Category Archives: biotechnology

Health Canada releases draft guidance on classification of observations for inspection of cells, tissues and organs establishments

Health Canada has released a draft guidance to assist with companies become compliant with the safety of human cells, tissues and organs for transplantation regulations which came into force on 7 December 2007. The purpose of this regulatory initiative is to minimise the potential health risks to Canadian recipient of human cells and tissues and organs. And to ensure that such organisations remain compliant with the proposed regulations.

More information is available on the Health Canada website

FDA publish updated guidance on current good tissue practice (CGTP)

The FDA is issuing this guidance to provide establishments that manufacture human cells, tissues, and cellular tissue-based products with recommendations complying with current good tissue practice (CGTP).

This is to ensure that all of these establishments can remaining compliance with 21CFR part 1271 subpart D and subpart E

FDA produces guidelines on the use of nucleic acid test on pooled and individual donor samples to reduce risk of hep B transmission

This guidance is being provided to blood establishments that collect whole blood and blood components for transfusion or other manufacturing. The FDA recommends the use of FDA licensed nucleic acid test to screen blood donors hepatitis B virus DNA. This guidance also provides recommendations for blood testing and disposition, Doner Management, methods of Donerrequalification and product labelling.

Full guidance provided below

FDA releases guidance on the re-qualification method for re-entry of donors who test positive for hepatitis B following vaccination

This guidance is intended for blood establishments the manufacturer whole blood and blood components including source plasma and source leucocytes. It provides guidance for the re-qualification method or process for the re-entry of deferred donors who test repeatedly reactive for hepatitis B surface antigens, confirmed positive by neutralisation, following a recent vaccination for hepatitis B infection, and who are not infected by hepatitis B virus.

Full guidance given below

New FDA resource: bioequivalence recommendations for specific products

The FDA has brought together all the its bioequivalence recommendations for specific products into one online database, over the years a number of specific recommendations have been made across a large number of products. These recommendations are now brought together in a single database (currently containing 890 products) which can be accessed through the FDA website link provided below, this is specifically aimed at people developing “generic biological” products to give them an understanding of expectations of the FDA with regard to bioequivalence.

FDA thePage http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm075207.htm#.TrufoqKWmLA.email

EMA publishes a reflection paper on methodological issues associated with pharmacgenomic biomarkers

As the number of available techniques to facilitate the study of human genomics has led to an exponential increase in investigation into genomic bio markersthe diagnosis of specific diseases. The AMA has decided that a guidance would be required to assist companies in implementing these technologies into clinical drug development.

These techniques are frequently used patient selection stratification or treatment strategies of patient groups, and the EMA is concerned the appropriate steps are not been taken hence the publication of this guidance.

excerpt from guidance

full text here

The availability of techniques that facilitate study of the human genome has led to an exponential increase in investigation into genomic biomarkers (GBMs) for diagnosis of specific diseases, as a marker of response to treatment or of prognosis. Theoretically genomic BMs should offer the advantage of improved specificity and reduction of heterogeneity that is an integral part of phenotypic population grouping. This is very attractive in drug development because of their potential ability to reduce drug attrition and to reduce overall developmental costs, that are achieved through improved understanding of the mechanism of drug action, predict adverse events to individual drugs or as a group effect (e.g. CYP poor metabolisers), and use of novel development strategies in pre-clinical and clinical phases.
In clinical drug development, GBMs may aid and influence a wide range of areas: patient selection, stratification of treatment strategies or patient groups, early evaluation of treatment effect including adverse reactions, and prognosis. There is opportunity for the GBMs to be used for pre-defined subgroup analysis or to enable novel trial designs that might not be possible otherwise due to heterogeneity of clinical characteristics.1,2 GBMs could also play a valuable role in the risk management strategies including risk minimisation by aiding a priori identification of patients susceptible to develop severe adverse effects (e.g. HLA B*- 5701 and use of Abacavir).
While a number of these aspects are discussed in many publications in the recent years, specific aspects relating to drug development and discussion on regulatory considerations have lagged behind. The intention of this paper is therefore to provide an evidence based consideration of GBM related issues from a regulatory viewpoint. Mention is also made of co-development of a GBM diagnostic test for use with a medicinal product.
The principles established in the reflection paper are based on the experiences gained from the evaluation of dossiers within the EU regulatory processes —including marketing authorisation applications reviewed by CHMP, the scientific advice documents and additionally, the voluntary genomic data submission meetings (briefing meetings) at the Pharmacogenomic Working party (PGWP) over the last several years. It is expected that these principles guide both industry and the assessors in the evaluation of such biomarkers in relation to the qualification process in the context of clinical development (BM qualification in EU) and the assessment of benefit: risk balance of medicinal products or selection of the relevant target population. The paper should also be read in conjunction with other relevant guidelines listed at the end of the documents under section “Other aspects”.
Development of GBMs and diagnostic tests may involve additional development of tests (companion diagnostics) or specific kits (platforms) to detect for the presence or absence of the GBM. Issues relating to these are outside the scope of this paper but a short discussion is included. The readers are referred to appropriate guidelines/ papers for details (see section on other aspects).

