September 2014 Presentation at the Regulatory Affairs Professionals Society Regulatory Convergence Conference in Austin, Texas, with a focus on:
• The “Good” News –351(k) BLAs Have Been Filed at FDA
• Interchangeability
• State Substitution Laws
• Naming
• Where FDA Stands on Biosimilars
Presentation at the Biosimilars and Follow-On Biologics 2014 Americas Conference, sponsored by Paradigm Global Events, February 12, 2014. Presentation focused on:
•Interchangeability
•State Substitution Laws
•Naming
•Risk Evaluation & Mitigation Strategies (REMS) and Their Impact on Biosimilars
•Where FDA Stands on Biosimilars
Update on U.S. Regulation of BiosimilarsMichael Swit
This document summarizes key issues regarding U.S. regulation of biosimilars, including the filing of the first biosimilar applications, requirements for demonstrating interchangeability, state substitution laws, challenges around naming conventions, and arguments on both sides of the naming debate. Industry is pursuing clinical trial designs aimed at demonstrating interchangeability, while FDA guidance is pending and naming remains controversial with pros arguing it ensures traceability and cons arguing it reduces biosimilar uptake.
This document provides an overview of biosimilars and their regulatory framework. It begins with definitions of biologics and biosimilars. Biosimilars are highly similar versions of approved biologics whose patents have expired. The development of biosimilars is unique compared to small molecule generics due to the complex nature of biologics. The document then discusses issues with biosimilars including potential efficacy, safety and substitution concerns. Finally, it provides details on the regulatory frameworks and guidelines established by organizations like WHO, EU, US and India to help facilitate the development and approval of biosimilars.
February 7, 2017
Many of today’s important medications are biological products made from living organisms, manufactured through biotechnology, derived from natural sources, or produced synthetically. Biosimilars are a type of biological product approved by FDA on the basis of being highly similar to an already approved biological reference product.
This panel of experts discussed the current state of biosimilars in the healthcare ecosystem and what comes next from a technical and legal perspective. Topics included how the next generation of biosimilars could improve patient access to standard-of-care therapies, the concept of “biobetters,” economic and intellectual property considerations, and policy approaches to support existing and future biosimilars.
Learn more on our website: http://petrieflom.law.harvard.edu/events/details/looking-forward
- Biosimilars are biologic medical products that are similar but not identical copies of original biologic drugs. They are developed when the patent expires on the original product.
- Regulatory agencies have stringent approval criteria for biosimilars to demonstrate similar quality, safety and efficacy as the reference product. Clinical trials must show comparable pharmacokinetics, pharmacodynamics and immunogenicity.
- While biosimilars increase access and lower costs, they are not generic copies and have unique safety profiles. Automatic substitution is not appropriate and unique nonproprietary names and labeling is required to facilitate pharmacovigilance.
This document provides an overview of biological products as defined by the FDA. It describes biological products as medical products made from sugars, proteins, nucleic acids or complex combinations in living cells or tissues. Examples like vaccines, blood components and monoclonal antibodies are provided. The document highlights how biological products differ from chemically synthesized drugs in being large molecules from natural sources, requiring complex manufacturing processes, and sometimes being heterogeneous or immunogenic. It briefly outlines the process required for a biological product to be licensed by the FDA, including demonstrating consistent manufacturing and clinical safety and efficacy data.
Hi all, with the rigorous secondary research for almost one month helped me to understand basic things about biosimilars and made me do this presentation. Hope u will appreciate it while going through it. thanks.
If anyone in need of this presentation, pls.put ur emial ID in comment box. will be sharing. and please share your thoughts about the presentation. i will be more thankful.
Presentation at the Biosimilars and Follow-On Biologics 2014 Americas Conference, sponsored by Paradigm Global Events, February 12, 2014. Presentation focused on:
•Interchangeability
•State Substitution Laws
•Naming
•Risk Evaluation & Mitigation Strategies (REMS) and Their Impact on Biosimilars
•Where FDA Stands on Biosimilars
Update on U.S. Regulation of BiosimilarsMichael Swit
This document summarizes key issues regarding U.S. regulation of biosimilars, including the filing of the first biosimilar applications, requirements for demonstrating interchangeability, state substitution laws, challenges around naming conventions, and arguments on both sides of the naming debate. Industry is pursuing clinical trial designs aimed at demonstrating interchangeability, while FDA guidance is pending and naming remains controversial with pros arguing it ensures traceability and cons arguing it reduces biosimilar uptake.
This document provides an overview of biosimilars and their regulatory framework. It begins with definitions of biologics and biosimilars. Biosimilars are highly similar versions of approved biologics whose patents have expired. The development of biosimilars is unique compared to small molecule generics due to the complex nature of biologics. The document then discusses issues with biosimilars including potential efficacy, safety and substitution concerns. Finally, it provides details on the regulatory frameworks and guidelines established by organizations like WHO, EU, US and India to help facilitate the development and approval of biosimilars.
February 7, 2017
Many of today’s important medications are biological products made from living organisms, manufactured through biotechnology, derived from natural sources, or produced synthetically. Biosimilars are a type of biological product approved by FDA on the basis of being highly similar to an already approved biological reference product.
This panel of experts discussed the current state of biosimilars in the healthcare ecosystem and what comes next from a technical and legal perspective. Topics included how the next generation of biosimilars could improve patient access to standard-of-care therapies, the concept of “biobetters,” economic and intellectual property considerations, and policy approaches to support existing and future biosimilars.
