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Presentation Outline
• Role of Biopharmaceutics
• In Vivo Bioavailability (BA) / Bioequivalence (BE) Assessment
• In Vitro and In Vivo Bridging for Assessment of Multiple Strengths and
Product Changes
• Biowaivers
• Biowaiver Approaches and Case Examples
– 21 CFR 320.22(d)(2) Based Approach
– Biopharmaceutics Classification System (BCS) Based Approach
– Risk Assessment for bridging drug product changes and multiple strengths
– Safe Space Approach
• Bracketing Approach
• Virtual BE
• In Vitro In Vivo Correlation (IVIVC)
• Concluding Remarks
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Role of Biopharmaceutics
Critical
In Vivo Performance
Material/Process/
of Drug Product
Quality Attributes
(CMA, CPP, CQA) BIOPHARMACEUTICS e.g., Bioavailability
(BA)/Bioequivalence
e.g., In Vitro
(BE) data
Dissolution
Moderate Changes
Could have a
significant impact
Biowaiver is Biowaiver is
not needed Applicable 7
Biowaiver Approaches for
Solid Oral Dosage Forms
CFR
21 CFR 320.22(d)(2)
Safe Space
BCS
Biowaiver Bracketing Approach
Approaches Virtual BE
IVIVC
Risk Assessment*
* Applicable to bridge product changes and strengths when waiver requirements are not met
21 CFR 320.22
FDA Guidance for Industry. Waiver of In Vivo BA/BE Studies for IR Solid Oral Dosage Forms Based on a Biopharmaceutics Classification System. December 2017 8
FDA Guidance for Industry – Extended Release Oral Dosage Forms : Development, Evaluation, and Application of In Vitro/In Vivo Correlations
Biowaiver Approaches for
Solid Oral Dosage Forms
CFR
21 CFR 320.22(d)(2)
Safe Space
BCS
Biowaiver Bracketing Approach
Approaches Virtual BE
IVIVC
Risk Assessment*
10
* Applicable to bridge product changes and strengths when waiver requirements are not met
21 CFR 320.22(d)(2) Based Biowaiver
21 CFR 320.22 11
FDA Draft Guidance for Industry - Bioavailability and Bioequivalence Studies Submitted in NDAs or INDs — General Considerations (2014)
Strength Dependent Dissolution
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21 CFR 320.22(d)(2)
Case Example 1 – Strength Dependent Dissolution
• Drug Product X - Drug A
• Immediate release tablet
• Two strengths
• BCS Class 2 drug substance
– pH dependent solubility: Solubility decreases with increase in pH
• An in vivo BE study bridging lower strength (Phase 2 formulation) and
higher strength [Phase 3/to-be-marketed formulation (TBM)]
– Major Formulation Change (Phase 2 to Phase 3)
– BE demonstrated for phase 2 and phase 3 formulation
– No PK data for lower strength (TBM)
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Suarez-Sharp, S.; Delvadia, P.R.., et. al. Regulatory Perspectives on Strength-Dependent Dissolution Profiles and Biowaiver Approaches for Immediate Release (IR) Oral Tablets in New Drug Applications. AAPSJ.
2016. May 18(3): 578-588
Case Example 1 – Strength Dependent Dissolution
pH 4.5
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Case Example 1 – Strength Dependent Dissolution
pH 4.5
Multiunit Dissolution
f2>50
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21 CFR 320.22(d)(2) Based Biowaiver - Summary
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Suarez-Sharp, S.; Delvadia, P.R.., et. al. Regulatory Perspectives on Strength-Dependent Dissolution Profiles and Biowaiver Approaches for Immediate Release (IR) Oral Tablets in New Drug
Applications. AAPSJ. 2016. May 18(3): 578-588
Biopharmaceutics Classification System
(BCS) Based Biowaiver
CFR
21 CFR 320.22(d)(2)
Safe Space
BCS
Biowaiver Bracketing Approach
Approaches Virtual BE
IVIVC
Risk Assessment*
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* Applicable to bridge product changes and strengths when waiver requirements are not met
BCS Based Biowaiver Approach
• BCS framework – Drug substance categorized into four classes
FDA Guidance for Industry. Waiver of In Vivo BA/BE Studies for IR Solid Oral Dosage Forms Based on a Biopharmaceutics Classification System. December 2017 18
https://www.researchgate.net/figure/Biopharmaceutical-classification-system-57_fig3_11646132
BCS Based Biowaiver Approach
T – Test Product 19
R – Reference Product
BCS Based Biowaiver
Case Example 2 – Biowaiver for Pharmaceutical Alternative
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BCS Based Biowaiver – Summary
• Common deficiencies
– Insufficient number of pH conditions (as per BCS guidance) to define pH
solubility profile
– Absence of analytical validation report
– Lack of stability indicating assay
– Incomplete information on permeability studies
– Lack of data on gastrointestinal stability of drug
– Lack of dissolution information, etc.