EMA publishes guideline on bioanalytical method validation

EMA has publishes guidelines to assist companies understand key elements required for validation of a bioanalytical method. It focuses on the validation geared towards quantitative concentration data used for pharmacokinetic and toxicokinetic parameter definitions. Guidance on criteria of application of these validated methods in the routine analysis of study samples from animals and humans.

excerpts from guidance

full text here

This guideline defines key elements necessary for the validation of bioanalytical methods. The guideline focuses on the validation of the bioanalytical methods generating quantitative concentration data used for pharmacokinetic and toxicokinetic parameter determinations. Guidance and criteria are given on the application of these validated methods in the routine analysis of study samples from animal and human studies.

Measurement of drug concentrations in biological matrices (such as serum, plasma, blood, urine, and saliva) is an important aspect of medicinal product development. Such data may be required to support applications for new actives substances and generics as well as variations to authorised drug products. The results of animal toxicokinetic studies and of clinical trials, including bioequivalence studies are used to make critical decisions supporting the safety and efficacy of a medicinal drug substance or product. It is therefore paramount that the applied bioanalytical methods used are well characterised, fully validated and documented to a satisfactory standard in order to yield reliable results.
Acceptance criteria wider than those defined in this guideline may be used in special situations. This should be prospectively defined based on the intended use of the method.

EMA publishes guidance on quality aspects on the isolation of candidate influenza viruses in cell culture

This EMA guideline lays down the quality recommendations the cells used to isolate candidate influenza vaccine viruses, the conditions in which to which the viruses are isolated and the subsequent purification and development of master seed batches and GMP conditions.

This guidance considers the different technologies available and that are in wide use and makes a series of recommendations. Manufactures still need to consider which are most appropriate for their products.

excerpt from guidance

full text here

This Guideline lays down the quality recommendations for cells used to isolate candidate influenza vaccine viruses, the conditions under which the viruses are isolated and the subsequent passage of the
viruses until the manufacturer’s Master Seed is prepared under GMP conditions.

Many influenza vaccine manufacturers are developing cell culture processes for the production of inactivated vaccine using a variety of cell types and several such vaccines have been licensed within the EU. Manufacturers of cell-derived vaccine typically use the recommended egg-derived candidate vaccine virus to derive their seed virus; this may be the wild type egg isolate or a high growth reassortant (hgr), especially for influenza A viruses. There is currently no published evidence that the use of an egg-derived hgr provides a growth advantage in cells compared with the wild type eggderived recommended strain – it is simply the vaccine virus that is available from WHO collaborative laboratories that supply such viruses.
Manufacturers of cell-derived influenza vaccine may prefer to use a cell-only passaged virus instead of one that has been egg-adapted. This is because research indicates that when a human influenza virus is adapted to grow in eggs, it undergoes phenotypic changes that might include changes to its antigenicity/immunogenicity [1]. Virus isolated on mammalian cell cultures do not, attheleast initially, undergo the type of selection that occurs during initial passage in eggs and typically the haemagglutinin (HA) of a cell isolated virus is structurally more related to the virus found in clinical specimens in contrast to egg-adapted variants in which specific HA amino acid substitutions have been identified [1]. Thus a cell-isolated virus might be more clinically relevant for vaccine than an egg isolate although to date this has not been fully demonstrated scientifically. For the reasons mentioned above, manufacturers are now keen to use non-egg adapted viruses, which are antigenically closer to the wild type virus. However, cells in general use by National Influenza Centres and WHO Collaborating Centres for virus isolation are not qualified/validated for use in deriving a candidate vaccine virus and so currently only egg-isolated viruses are taken forward as vaccine candidates.