Learn more on our website: http://petrieflom.law.harvard.edu/events/details/looking-forward
- Biosimilars are biologic medical products that are similar but not identical copies of original biologic drugs. They are developed when the patent expires on the original product.
- Regulatory agencies have stringent approval criteria for biosimilars to demonstrate similar quality, safety and efficacy as the reference product. Clinical trials must show comparable pharmacokinetics, pharmacodynamics and immunogenicity.
- While biosimilars increase access and lower costs, they are not generic copies and have unique safety profiles. Automatic substitution is not appropriate and unique nonproprietary names and labeling is required to facilitate pharmacovigilance.
This document provides an overview of biological products as defined by the FDA. It describes biological products as medical products made from sugars, proteins, nucleic acids or complex combinations in living cells or tissues. Examples like vaccines, blood components and monoclonal antibodies are provided. The document highlights how biological products differ from chemically synthesized drugs in being large molecules from natural sources, requiring complex manufacturing processes, and sometimes being heterogeneous or immunogenic. It briefly outlines the process required for a biological product to be licensed by the FDA, including demonstrating consistent manufacturing and clinical safety and efficacy data.
Hi all, with the rigorous secondary research for almost one month helped me to understand basic things about biosimilars and made me do this presentation. Hope u will appreciate it while going through it. thanks.
If anyone in need of this presentation, pls.put ur emial ID in comment box. will be sharing. and please share your thoughts about the presentation. i will be more thankful.
Biosimilars are biological generics drugs.They undergo a rigorous evaluation to get approved.How to prove biosimilariy from analytical comparability is explained using a recently approved US FDA bio-similar monoclonal antibody.
This document discusses the regulatory requirements for clinical development of biosimilars in India. It provides an overview of the applicable regulations, guidelines, and authorities overseeing clinical trials. The key principles for developing biosimilars are to demonstrate comparability to the reference biologic through a stepwise characterization and clinical development program involving pharmacokinetic, pharmacodynamic, and confirmatory safety and efficacy studies. Post-marketing requirements include pharmacovigilance plans and potential post-marketing studies to further evaluate safety and immunogenicity.
Bio similar- An opportunities or challenge for Indian Company Debashish Kar
1. The global biosimilars market is expected to grow significantly in the coming years due to various drivers such as patent expiries of major biologics and increasing cost containment pressures.
2. Indian companies are well positioned in the biosimilars space due to their established low-cost manufacturing capabilities and expertise in biologics. Key players in India include Dr. Reddy's, Biocon, Cipla and Intas.
3. Developing biosimilars presents several challenges including high development costs, complex clinical trials and unclear regulatory guidelines. Indian companies strategy involves partnerships for cost-effective development and leveraging domestic capabilities and emerging markets for growth.
This document discusses biosimilars and their regulation. It begins with a brief history of biotechnology and biopharmaceuticals. It then defines biosimilars as similar but not generic versions of biologic drugs whose patents have expired. The document outlines key differences between biosimilars and generic drugs, including their larger and more complex molecular structures. It also discusses concerns regarding biosimilar efficacy, safety, interchangeability, and pharmacovigilance. Finally, it provides an overview of regulatory frameworks for biosimilars in various regions like the EU, US, India, and WHO guidelines.
Dialogue with Canada’s leading regulatory and assessment experts: Health Canada Bureau of Biologics and Genetic Therapies (BGTD) and Canadian Agency for Drugs and Technologies in Health (CADTH)
Date: June 29, 2016
Time: 1:00pm to 3:00pm EST
Presentation at the Center for Professional Advancement (CFPA) Course on Generic Drug Approval, August 2013. New Brunswick, NJ., with a focus on how biosimilars are regulated
This document summarizes the global regulatory landscape for biosimilars. It begins by defining biosimilars and biological drugs. It then discusses the guidelines established by various regulatory bodies including the EMA, FDA, WHO, and agencies in countries like Japan, Korea, Canada, China, and India. The guidelines generally require demonstrating biosimilarity to the reference product through comparative quality, nonclinical and clinical studies. The document also discusses business opportunities for biosimilars in emerging versus established markets and strategies used by originator companies to combat biosimilar competition. It concludes by noting concerns around interchangeability between biosimilars and reference products.
The document summarizes India's new guidelines for approval of biosimilar biologics. Some key points:
1) The guidelines define biosimilars as biological products claimed to be similar in safety, efficacy, and quality to an approved reference biologic.
2) Biosimilars are developed through analytical studies comparing properties to the reference product, which could reduce required clinical testing.
3) Clinical testing may include pharmacokinetic, pharmacodynamic, and safety/efficacy studies designed to establish comparability to the reference product. Post-market surveillance is also required.
4) The guidelines aim to balance regulatory standards with access to affordable biologics through a biosimilars pathway
This document summarizes strategies for developing and manufacturing biosimilars. It discusses Hospira's biosimilars business and development network. Biosimilars have distinct development challenges compared to generics, including higher costs and regulatory uncertainty. Manufacturing technologies like disposable bioreactors and chromatography can help lower costs. Close surveillance of originator products and demonstrating scalability are important. Post-approval changes will likely follow ICH Q5E guidelines. With scientific expertise and incremental innovations, biosimilar companies can successfully manage uncertainties in this emerging industry.
