pathways/stability profiles.• Process-related impurities are expected, but their impact should be confirmed by appropriate studies(including non-clinical and/or clinical studies• Measurement of quality attributes in characterisation studies does not necessarily entail the use of validatedassays, but the assay should be sound and provide results that are reliable. Those methods used to measure
  27. 27. 43quality attributes for batch release should be validated in accordance with ICH guidelines (ICH Q2A, Q2B,Q5C, Q6B), as appropriate1.2.6 Setting specificationsSetting specificationsSetting specificationsSetting specifications• The analytical procedures chosen to define drug substance or drug product specifications alone are notconsidered adequate to assess product differences since they are chosen to confirm the routine quality of theproduct rather than to fully characterise it.• The manufacturer should confirm that the specifications chosen are appropriate to ensure product quality.• Specification limits: should not be wider than the range of variability of the reference product.1.2.71.2.71.2.71.2.7 Stability cStability cStability cStability considerations:onsiderations:onsiderations:onsiderations:• Proteins are frequently sensitive to changes, such as those made to buffer composition, processing andholding conditions, and the use of organic solvents• .Accelerated and stress stability studies are useful tools to establishdegradation profiles and can thereforecontribute to a direct comparison of biosimilar and the reference product. Appropriate studies should beconsidered to confirm that storage conditions and controls are selected.• ICH Q5C and Q 1A(R2) should be consulted to determine the conditions for stability studies that providerelevant data to be compared before and after a change.• For a biosimilar approach, it would be worth comparing a biosimilar with reference product by acceleratedstability studies as these studies at elevated temperature may provide complementary supporting evidencefor the comparable degradation profile1.31.31.31.3 NONNONNONNON----CLINICAL AND CLINICAL GUIDELINESCLINICAL AND CLINICAL GUIDELINESCLINICAL AND CLINICAL GUIDELINESCLINICAL AND CLINICAL GUIDELINES2.3.1 General2.3.1 General2.3.1 General2.3.1 GeneralThe information in this section provides only general guidance on non-clinical and data requirements for biosimilars. Thenon-clinical studies should be conducted prior to the initiation of any clinical studies. These studies should be comparativeand aim to detect differences between the biosimilar and the reference product. The requirements for the drug classes (forexample: insulin, growth hormone) may vary. The requirements may also vary depending on various clinical parameterssuch as therapeutic index, the type and number of indications applied. Efficacy and safety for each indication will eitherhave to be demonstrated or an extrapolation from one indication to another justified. The final biosimilar product (usingthe final manufacturing process) should be used for non-clinical and clinical studies. Clinical comparability is done in
  28. 28. 44stages, much like a traditional program. Proposed indications for biosimilar must be identical or within the scope ofindications granted for the reference product. In case the reference product has more than one therapeutic indication, theefficacy and safety of the biosimilar has to be justified or, if necessary, demonstrated separately for each of the claimedindications. In certain cases it may be possible to extrapolate therapeutic similarity shown in one indication to otherindications of the reference product, but this is not automatic.The non-clinical section addresses the pharmaco-toxicological assessment. The clinical section addresses the requirementsfor pharmacokinetic, pharmacodynamic, efficacy studies. The section on clinical safety and pharmacovigilance addressesclinical safety studies as well as the risk of management plan with special emphasis on studying immunogenicity of thebiosimilar.2.3.2 Non2.3.2 Non2.3.2 Non2.3.2 Non----clinical requirementsclinical requirementsclinical requirementsclinical requirements• Biosimilars should undergo appropriate non-clinical testing sufficient to justify the conduct of clinical studies inhealthy volunteers or patients. These studies should be comparative and aim to detect differences between thebiosimilar and the reference product and not just response per se.• Ongoing consideration should be given to the use of emerging technologies (For e.g In vitro techniques such ase.g .real-time. Binding assays may prove useful. In vivo, the developing genomic/proteomic microarray sciencesmay, in the future, present opportunities to detect minor changes in biological response to pharmacologicallyactive substances)• In vitro studies:- Receptor-binding studies or cell-based assay (e.g cell-proliferation assay) should be conducted• In vivo studies:- Animal pharmacodynamic study where appropriate, relevant to clinical use- At least one repeat-dose toxicity study, including toxicokinetic measurements, should be conducted inrelevant species.- Relevant safety observations (for e.g local tolerance) can be madeduring the same toxicity study.• The rationale for request of antibody measurements in the context of the repeat dose toxicity study :- Generally, the predictive value of animal models for immunogenicity in is considered low.Nevertheless, antibody measurements (e.g antibody titres, neutralising capacity, cross reactivity) as partof repeated dose toxicity studies is required to aid in the interpretation of the toxicokinetic data and to