The major concern in isolating vaccine viruses in cells is the possibility of adventitious agent contamination that might derive from the cells, the environment or materials used during isolation and propagation of the viruses. Thus, the purpose of this document is to provide regulatory guidance on the quality of the cells used to isolate the virus, the conditions under which viruses are isolated and the subsequent passage of these viruses until the manufacturer’s master seed is prepared according to GMP. Normally, regulatory guidance is directed towards the vaccine manufacturers as it is they who have the responsibility for ensuring that their vaccine seed is suitable for the production of a human influenza vaccine. However, it is appreciated that the isolation of influenza candidate vaccine viruses will take place in WHO Collaborating Centres and as such, from a practical point of view, these laboratories should be familiar with the EU recommendations presented in this document. The quality aspects of the establishment of a manufacturer’s Master Seed lot and subsequent use in a cell vaccine manufacturing process have been described previously in the guideline ‘Cell Culture Inactivated Influenza Vaccines, Annex to note for guidance on harmonisation of requirements for influenza vaccines’ [2] and will not be further addressed in this document.

DMA publishes concept paper on bio similars containing proteins

In the current EMA guideline on similar biological medicinal products containing biotechnology derived proteins as active substances, nonclinical and clinical issues lays down the requirements of such products to determine its similarity to one another. This guidance came into effect in June 2006, however since then several by a similar products have come to the market and the number of guidance is in this area has increased significantly and the regulatory framework is becoming wider.

The EMA considers it necessary to update these guidance and bring together a number of issues into a single document. In order to tackle the complex issues that are arising. And to allow for the WHO guidelines on evaluation of similar biotherapeutic products. And also to be compliant with the Three R principals (replacement, reduction and refinement) with regard to the use of animal experiments.

excerpt from concept paper

full text here

The Guideline on similar biological medicinal products containing biotechnology-derived proteins as active substance: non-clinical and clinical issues (EMEA/CHMP/BMWP/42832/2005) lays down the  nonclinical and clinical requirements for a biological medicinal product  claiming to be similar to another one already marketed. This guideline came into effect in June 2006. Since then several biosimilar products
have come into the EU market, the number of scientific advices given by the CHMP on the development of biosimilar products has increased significantly and the regulatory framework is becoming wider, e.g. the draft guideline of the biosimilar monoclonal antibodies is being finalised. .An increasing number of biosimilar products are under development, especially biosimilar monoclonal antibodies. The development of more complex biosimilar medicinal products is challenging, and several issues in the development are under re-evaluation. These include the selection of relevant species for
non-clinical studies, need for clinical equivalence studies and other issues of the design of the pivotal clinical studies, role of biomarkers, amount of immunogenicity data needed, and the possibility to
extrapolate to other indications. The WHO Guidelines on Evaluation of Similar Biotherapeutic Products with detailed recommendations on clinical development were published in October 2009. In addition,
the EMA is emphasizing the need to follow the 3 R principles (replacement, reduction and refinement) with regard to the use of animal experiments. All these factors suggest revising the current guideline.

EMA Publish Concept Paper on Bio-Similar products containing Active Proteins: Clinical and Non-Clinical

EMA Publish Concept Paper on Bio-Similar products containing Active Proteins: Clinical and Non-Clinical

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The Guideline on similar biological medicinal products containing biotechnology-derived proteins as active substance: non-clinical and clinical issues (EMEA/CHMP/BMWP/42832/2005) lays down the  nonclinical and clinical requirements for a biological medicinal product claiming to be similar to another one already marketed. This guideline came into effect in June 2006. Since then several biosimilar  products have come into the EU market, the number of scientific advices given by the CHMP on the development of biosimilar products has increased significantly and the regulatory framework is becoming wider, e.g. the draft guideline of the biosimilar monoclonal antibodies is being finalised.