This document provides an overview of biosimilars. It discusses that biosimilars are similar versions of biologic drugs that are set to lose patent protection. This presents both opportunities to make cheaper biologics to increase access, as well as regulatory challenges to demonstrate similarity. The global biosimilars market is growing, driven by both developed and emerging markets. India is emerging as a key player, with companies developing biosimilars for both domestic and export markets. However, hurdles remain around establishing clear regulatory pathways and demonstrating similarity to reference biologics.
June 14, 2018 presentation to the San Diego Regulatory Affairs Network (SDRAN) Regulatory Affairs Certification (RAC) Review Course on the basics of FDA regulation of generic drugs and biosimilars.
Please share this slideshow with anyone who may be interested!
Watch all our webinars: https://www.youtube.com/playlist?list=PL4dDQscmFYu_ezxuxnAE61hx4JlqAKXpR
In this webinar:
● Discussion on biologics, including an explanation of the high level of precision that is required to produce a consistent biological product each time.
● Discussion on the growing interest in biosimilars, followed by what we can learn from Europe’s experience.
● Health Canada’s position on biosimilars, discussion on key issues surrounding biosimilars relevant to the Canadian market.
● The importance of patient safety and patient choice.
View the video: https://youtu.be/h3Ap6HoiSC8
Follow our social media accounts:
Twitter - https://twitter.com/survivornetca
Facebook - https://www.facebook.com/CanadianSurvivorNet
Pinterest - https://www.pinterest.com/survivornetwork
YouTube - https://www.youtube.com/user/Survivornetca
Drug Types: Biosimilars, generics and more. December 2017 Webinar 12122017Fight Colorectal Cancer
This document provides information about an upcoming webinar on drug types including biosimilars and generics. It outlines details like the speaker, how to ask questions during the webinar, and instructions for accessing the webinar archive and following along on Twitter. It also provides brief bios of the speaker and gives technical instructions for participating in the webinar platform. Finally, it lists some resources and includes a standard disclaimer.
This document discusses biosimilars in India and the opportunities and challenges in the biosimilars industry in India. It defines biosimilars and provides an overview of the global and Indian biosimilars market and regulatory landscape. The key opportunities for India include providing affordable treatment options and commercial benefits from lower cost manufacturing. However, challenges include regulatory hurdles, concerns around quality and safety, high development costs, and physician reluctance to prescribe biosimilars.
This document provides an overview of biosimilars including their advantages and disadvantages. It discusses regulatory guidelines for biosimilar approval in India, challenges in biosimilar development and production, and recently approved biosimilars. The conclusion recognizes biosimilars as an important part of the pharmaceutical ecosystem but one that faces barriers to adoption such as questions of interchangeability and not having approval for all reference product indications. It recommends overcoming challenges to biosimilar market access.
Regulatory guidance and guidelines for filing and approval for biologicsNimmiRoy
This document provides an overview of the regulatory guidance and guidelines for filing a Biologics License Application (BLA) with the FDA for approval of a biological product. It discusses the requirements for a BLA, including the contents that must be submitted. A BLA generally includes 20 sections that provide information on chemistry and manufacturing, nonclinical and clinical data, labeling, facilities and more. The document reviews the content required in each section and the review process by the FDA.
Drug development and discovery in biologicsAshish sharma
This document provides an overview of drug development and discovery in biologics. It discusses key topics such as biologics and biosimilars, the integrated discovery and development process of antibodies, the market status and typical manufacturing process of biologics, their therapeutic roles and biological targets in therapy. Some of the challenges in biologics development include the complex manufacturing process, safety implications, immunogenicity, and limited shelf life. Regulations of biologics in India are outlined. Recent FDA-approved biologics are also mentioned. In conclusion, biologics and small molecules are seen as complementary approaches for drug development.
This document discusses biosimilar medicines. It defines biosimilars as medicines similar to existing approved biopharmaceutical medicines. Biosimilars have similar quality, safety and efficacy profiles but are not identical. Their development and approval process is more complex than for generics due to the biological nature of biopharmaceuticals which are sensitive to manufacturing changes. Guidelines from the European Medicines Agency provide recommendations on demonstrating biosimilarity in terms of quality, non-clinical and clinical testing. Ensuring biosimilars are highly similar seeks to guarantee their safe substitution for biopharmaceuticals while increasing treatment access and lowering costs.
Biosimilars are biological generics drugs.They undergo a rigorous evaluation to get approved.How to prove biosimilariy from analytical comparability is explained using a recently approved US FDA bio-similar monoclonal antibody.
This document discusses the regulatory requirements for clinical development of biosimilars in India. It provides an overview of the applicable regulations, guidelines, and authorities overseeing clinical trials. The key principles for developing biosimilars are to demonstrate comparability to the reference biologic through a stepwise characterization and clinical development program involving pharmacokinetic, pharmacodynamic, and confirmatory safety and efficacy studies. Post-marketing requirements include pharmacovigilance plans and potential post-marketing studies to further evaluate safety and immunogenicity.
Bio similar- An opportunities or challenge for Indian Company Debashish Kar
1. The global biosimilars market is expected to grow significantly in the coming years due to various drivers such as patent expiries of major biologics and increasing cost containment pressures.
2. Indian companies are well positioned in the biosimilars space due to their established low-cost manufacturing capabilities and expertise in biologics. Key players in India include Dr. Reddy's, Biocon, Cipla and Intas.