  29. 29. 45help assess, as part of the comparability exercise, if structural differences exist between the biosimilarand the reference product.• Other toxicological studies, including safety pharmacology, reproductive toxicology, mutagenicity andcarcinogenicity studies are not required for unless warranted by the results from repeated toxicological studies.2.3.3 Clinical2.3.3 Clinical2.3.3 Clinical2.3.3 Clinical requirementsrequirementsrequirementsrequirements2.3.3.12.3.3.12.3.3.12.3.3.1 Pharmacokinetic (PK) studiesPharmacokinetic (PK) studiesPharmacokinetic (PK) studiesPharmacokinetic (PK) studies• Comparative pharmacokinetic studies should be conducted to demonstrate the similarities in pharmacokinetic(PK) characteristics between biosimilar and the reference product.• If appropriate from an ethical point of view, healthy volunteers will in most cases represent a sufficiently sensitiveand homologous model for such comparative PK studies.• Choice of designs must be justified and should consider factors such as clearance and terminal half-life, linearityof PK parameters,• where applicable the endogenous level and diurnal variations of the protein under study, production ofneutralizing antibody conditions and diseases to be treated.• The acceptance range/equivalence margin to conclude clinical comparability should be defined prior to theinitiation of the study taking into consideration known PK parameters and their variations, assaymethodologies, safety and efficacy of the reference product.• Other PK studies such as interaction studies or other special populations (e.g children, elderly, patients withrenal or hepatic insufficiency) are usually not required.2.3.3.2 Pharmacodynamic (PD) studies2.3.3.2 Pharmacodynamic (PD) studies2.3.3.2 Pharmacodynamic (PD) studies2.3.3.2 Pharmacodynamic (PD) studiesParameters should be clinically relevant or a surrogate marker which is clinically validated. The PD study may be combinedwith a PK study and the PK/PD relationship can be characterised. PD studies should be comparative in nature.2.3.3.22.3.3.22.3.3.22.3.3.2 ConfirmatoryConfirmatoryConfirmatoryConfirmatory Pharmacokinetic/PharmacodynamicPharmacokinetic/PharmacodynamicPharmacokinetic/PharmacodynamicPharmacokinetic/Pharmacodynamic(PK/PD) studies(PK/PD) studies(PK/PD) studies(PK/PD) studiesComparative PK/PD studies may be sufficient to demonstrate comparable clinical efficacy, provided all the followings aremet (however, cases when approval on the basis of PK/PD data might be acceptable are highly limited):• PK and PD properties of the reference product are well characterised
  30. 30. 46• Sufficient knowledge of PD parameters is available• At least one PD marker is accepted as surrogate marker fo refficacy• Dose response is sufficiently characterised (ICH E10)• Equivalence margin is pre-defined and appropriately justified.2.3.3.4 Clinical efficacy trials2.3.3.4 Clinical efficacy trials2.3.3.4 Clinical efficacy trials2.3.3.4 Clinical efficacy trials• Comparative clinical trials (head-to-head adequately powered, randomised, parallel group clinical trials, so-called .equivalence trials.) are required to demonstrate the similarity in efficacy and safety profiles betweenbiosimilar and the reference product. The design of the studies is important. Assay sensitivity must be ensured(ICH E10)• Equivalence margins should be pre-specified, adequately justified on clinical grounds.• Equivalent rather than non-inferior efficacy should be shown in order for the biosimilar to adopt the posology ofthe reference product and to open the possibility of extrapolation to other indications, which may includedifferent dosages.2.3.3.52.3.3.52.3.3.52.3.3.5 Clinical safety and ImmunogenicityClinical safety and ImmunogenicityClinical safety and ImmunogenicityClinical safety and Immunogenicity• The safety of biosimilar should be demonstrated to be similar to the reference product in terms of nature,seriousness and frequency of adverse events. Thus data from sufficient number of patients and sufficient studyduration with sufficient statistical power to detect major safety differences are needed.• For products intended for administration for longer than 6 months, the size of the safety database shouldtypically conform with the recommendations of ICH E1 on the extent of population exposure to assess clinicalsafety.• Data from pre-approval studies are insufficient to identify all differences in safety. Therefore, safety monitoringon an ongoing basis after approval including continued benefit-risk assessment is mandatory.• A written rationale on the strategy for testing immunogenicity should be provided. State-of-the-art methodsshould be used, validated and able to characterise antibody content (concentration or titre), neutralisingantibody and crossreactivity.• Special attention should be paid to the possibility that the immune response seriously affects the endogenousprotein and its unique biological function.