An increasing number of biosimilar products are under development, especially biosimilar monoclonal antibodies. The development of more complex biosimilar medicinal products is challenging, and several issues in the development are under re-evaluation. These include the selection of relevant species for non-clinical studies, need for clinical equivalence studies and other issues of the design of the pivotal clinical studies, role of biomarkers, amount of immunogenicity data needed, and the possibility to extrapolate to other indications. The WHO Guidelines on Evaluation of Similar Biotherapeutic Products with detailed recommendations on clinical development were published in October 2009. In addition, the EMA is emphasizing the need to follow the 3 R principles (replacement, reduction and refinement) with regard to the use of animal experiments. All these factors suggest revising the current guideline.



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EMA and FDA set up Biosimilar Cluster and Publish Report

EMA and FDA set up Biosimilar Cluster and Publish Report

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The European Medicines Agency (EMA) and the United States Food and Drug Administrationicon link external EMA and FDA set up Biosimilar Cluster and Publish Report (FDA) have set up a new ‘cluster’ on biosimilar medicines.

Clusters are topic areas of mutual interest for the two agencies, which they have identified as benefiting from the regular exchange of information and collaborative meetings. Biosimilar medicines is the latest addition to the existing list of topics, which already includes medicines to treat cancer, orphan medicines, medicines for children and blood-based products.

The new cluster will allow the two agencies to increase their degree of interaction and will begin with a kick-off meeting to discuss the group’s activities. The group will follow this with discussions by teleconference around three times a year.

This is the latest step in the two agencies’ ongoing collaboration on regulatory issues under their confidentiality arrangements, which they first signed in 2003. The degree of interaction between the EMA and the FDA has increased significantly since then, to the current stable level of around 55 interactions per month, according to the first report on interactions between the two agencies, published today.

The report, which covers regular and ad-hoc interactions, emphasises the close level of collaboration between the two agencies, including the exchange of staff and regular staff visits, the co-ordination of communication on high-profile issues and the exchange of information on topics of shared interest.

The agencies plan to issue an report on their interactions every year.



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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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FDA Publish Guidance on E16 Biomarkers Related of Drug or Biotechnology Product Development Context, Structure and Format of Qualification Submissions

FDA Publish Guidance on E16 Biomarkers Related of Drug or Biotechnology Product Development Context, Structure and Format of Qualification Submissions

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The guidance describes recommendations regarding context, structure and format of regulatory submissions for qualification of genomic biomarkers (as defined in ICH E15 3). Qualification is a conclusion that, within the stated context of use, the results of assessment with a biomarker canbe relied upon to adequately reflect a biological process, response, or event, and support use of the biomarker during drug or biotechnology product development, ranging from discovery through postapproval. A biomarker qualification application might be submitted to regulatory authorities if the biomarker directly or indirectly helps in regulatory decision-making.

The objective of the guidance is to create a harmonized recommended structure for biomarker qualification applications that will foster consistency of applications across regions and facilitate discussions with and among regulatory authorities. It will also reduce the burden on sponsors as a harmonized format will be recommended for use across all ICH regulatory regions. It is also expected that the proposed document format will facilitate incorporation of biomarker data into specific product-related applications. Biomarker qualification can take place at any time during drug or biotechnology product development, ranging from discovery through postapproval. For those instances where it is appropriate, general guidance for inclusion of biomarker qualification data into the Common Technical Document for the Registration of Pharmaceuticals for Human Use (CTD) format for marketing authorization applications is provided in this document. The use of the CTD format would be considered appropriate when biomarker data are submitted as part of a new drug application (NDA), a biologics license application (BLA), a market authorization application (MAA), or other postapproval regulatory procedures, or upon request by the regulatory authorities.