3. Developing biosimilars presents several challenges including high development costs, complex clinical trials and unclear regulatory guidelines. Indian companies strategy involves partnerships for cost-effective development and leveraging domestic capabilities and emerging markets for growth.
This document discusses biosimilars and their regulation. It begins with a brief history of biotechnology and biopharmaceuticals. It then defines biosimilars as similar but not generic versions of biologic drugs whose patents have expired. The document outlines key differences between biosimilars and generic drugs, including their larger and more complex molecular structures. It also discusses concerns regarding biosimilar efficacy, safety, interchangeability, and pharmacovigilance. Finally, it provides an overview of regulatory frameworks for biosimilars in various regions like the EU, US, India, and WHO guidelines.
Dialogue with Canada’s leading regulatory and assessment experts: Health Canada Bureau of Biologics and Genetic Therapies (BGTD) and Canadian Agency for Drugs and Technologies in Health (CADTH)
Date: June 29, 2016
Time: 1:00pm to 3:00pm EST
Presentation at the Center for Professional Advancement (CFPA) Course on Generic Drug Approval, August 2013. New Brunswick, NJ., with a focus on how biosimilars are regulated
This document summarizes the global regulatory landscape for biosimilars. It begins by defining biosimilars and biological drugs. It then discusses the guidelines established by various regulatory bodies including the EMA, FDA, WHO, and agencies in countries like Japan, Korea, Canada, China, and India. The guidelines generally require demonstrating biosimilarity to the reference product through comparative quality, nonclinical and clinical studies. The document also discusses business opportunities for biosimilars in emerging versus established markets and strategies used by originator companies to combat biosimilar competition. It concludes by noting concerns around interchangeability between biosimilars and reference products.
The document summarizes India's new guidelines for approval of biosimilar biologics. Some key points:
1) The guidelines define biosimilars as biological products claimed to be similar in safety, efficacy, and quality to an approved reference biologic.
2) Biosimilars are developed through analytical studies comparing properties to the reference product, which could reduce required clinical testing.
3) Clinical testing may include pharmacokinetic, pharmacodynamic, and safety/efficacy studies designed to establish comparability to the reference product. Post-market surveillance is also required.
4) The guidelines aim to balance regulatory standards with access to affordable biologics through a biosimilars pathway
This document summarizes strategies for developing and manufacturing biosimilars. It discusses Hospira's biosimilars business and development network. Biosimilars have distinct development challenges compared to generics, including higher costs and regulatory uncertainty. Manufacturing technologies like disposable bioreactors and chromatography can help lower costs. Close surveillance of originator products and demonstrating scalability are important. Post-approval changes will likely follow ICH Q5E guidelines. With scientific expertise and incremental innovations, biosimilar companies can successfully manage uncertainties in this emerging industry.
This document provides an overview of biosimilars. It discusses that biosimilars are similar versions of biologic drugs that are set to lose patent protection. This presents both opportunities to make cheaper biologics to increase access, as well as regulatory challenges to demonstrate similarity. The global biosimilars market is growing, driven by both developed and emerging markets. India is emerging as a key player, with companies developing biosimilars for both domestic and export markets. However, hurdles remain around establishing clear regulatory pathways and demonstrating similarity to reference biologics.
June 14, 2018 presentation to the San Diego Regulatory Affairs Network (SDRAN) Regulatory Affairs Certification (RAC) Review Course on the basics of FDA regulation of generic drugs and biosimilars.
Please share this slideshow with anyone who may be interested!
Watch all our webinars: https://www.youtube.com/playlist?list=PL4dDQscmFYu_ezxuxnAE61hx4JlqAKXpR
In this webinar:
● Discussion on biologics, including an explanation of the high level of precision that is required to produce a consistent biological product each time.
● Discussion on the growing interest in biosimilars, followed by what we can learn from Europe’s experience.
● Health Canada’s position on biosimilars, discussion on key issues surrounding biosimilars relevant to the Canadian market.
● The importance of patient safety and patient choice.
View the video: https://youtu.be/h3Ap6HoiSC8
Follow our social media accounts:
Twitter - https://twitter.com/survivornetca
Facebook - https://www.facebook.com/CanadianSurvivorNet
Pinterest - https://www.pinterest.com/survivornetwork
YouTube - https://www.youtube.com/user/Survivornetca
Drug Types: Biosimilars, generics and more. December 2017 Webinar 12122017Fight Colorectal Cancer
This document provides information about an upcoming webinar on drug types including biosimilars and generics. It outlines details like the speaker, how to ask questions during the webinar, and instructions for accessing the webinar archive and following along on Twitter. It also provides brief bios of the speaker and gives technical instructions for participating in the webinar platform. Finally, it lists some resources and includes a standard disclaimer.
This document discusses biosimilars in India and the opportunities and challenges in the biosimilars industry in India. It defines biosimilars and provides an overview of the global and Indian biosimilars market and regulatory landscape. The key opportunities for India include providing affordable treatment options and commercial benefits from lower cost manufacturing. However, challenges include regulatory hurdles, concerns around quality and safety, high development costs, and physician reluctance to prescribe biosimilars.