  31. 31. 472.3.3.62.3.3.62.3.3.62.3.3.6 Pharmacovigilance Plan/Risk Management Plan (RMP)Pharmacovigilance Plan/Risk Management Plan (RMP)Pharmacovigilance Plan/Risk Management Plan (RMP)Pharmacovigilance Plan/Risk Management Plan (RMP)• Any post-market Risk Management Plan (RMP) should include detailed information of a systematic testingplan for monitoring immunogenicity of the biosimilar post-market.• The RMP should includeRisk Identification and characterisation (e.g case definitions, antibody assays);Risk Monitoring (e.g specific framework to associate risk with product);Risk Minimisation and Mitigation strategies (e.g plans to restrict to intravenous use where necessary, actionsproposed in response to detected risk etc.);Risk communication (e.g minimising and mitigation messages for patients and physicians)Monitoring activities to ensure effectiveness of risk minimisation.3.03.03.03.0 POSTPOSTPOSTPOST MARKET REQUIREMENTSMARKET REQUIREMENTSMARKET REQUIREMENTSMARKET REQUIREMENTS• The pharmacovigilance plan must be approved prior to approval of product and the system must be in placeto conduct monitoring.• The pharmacovigilance plan should be designed to monitor and detect both known inherent safety concernsand potentially unknown safety problems that may have resulted from the impurity profiles of a biosimilar.• The pharmacovigilance, as part of a comprehensive RMP, should include regular testing for consistentmanufacturing of the biosimilar.• The pharmacovigilance plan should be able to distinguish between and tracking different products andmanufacturers of products in the same class of medicinal products (e.g epoetins, insulins, interferons). Suchcapability is essential to help ensure adverse events are properly attributed to the relevant medicinal product(i.e traceability)• Traceability of the product should involve product identification defined in terms of product name, brandname, pharmaceutical form, formulation, strength, manufacturer.s name and batch number(s).• Periodic Safety Update Reports (PSURs) of biosimilars should be submitted and evaluation of benefit/risk ofthe biosimilar post-market should be discussed. Such systems should include provisions for passivepharmacovigilance and active evaluations such as registries and post marketing clinical studies.4.0 ORGANISATION OF DATA / DOSSIER4.0 ORGANISATION OF DATA / DOSSIER4.0 ORGANISATION OF DATA / DOSSIER4.0 ORGANISATION OF DATA / DOSSIER
  32. 32. 48As regards the amount/kind of data requirements for a biosimilar application, the one size fits all. approach cannot beapplied. This is due to the wide spectrum of molecular complexity among the various products concerned. Thus, therequirements to demonstrate safety and efficacy of a biosimilar are essentially product class-specific.The data for submission are organised according to the ASEAN Common Technical Dossier (ACTD), with full quality dataplus comparability exercise and studies of the non-clinical and clinical components.The biosimilar approach requires a thorough comparability exercise to generateevidence substantiating the similar nature,in terms of quality, safety and efficacy, of the biosimilar product and the chosen reference product. In other words, thequality data need to be supplemented by a new element . the .comparability exercise..The demonstration of similarity at the quality level may allow a reduction of the non-clinical and clinical data requirementcompared to a full dossier. Demonstration of similarity may also allow extrapolation of efficacy and safety data to otherindications of the reference product.5.0 INTERCHANGEABILITY AND SUBSTITUTION5.0 INTERCHANGEABILITY AND SUBSTITUTION5.0 INTERCHANGEABILITY AND SUBSTITUTION5.0 INTERCHANGEABILITY AND SUBSTITUTIONBiosimilars are not generic products and cannot be identical to their reference products. Further, the formulations may bedifferent and these can have profound effect on their clinical behaviour. In addition, biosimilars do not necessarily havethe same indications or clinical use as the reference products. Therefore, given current science, they cannot be consideredinterchangeable with the reference product or products of the same class. Automatic substitution (i.e the practice by whicha different product to that specified on the prescription is dispensed to the patient without the prior informed consent ofthe treating physician) and active substance-based prescription cannot apply to biologicals, including biosimilars. Such anapproach ensures that treating physicians can make informed decisions about treatments is in the interest of patients.safety.6.0 NAME OF PRODUCTS6.0 NAME OF PRODUCTS6.0 NAME OF PRODUCTS6.0 NAME OF PRODUCTSIn order to facilitate effective pharmacovigilance monitoring and tracing of adverse safety events and to preventinappropriate substitution, the specific medicinal product (innovator or biosimilar) prescribed by the treating physicianand dispensed to the patient should be clearly identified. Therefore, all biosimilars should be distinguishable by name i.eassign a brand name explicitly,using names that are not suggestive towards the originator nor towards otherbiosimilars.Note:Note:Note:Note:In 2006, the WHO Expert Committee on INNs agreed that the INN system should not be altered to reflect regulatoryprocesses associated with the approval of biosimilar. Since INNs are based on information concerning the molecular