The use of biomarkers has the potential to facilitate the availability of safer and more effective drug or biotechnology products, to guide dose selection, and to enhance their benefit-risk profile. This guidance is based on previous experiences with submissions containing biomarker data in the various regions. These submissions have been either stand-alone biomarker qualification applications or a component of medicinal product-related regulatory process marketing applications (NDAs/BLAs/MAAs). The development of a consistent format for submission of biomarker data will facilitate easy review and exchange of assessments between regions.


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EMA Seeks Views on Genomic Markers and Use in Development

EMA Seeks Views on Genomic Markers and Use in Development

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European Medicines Agency seeks views on genomic markers in medicine development

The European Medicines Agency has released a reflection paper on use of ‘genomic markers’ in the development and testing of human medicines for public consultation.

The reflection paper on methodological issues associated with pharmacogenomic biomarkers in relation to clinical development and patient selection discusses the role that markers in the DNA can play in predicting which patients are likely to benefit from a medicines or experience side effects. The paper also covers their role in understanding how medicines work, selecting patients for inclusion in clinical trials and evaluating treatments.

The paper, prepared by the Committee for Medicinal Products for Human Use’s (CHMP’s) Pharmacogenomics Working Party, focuses on the experiences gained by the Agency through applications for marketing authorisations and scientific advice.

The paper is open for comments until 25 November 2011.


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FDA Publish Guidance on eSubmitter Programme from Licensed Blood Establishments

FDA Publish Guidance on eSubmitter Programme from Licensed Blood Establishments

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The FDA, the Center for Biologics Evaluation and Research (CBER), are announcing to you, licensed blood establishments that collect Whole Blood and blood components, including Source Plasma, the availability of CBER’s eSubmitter Program (eSubmitter), an electronic submissions program. The eSubmitter program is intended to facilitate submission and processing of regulatory filings, including biologics license applications (BLAs), BLA supplements (BLSs), annual reports and amendments to pending eSubmitter applications and supplements. In this guidance, we describe how you may obtain and use the eSubmitter program.

FDA’s eSubmitter is an electronic submissions program that is available for voluntary use by sponsors, manufacturers, and importers to submit a variety of submission types for FDA-regulated products. The eSubmitter application software, which can be downloaded free of charge, assists applicants in the preparation of submissions that contain the minimum elements necessary for FDA to perform a comprehensive review.
The eSubmitter program is designed to ensure that applicants include necessary information in their regulatory submissions. The eSubmitter program also functions to guide users as they complete the filing process. FDA believes that eSubmitter will help improve the consistency, quality and completeness of regulatory submissions and make the submission and review process more user-friendly for applicants. In the future, additional instructions for electronic submissions may be posted on the FDA website.

The FDA eSubmitter program is government-issued software governed by the Government Paperwork Elimination Act of 1998. As a user of this software, you are not required to perform your own validation. However, if you decide to use the software for purposes other than the intended uses identified in this guidance, you may be required to comply with additional requirements applicable to those intended uses.
In the Federal Register of March 26, 2009, FDA announced an invitation to participate in a pilot evaluation program for the use of eSubmitter for BLAs and BLSs submitted by blood establishments that collect Source Plasma (74 FR 13210). In the Federal Register of September 7 2010, FDA announced an invitation to participate in another pilot evaluation program, this time for the use of eSubmitter for BLAs and BLSs submitted by blood establishments that collect Whole Blood and blood components (75 FR 54343). These pilot programs were intended to provide industry and CBER regulatory staff the opportunity to evaluate the effectiveness of eSubmitter for these purposes. FDA has completed its evaluation of these pilot programs and the agency now has decided to make this system broadly available.