This document provides an overview of biosimilars including their advantages and disadvantages. It discusses regulatory guidelines for biosimilar approval in India, challenges in biosimilar development and production, and recently approved biosimilars. The conclusion recognizes biosimilars as an important part of the pharmaceutical ecosystem but one that faces barriers to adoption such as questions of interchangeability and not having approval for all reference product indications. It recommends overcoming challenges to biosimilar market access.
Regulatory guidance and guidelines for filing and approval for biologicsNimmiRoy
This document provides an overview of the regulatory guidance and guidelines for filing a Biologics License Application (BLA) with the FDA for approval of a biological product. It discusses the requirements for a BLA, including the contents that must be submitted. A BLA generally includes 20 sections that provide information on chemistry and manufacturing, nonclinical and clinical data, labeling, facilities and more. The document reviews the content required in each section and the review process by the FDA.
Drug development and discovery in biologicsAshish sharma
This document provides an overview of drug development and discovery in biologics. It discusses key topics such as biologics and biosimilars, the integrated discovery and development process of antibodies, the market status and typical manufacturing process of biologics, their therapeutic roles and biological targets in therapy. Some of the challenges in biologics development include the complex manufacturing process, safety implications, immunogenicity, and limited shelf life. Regulations of biologics in India are outlined. Recent FDA-approved biologics are also mentioned. In conclusion, biologics and small molecules are seen as complementary approaches for drug development.
This document discusses biosimilar medicines. It defines biosimilars as medicines similar to existing approved biopharmaceutical medicines. Biosimilars have similar quality, safety and efficacy profiles but are not identical. Their development and approval process is more complex than for generics due to the biological nature of biopharmaceuticals which are sensitive to manufacturing changes. Guidelines from the European Medicines Agency provide recommendations on demonstrating biosimilarity in terms of quality, non-clinical and clinical testing. Ensuring biosimilars are highly similar seeks to guarantee their safe substitution for biopharmaceuticals while increasing treatment access and lowering costs.
FDA Regulatory Challenges for Biosimilars and CMOsMichael Swit
Presentation to webinar sponsored by FierceBiotech with a focus on:
* background behind creation of new law
* difference from chemical generic drug regulation
* details of new law
* challenges faced by new law
* interchangeability
Biosimilar Drugs: Overview and Regulatory Issuesflasco_org
This document provides an overview of biosimilar drugs and regulatory issues from a presentation given by Phil Johnson. It defines biosimilars and the FDA approval pathways for biologics and biosimilars. The FDA process for demonstrating biosimilarity is described, focusing on analytical, functional, and clinical data requirements. Issues around naming, interchangeability, and state-level legislation regarding substitution are discussed. Finally, the potential financial impact of biosimilars on the healthcare system is noted given rising drug costs and the patent cliff facing many biologic drugs.
What’s In a Name? FDA and Non-Proprietary Names for Biologics/BiosimilarsMichael Swit
April 20, 2018 Presentation to the 11th Biosimilars & Follow-On Biologics 2018 Americas conference on FDA's Policy on Non-proprietary names for Biosimilars
This document summarizes information about biosimilars and the regulatory pathways for their approval in the United States and European Union. It discusses how biosimilars differ from traditional small-molecule generics due to biological molecules' larger size, greater complexity, and manufacturing dependence. The U.S. passed the Biologics Price Competition and Innovation Act in 2010 to create an approval pathway for follow-on biologics, requiring biosimilarity demonstration and possible interchangeability labeling. Upcoming FDA hearings will provide information to guide biosimilar approval requirements regarding analytical and clinical data needs. The E.U. has approved several biosimilars under its regulatory framework established in 2005.
Michael Swit presented at the RAPS Annual Conference in San Jose on October 25, 2010. He discussed the history of biologics regulation and the new pathway for biosimilars established by the Biologics Price Competition and Innovation Act of 2009. The new pathway allows for an abbreviated approval process for biosimilars but gives FDA flexibility in implementation. Biosimilars must show similarity to the reference product through analytical, animal, and clinical studies but may not need to repeat all studies. Interchangeability requires additional evidence and is not required for approval. FDA is seeking input on guidance and other implementation issues.
This document summarizes the results of a survey conducted by ACE (Arthritis Consumer Experts) on patient perspectives regarding the regulation of subsequent entry biologics (SEBs). The key findings were that patient safety was the top priority for regulation of SEBs. Patients also wanted SEBs to undergo the same rigorous review processes as originator biologics and wanted to discuss treatment options with their physician. The document then discusses evidence on the benefits of originator biologic therapies in controlling rheumatoid arthritis and reducing healthcare costs. It notes patients still have unanswered questions about SEBs and discusses ambiguity around Quebec's listing of an SEB together with its originator biologic. In conclusion, the document states patients need timely access to
Orphan Drugs – the Challenges and Benefits of Navigating FDA’s Regime Governi...Michael Swit
Webinar sponsored by The Weinberg Group on Orphan Drugs, covering these topics:
The Basics of the Orphan Drug Act
Benefits of Orphan Drug status
Exclusivity
Protocol assistance, tax credits, and research grants
When is an indication is “rare”?
Orphan Drug Designation Requests – ensuring yours
robust and persuasive
Approval criteria for orphan products – how they
compare to non-orphan products
Challenges in the Orphan Drug Process
The document provides an overview of the Waxman-Hatch Act of 1984, which established the modern generic drug approval pathway in the United States. It discusses the reasons for its creation, key provisions such as bioequivalence standards and patent certification requirements, and subsequent amendments. The Act sought to balance increased availability of low-cost generic drugs with incentives for continued pharmaceutical innovation.