  33. 33. 49characteristics and pharmacological class of a product, it was decided that no distinctive INN designation should be usedto indicate a biosimilar. Instead, it was proposed that INN policy for naming a biosimilar be the same as that forinnovator biologicals. However, there was a need to explain clearly to stakeholders the scientific basis for assigning INNsand their purpose, as well as limitations of this nomenclature for biologicals. Therefore, for pharmacovigilance purposes,biological product identification included in addition to the INN, other indicators such as the country oforigin, manufacturer.s name and batch number(s).7.07.07.07.0 LABELING / PACKAGE INSERTLABELING / PACKAGE INSERTLABELING / PACKAGE INSERTLABELING / PACKAGE INSERTThe labeling of biosimilars should provide transparent information to healthcare professionals and patients on issues thatare relevant to the safe and effective use of the medicinal product.It is expected that the labeling of biosimilar meet the following criteria:• A clear indication that the medicine is a biosimilar of a specific reference product.• The invented name, common or scientific name and the manufacturer.s name• Clinical data for the biosimilar describing the clinical similarity (i.e safety and efficacy) to the referenceproduct and in which indication(s)• Interchangeability and substitution advice . should clearly and prominently state that the biosimilar is notinterchangeable or substitutable with the reference product.
  34. 34. 50Appendix 2.Appendix 2.Appendix 2.Appendix 2.Example of a Biosimilar programme; Erythropoeitin biosimilarExample of a Biosimilar programme; Erythropoeitin biosimilarExample of a Biosimilar programme; Erythropoeitin biosimilarExample of a Biosimilar programme; Erythropoeitin biosimilarExample of EMEA registration requirements for a biosimilar erythropoietinsExample of EMEA registration requirements for a biosimilar erythropoietinsExample of EMEA registration requirements for a biosimilar erythropoietinsExample of EMEA registration requirements for a biosimilar erythropoietins (EU, 2010)(EU, 2010)(EU, 2010)(EU, 2010) as an exampleas an exampleas an exampleas an examplePreclinicalPreclinicalPreclinicalPreclinical In vitro: comparative biological studies (binding to the receptor, cell proliferation)Evaluation of erythrogenic effect on mice,4-week study of repeated dose toxicity in ratsPhase I studiesPhase I studiesPhase I studiesPhase I studies Clinical Pharmacokinetic and pharmacodynamic studies ( Evaluation of the following parameters:AUC, Cmax2, T1/2, reticulocyte countPhase 3 studiesPhase 3 studiesPhase 3 studiesPhase 3 studies Two randomized, 2-blind studies in patients with chronic renal failure, patients ondialysis The two studies comprise:A correction phase study willA correction phase study willA correction phase study willA correction phase study will determine response dynamics and dosing during the anaemia correction phase and isparticularly suitable to characterize the safety profile related to the pharmacodynamics of the similar biologicalmedicinal product. It should include treatment naïve patients or previously treated patients after a suitably long periodappropriate to the species of biological . In case of pre-treatment with long-acting erythropoesis stimulating agents(such as pegylated epoetin), the treatment-free phase may need to be longer.A maintenance phase study,A maintenance phase study,A maintenance phase study,A maintenance phase study, on the other hand, may be more sensitive to detect differences in biological activity betweenthe similar and the reference product, although experience suggests that correction phase studies are also likely to besufficiently discriminatory. The study design for a maintenance phase study should minimise baseline heterogeneityand carry over effects of previous treatments. Patients included in a maintenance phase study should be optimallytitrated on the reference product for a suitable duration of time (usually at least 3 months). Thereafter, study subjectsshould be randomised to the similar or the reference product, maintaining their pre-randomisationepoetin dosage, dosing regimen and route of administration. However this regime would be lamentably short for ahormone such as human somatotrophin unless surrogate endpoints were used.Study of immunogenicityStudy of immunogenicityStudy of immunogenicityStudy of immunogenicityDuration - not less than 12 months – part of Phase 3 programme.PostPostPostPost----marketing studiesmarketing studiesmarketing studiesmarketing studiesThe manufacturer submits a plan of continuous pharmaco-vigilance Particular attention shouldbe paid to rare adverse reactions and immunogenicity
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