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Risk Assessment Based Biowaiver
CFR
21 CFR 320.22(d)(2)
Safe Space
BCS
Biowaiver Bracketing Approach
Approaches Virtual BE
IVIVC
Risk Assessment*
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* Applicable to bridge product changes and strengths when waiver requirements are not met
Risk Assessment
Case Example 3 – Support Minor Manufacturing Change
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Risk Assessment Based Biowaiver - Summary
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Safe Space Based Biowaiver
CFR
21 CFR 320.22(d)(2)
Safe Space
BCS
Biowaiver Bracketing Approach
Approaches Virtual BE
IVIVC
Risk Assessment*
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* Applicable to bridge product changes and strengths when waiver requirements are not met
Safe Space Approaches
• Safe space – Boundaries defined by dissolution profiles within which drug
product batches are anticipated to be bioequivalent to one another
Bioequivalent
Safe Space
Outside of Safe Space
In vivo performance not known
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Sandra Suarez-Sharp, et. al. Applications of Clinically Relevant Dissolution Testing. Workshop Summary Report. The AAPS Journal (2018) 20: 93
Safe Space Approaches
• Safe space can be defined by – Bracketing approach, virtual bioequivalence, and IVIVC
• Application for both setting clinically relevant drug product specification and gaining
regulatory flexibility i.e., biowaiver
• Safe space based on Approach B, C1, and C2 is wider than based on pivotal clinical trial
batches
• Selection of the safe space approach depends on the type of data available
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Sandra Suarez-Sharp, et. al. Applications of Clinically Relevant Dissolution Testing. Workshop Summary Report. The AAPS Journal (2018) 20: 93
Safe Space - Bracketing Approach
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Bracketing Approach
• Demonstration of bioequivalence between strengths or drug product
variants representing the extremes in dissolution profiles. All dissolution
profiles falling within the BE dissolution bounds are considered to be BE.
Bioequivalent
Safe Space
Outside of Safe Space
In vivo performance not known
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Bracketing Approach Based Safe Space
Case Example 4 – Bridging of Intermediate Strength
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Case Example 4 – Bracketing Approach Based Safe Space
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Safe Space – Virtual Bioequivalence (BE)
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Virtual BE Based Safe Space
• Virtual BE study using physiologically based biopharmaceutics modeling (PBBM) approach to demonstrate
bioequivalence between test and reference drug products
• PBBM uses mechanistic models which integrate physicochemical properties of API, physiological
conditions, and formulation variables (e.g., dissolution profile as a function of formulation variables) for
prediction of systemic exposure vs time
Verified Model
Test and Reference are BE
Virtual BE Study
Safe Space
Safe Space
Xavier J. H. Pepin, Talia R. Flanagan et. al., Justification of Drug Product Dissolution Rate and Drug Substance Particle Size Specifications Based on Absorption PBPK 36
Modeling for Lesinurad Immediate Release Tablets. Molecular Pharmaceutics. 2016. 13, 3256 – 3269.
Virtual BE - Summary
• Virtual BE is a valuable tool
– Gaining experience in regulatory applications e.g., setting clinically relevant drug
product specification
• However, biowaiver application is limited
– Lack of confidence on the model
• Thorough model verification to increase confidence in the model prediction
– Verification using BE and non-BE batches to evaluate predictability of the model
• The regulatory application of virtual BE based safe space will depend on
the data used to develop and verify the relationship
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Sandra Suarez-Sharp, et. al. Applications of Clinically Relevant Dissolution Testing. Workshop Summary Report. The AAPS Journal (2018) 20: 93
Safe Space – In Vitro In Vivo Correlation (IVIVC)
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IVIVC
• “A predictive mathematical model describing relationship between an in
vitro property (e.g., dissolution time profile) and a relevant in vivo
response (concentration time profile) of a drug product”
• Goal: to predict the in vivo plasma concentration-time profile
• Application:
– To support major formulation/manufacturing changes (biowaiver)
– To support product strength equivalence (biowaiver)
– To set drug product specifications [e.g., dissolution, hardness]
• Categories of IVIVC
– Level A,
– Level B,
– Level C, IVIVC
– Multiple Level C
FDA Guidance for Industry – Extended Release Oral Dosage Forms : Development, Evaluation, and Application of In Vitro/In Vivo Correlations
Sharp, S.S. et. al. (2016). Regulatory Experience in IVIVC in New Drug Applications. The AAPS Journal.
39
http://www.pharmogo.com/training.php?act=show&id=30
Level A IVIVC
Case Example 5 – Manufacturing site change and product strength equivalence (MR product)
• Biowaiver Request
– Lower strength
– Manufacturing site change
40
Level A IVIVC
Treatment B
42
IVIVC based Safe Space
Safe Space
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IVIVC – Summary
• Advantages
– Reduced regulatory burden/Gain regulatory flexibility
– Supports clinically relevant drug product specification settings
– Potential of wider drug product specifications
– Approval of meaningful design space in Quality by Design framework
• Low success rate
– Insufficient considerations of in vivo situation with conventional IVIVC
methodologies
• Physiologically based/Mechanistic IVIVC has promising advantages
to address limitation with conventional methodologies
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Sandra Suarez-Sharp, Min Li., et. al. Regulatory Experience with In Vivo In Vitro Correlations (IVIVC) in New Drug Applications. The AAPS Journal. 18 (6), Nov 2016. 1379 - 1390
Concluding Remarks
• Approaches for Biowaiver
– Selection of approach depends on the type of in vitro and in vivo data available
– Dissolution is one of the key elements
– Establishment of in vitro – in vivo link and clinical relevance for biowaiver applications and lifecycle
management of drug products
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Acknowledgements
• Sandra Suarez Sharp, Ph.D.
• Kimberly Raines, Ph.D.
• Paul Seo, Ph.D.
• Min Li, Ph.D.
• John Duan, Ph.D.
• Meng Wang, Ph.D.
• Division of Biopharmaceutics Colleagues
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