Biosimilars are complex biologic drugs that are similar but not identical to innovative biologic reference products. Several key points are made:
- Biosimilars are regulated differently than small molecule generics due to biologics' larger size and more complex manufacturing processes.
- While some regulators may designate a biosimilar as interchangeable, decisions on substitution are made separately at a national or state level.
- Health Canada does not declare any drug interchangeable and leaves substitution decisions to provinces, whereas the FDA may designate a biosimilar interchangeable if it is biosimilar and switching poses no greater risk to patients.
- Automatic substitution is not recommended and interchangeability requires specifically designed clinical trials for each
Dr. Liz Wagstrom - The Future of Antibiotic Use in Pork ProductionJohn Blue
The Future of Antibiotic Use in Pork Production - Dr. Liz Wagstrom, DVM, Chief Veterinarian, National Pork Producers Council, Washington, D.C., from the 2013 Minnesota Pork Congress, January 16-17, Minneapolis, MN, USA.
More presentations at http://www.swinecast.com/2013-minnesota-pork-congress
This document summarizes a presentation about FDA regulation of biosimilars. It discusses how biosimilars differ from traditional generics due to biologics being more complex molecules than small molecule drugs. It outlines the key provisions of the Biologics Price Competition and Innovation Act of 2009, including requirements for biosimilar applications such as analytical, animal and clinical studies demonstrating biosimilarity to the reference product. It also discusses requirements for interchangeability and other miscellaneous rules regarding biosimilar approval pathways.
Dr. Liz Wagstrom - Multiple challenges to antibiotic useJohn Blue
The document discusses multiple challenges to antibiotic use from legislative, regulatory, and legal perspectives, including proposed laws to ban non-medical uses of antibiotics also used in humans, new FDA guidance to phase out antibiotic growth promotion and require veterinary oversight for other uses, and a lawsuit challenging the FDA's failure to address safety risks of certain antibiotic uses. The FDA is implementing changes over the next 3-5 years that will likely end most non-medical antibiotic uses and require veterinary oversight through mechanisms like veterinary feed directives.
This document provides information on biosimilars and interchangeable biosimilars for health care providers. It defines key terms like reference product, biosimilar, and interchangeable. It describes the FDA approval pathways for biosimilars and generics. The FDA recommends a comparative analytical assessment and targeted clinical studies to demonstrate biosimilarity or interchangeability to a reference product. Clinical studies generally show biosimilars and interchangeable biosimilars are equivalent to their reference products in terms of safety, efficacy, and immunogenicity, including after switching. To date, the FDA has approved 4 interchangeable biosimilars.
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U.S. Regulation of Biosimilars: Key Issues
1. U.S. Regulation of Biosimilars:
Key Issues
RAPS Annual Convention 2014
Austin, Texas
Michael A. Swit, Esq.
Special Counsel, FDA Law Practice
Duane Morris LLP
2. Standard Disclaimers
• The views expressed here are solely my own and
do not necessarily reflect the views of my firm or
any of our clients.
• These slides support a verbal briefing and should
not be relied upon solely to support any
conclusion of law or fact.
• These slides – and the verbal briefing they
support – are intended for educational purposes
and should not be construed as legal advice.
2
3. What We Will Cover
• The “Good” News – 351(k) BLAs Have Been
Filed at FDA
• Interchangeability
• State Substitution Laws
• Naming
• Where FDA Stands on Biosimilars
3
5. Two 351(k) Filings
• Sandoz – July 24 – announced FDA had accepted
for filing its Biosimilar application for a version of
Amgen’s Neupogen® (filgrastim)
• Celltrion – August 11 – announced it had
“completed the filing process” at FDA for its
Biosimilar application for a version of Janssen’s
Remicade®
– using its own trade name of Remsima®
– first MAB biosimilar
5
7. The Gospel According to
Woodcock
Testimony of Janet Woodcock, before the House Committee on
Oversight & Government Reform. “Follow-on Protein Products.”
March 26, 2007.
7
9. Where is FDA Going?
• Not clear; guidance due out this year
– I am unaware of any statements inconsistent with
Woodcock’s 2007 and 351(k)(4) meshes with her view
• A few things we know:
– an interchangeable biologic is not a new active ingredient under PREA
– interchangeability can only be proven with reference to the U.S.
Reference Product
– FDA reluctant to let you go straight to interchangeability
• Interchangeability – infuses all the other issues
• Nomenclature – is it time to stop calling biologics
that are interchangeable “biosimilars”?
– “Purple Book” – uses “I” for Interchangeable9
10. Current Industry Approaches
• EGALITY (Sandoz) –
– Randomized, Double-Blind Multi-center Study to Demonstrate
Equivalent Efficacy and to Compare Safety and Immunogenicity of a
Biosimilar Etanercept (GP2015) and Enbrel® in Patients with
Moderate to Severe Plaque-type Psoriasis
– 564 subjects @ 64 sites in 12 countries – 22-month long study
• ADACESS -- Humira Study (Sandoz) – similar to
EGALITY
– A Randomized, Double-blind, Multicenter Study to Demonstrate
Equivalent Efficacy and to Compare Safety and Immunogenicity of a
Biosimilar Adalimumab (GP2017) and Humira® in Patients With
Moderate to Severe Chronic Plaque-type Psoriasis
– 448 patients – 2-year study (only one location mentioned)
10
11. Current Industry Approaches
• SB2/Remicade (Samsung Bioepis)
– Randomized, double-blind, parallel group, multicentre
clinical study to evaluate the efficacy, safety,
pharmacokinetics and immunogenicity of SB2 compared
to Remicade in subjects with moderate to severe
Rheumatoid Arthritis (RA) despite Methotrexate (MTX)
therapy.
– 584 patients – year long study – 2 locations listed
• What is not clear – are these for U.S. applications?
11
12. What Will Guidance Say –
A Few Views
• Key issue – how will FDA deal with the “any
given patient” language of 351(k)(4)?
– studies will need to be indication specific
– strong argument exists that interchangeability must be
proven in all indications to satisfy the “any given patient”
standard
– result – more likely to be shown in biologics with just one or
a few indications
• Number of patients – will need to high enough to
tease out safety/immunogenicity/efficacy
differences
12
18. Washington – “Compromise”
Agreement -- Pending
• Strange Bedfellows?
– BIO, Wash. Biotechnology & Biomedical Assn., Amgen,
Genentech
– Actavis, Hospira, and Sandoz
• Provisions for interchangeable biologics:
– Physician consent required -- 2-line Rx sheets in Wash. – DAW
or Substitution Permitted – doc signs on one of lines
– Pharmacist –
• has to note on file copy of Rx: (1) mfr.; (2) brand name or, if
none, non-proprietary name
• has 10 days to record in an “interoperable health records
system” or, if none exists, communicate to prescribing doc
the (1) drug name and (2) mfr.18
19. Washington Legislation
• Mandatory substitution – pharmacist “shall”
substitute – if he/she has a TE drug or
interchangeable biologic if wholesale price is less
than the prescribed drug; 60% of savings must be
passed to consumer
• Visible sign required at pharmacies:
– “Under Washington law, a less expensive interchangeable
biological product or equivalent drug may in some cases be
substituted for the drug prescribed by your doctor. Such
substitution, however, may only be made with the consent of your
doctor. Please consult your pharmacist or physician for more
information.”
– not clear how this jibes with consent req.19
20. Pennsylvania – SB 405 and HB 476
• Provisions – just reported this past week out of
committee
– substitution only for interchangeable biologics
– if prescriber bars verbally or in writing, no substitution
– Patient notice -- pharmacist must notify consumer of
planned substitution
– Prescriber notice – within 72 hours
– Record retention – 2 years
– Sign in pharmacy about substitution
– State – can determine that a drug is not interchangeable
(notwithstanding what FDA says) – no standard
articulated20
21. Pros and Cons
• Pros
– Transparency -- “right to know”
• Cons
– Veiled attempts to being anti-competitive – especially
notification mandates, which favor biologics with large sales
forces – pushes uptake in brand use (TN-epilepsy drugs)
– Undermines FDA interchangeability decision – contrary to
BPCIA – Preemption????
– Disincentive to biosimilar development
– Doctors don’t want to know from a liability perspective
– The law in most states already provides for physician notice
when a pharmacy wants to substitute non-TE drugs for what
was prescribed (whether on a brand/brand basis or gen.)
21
23. The Naming Process
• U.S. Adopted Name (USAN) Council – AMA,
American Pharmacists Assn., USP
– Independent of WHO and INN process
– Drug substances only
– Biologics –
• primary sequence – characteristics of the biopolymer
• if different glycosylation pattern – Greek suffix
• further elements – numbers (Interferon Alfa – 2a)
• USP – monographs for drug products as well
– if official, name must be used by approved drug/biologic
• If no official USP name, FDA picks
23
24. Naming Process
• INN
– April 2013 – consensus to develop a naming convention
– Oct. 2013 – suggested a naming system to be done
separate from INN – nothing resolved yet
• did comment that, for PV, reimbursement and substitution, an
INN itself is insufficient
• focus on drug substance, not product non-proprietary names
• would mull using a worldwide “Biological Qualifier” – BQ
– July 2014 – INN issues Biological Qualifier (BQ)
Proposal – comments were due by Sept. 19
http://www.who.int/medicines/services/inn/bq_innproposal201407.pdf?ua=1
• non-glycosylated protein – always same NN as innovator
24
25. Naming Process …
• INN – July 2014 “Biological Qualifier” (BQ)
– BQ = an alphabetic code assigned at random to a
biological active substance made at a specified site
– “voluntary” – person can make application for a BQ
– technically, not part of the INN, but, where “use of a BQ
is considered by an authority to be desirable, availability
of a single global scheme will avoid proliferation of
separate and distinct national qualifier systems.”
– prospective and retrospective –
– four letters (no vowels) – 160,000 combinations
• EMA – was comfortable with its current approach –
same for NN for RP and biosimilar25
26. Arguments -- Con
• Five key ways drugs are tracked in U.S. – the
generic name is only one aspect of this
– NDC # -- Bar code
– Trade name -- Generic name
– Manufacturer
• Express Scripts to the FTC – we can track every
drug we paid for without reference to INN
• FDA to WHO in 2006
– rejects relying on non-proprietary names relative to
interchangeability
– not needed for AE/PV handling
26
27. Arguments -- Con …
• FDA –
– allows a branded biologic to keep same INN after mfg.
change via a comparability protocol –
• both this and biosimilarity rely on the same premise – that
there are “no meaningful clinical differences” between either:
– RP1 and RP2 (in mfg. change situation)
– RP and Biosimilar
– already assigns same INN to biologics from different
makers (e.g., Avonex v. Rebif – both Interferon Beta-
1A)
– Pro -- lacks current authority to insist on a brand name
• Confusion created by multiple INNs?
27
28. Arguments -- Con …
• Europe –
– does not rely on INN for adverse event reporting
– INN is (usually) same for brand and biosimilar
– much greater penetration
• Negative Penetration – data shows using different
INNs markedly reduces use of the biosimilar
– Australia
– Japan
– Europe – in cases where there are different INNs (e.g.,
Hospira’s EPO zeta) – excluded from tenders
• Prefixes or suffixes – will confuse docs28
29. Pro -- Branded Views …
• Amgen
– Different naming is essential to traceability
– Claims naming does not impact market uptake
– Physicians favor “similar name” to brand, with “additional
nomenclature” to make clear it is a biosimilar
• Pfizer
– Study – AE’s for small molecule drug with generic competition
• 14% of AE’s not traceable to actual manufacturer
• only 10% had NDC #’s; 30% of those were inaccurate
– 99% traceable to brand name of biologic
– But, not all global jurisdictions – including FDA -- can require a
trade name; thus, need a second identifier – a distinct INN
29
30. Solution?
• Require brand names for biosimilars globally?
– Pfizer – need two identifiers -- both INN and brand names to be
different (Japan has this approach)
• But, can you satisfy with:
– batch #
– better use of NDC numbers?
– brand name?
– Track and Trace requirements under the Drug Quality & Safety
Act – are they the solution relative to alleged AE issues?
• too long a lead time?
• info in “wrong” hands – e.g., distributors and wholesalers?
30
31. Other Naming Issues
• What if a product is first approved as a non-
interchangeable biosimilar and later gets FDA
nod as interchangeable?
– What happens with the INN?
• Does FDA have the legal authority to mandate
brand names?
– pro – yes under “efficient enforcement of law”
provisions
– con – not authorized under BPCIA or FDCA
31
32. Other Naming Issues …
• INNs as a basis for AE tracking does not address
problems with batch/batch variations
– Eprex problem – would not have been addressed by
INN and brand name – needs NDC # in mix to tease
out that type of situation
– but – NDC numbers are hard to access and input (10
digits) and are solely used in U.S.
32
34. Current Guidances
34
Category Title Type Date
Biosimilarity; Procedural
Formal Meetings Between the FDA and
Biosimilar Biological Product Sponsors or
Applicants (PDF - 272KB)
Draft Guidance 03/29/13
Biosimilarity
Guidance for Industry on Biosimilars: Q & As
Regarding Implementation of the BPCI Act of
2009
Draft Guidance
Updated for 508
compliance.
02/09/12
Biosimilarity
Scientific Considerations in Demonstrating
Biosimilarity to a Reference Product (PDF -
576KB)
Draft Guidance 02/09/12
Biosimilarity
Quality Considerations in Demonstrating
Biosimilarity to a Reference Protein
Product (PDF - 432KB)
Draft Guidance 02/09/12
Biosimilarity
Clinical Pharmacology Data to Support a
Demonstration of Biosimilarity to a Reference
Product (PDF - 142KB)
Draft Guidance 05/13/14
Procedural; Biosimilarity
Reference Product Exclusivity for Biological
Products Filed Under (PDF - 99KB)
Draft Guidance 08/04/14
36. Questions?
• Call, e-mail or fax:
Michael A. Swit, Esq.
Special Counsel, FDA Law Practice
Duane Morris LLP
San Diego, California
direct: 619-744-2215
fax: 619-923-2648
maswit@duanemorris.com
• Follow me on:
– LinkedIn: http://www.linkedin.com/in/michaelswit
– Twitter: https://twitter.com/FDACounsel
36
37. About Your Speaker
Michael A. Swit, Esq., is a Special Counsel in the San Diego office of the
international law firm, Duane Morris, LLP, where he focuses his practice on solving FDA legal
challenges faced by highly-regulated pharmaceutical and medical device companies.
Before joining Duane Morris in March 2012, Swit served for seven years as a vice
president at The Weinberg Group Inc., a preeminent scientific and regulatory consulting firm in
the Life Sciences. His expertise includes product development, compliance and enforcement,
recalls and crisis management, submissions and related traditional FDA regulatory activities,
labeling and advertising, and clinical research efforts for all types of life sciences companies, with
a particular emphasis on drugs, biologics and therapeutic biotech products.
Mr. Swit has been addressing vital FDA legal and regulatory issues since 1984, both in
private practice with McKenna & Cuneo and Heller Ehrman, and as vice president, general
counsel and secretary of Par Pharmaceutical, a top public generic and specialty drug firm. He
also was, from 1994 to 1998, CEO of FDANews.com, a premier publisher of regulatory
newsletters and other specialty information products for FDA-regulated firms. He has taught
and written on many topics relating to FDA regulation and associated commercial activities and
is a past member of the Food & Drug Law Journal Editorial Board.
He earned his A.B., magna cum laude, with high honors in history, at Bowdoin College,
and his law degree at Emory University, and is a member of the California Bar and previously
was admitted in both Virginia and D.C., but is inactive in those jurisdictions.
37