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EMA Publish Guidance on Plasma-Derived Medicinal Products

EMA Publish Guidance on Plasma-Derived Medicinal Products

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Human plasma contains many proteins which, following extraction, purification, and formulation into medicinal products are of great medical importance. Plasma-derived products provide life-saving therapies but the quantity of plasma for fractionation is limited by the number of donors. Therefore, the exchange of intermediates between manufacturers or the use of a variant manufacturing process (see below) may be possible to assure the best use of blood/plasma donations.
Although the therapeutic use of blood transfusion goes back to the beginning of the 20th century, it was not until the 1940s that the technique of plasma fractionation, devised by Cohn and colleagues, enabled the widespread use of medicinal products extracted from human plasma.
Improvements in protein purification and molecular separation technology have made available a wide variety of products, with medical applications covering a large field, and the therapeutic value of these is unquestioned. However, the potential for viral transmission is well recognised, and because of the large number of donations which are pooled, a single contaminated batch of a plasma-derived product, with the contamination possibly originating from a single donation, can transmit viral disease to a large number of recipients. The recognition in the mid-1980′s that plasma-derived medicinal products, in particular coagulation factor concentrates, had caused widespread transmission of human immunodeficiency virus (HIV) and hepatitis C (previously identified as non-A non-B hepatitis) resulted in major changes to the manufacturing processes, with the introduction of specific steps to inactivate or remove these and other blood-borne viruses. Infectious non-enveloped viruses were detected in certain plasma-derived medicinal products during the 1990’s and early 2000’s. Therefore, recent process development has been devoted to further reducing non-enveloped viruses such as hepatitis A (HAV) and parvovirus B19 (B19V).
Measures taken to prevent infection include selection of donors, screening of individual donations and plasma pools for markers of infection with known viruses and validation of the production process for inactivation or removal of viruses. From the 1990’s on, measures designed to minimise contamination of the starting plasma have been improved by the refinement of serological test kits and the use of nucleic acid amplification technology (NAT) for the testing of viral DNA and RNA, thereby shortening the window period during which infectious donations are not detected.
Recent cases of apparent iatrogenic variant Creutzfeldt-Jakob disease (vCJD) infection by blood transfusion in man in the UK provide strong evidence that vCJD is transmissible through blood transfusion. Precautionary measures to minimize the risk of transmission of infectivity by plasma-derived medicinal products were put in place by CHMP in 1998 following the identification of the first cases of vCJD and have been kept under review and updated as needed.
The legal basis for EU minimum standards for the quality and safety of the starting material for plasma-derived medicinal products has been established along with the pharmaceutical legislation and specific provisions have been laid down in the pharmaceutical Directive 2001/83/EC as amended. In this legislation the option of a centralised certification of Plasma Master File was established.
In 2003 the European Parliament and the Council have adopted the overarching Directive 2002/98/EC “Setting standards of quality and safety for the collection, testing, processing, storage and distribution of human blood and blood components…”, also known as the “Blood Directive”. Thereby, from 8 February 2005, Directive 2002/98/EC amending Directive 2001/83/EC establishes the requirements for the collection and testing of human blood and blood components whatever the intended purpose. In line with this Directive, the technical Directives 2004/33/EC, 2005/61/EC and 2005/62/EC have been issued by the Commission. Guidance is also provided by the “Guide to the Preparation, Use and Quality Assurance of Blood Components” of the Council of Europe which contains a compendium of measures designed to ensure the safety, efficacy and quality of blood components.


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FDA Publish Execptions and Alternative Procedures Approved under 21 CFR 640.120

FDA Publish Execptions and Alternative Procedures Approved under 21 CFR 640.120

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Title 21 Code of Federal Regulations 640.120(a) – The Director, Center for Biologics Evaluation and Research, may approve an exception or alternative procedures to any requirement in subchapter F (Biologics) of Chapter I (Parts 600 – 680) of title 21 of the Code of Federal Regulations regarding blood, blood components or blood products.

Both licensed and unlicensed blood establishments must submit requests for an exception or alternative procedure to the requirements in Parts 600-680. Licensed establishments should submit the request in accordance with 21 CFR 601.12 and may reference our guidance document entitled: Guidance for Industry: Changes to an Approved Application: Biological Products: Human Blood and Blood Components Intended for Transfusion or for Further Manufacture (July 2001).

Requests for such exceptions or alternative procedures should ordinarily be made in writing, however, in limited circumstances, such requests may be made orally and permission may be given orally by the Director. Oral requests and approvals must be promptly followed by written requests and written approvals.

It should be noted that requests for exceptions or alternate procedures includes specific circumstances and may require submission of supporting data unique to the circumstance. Publication of these approvals for a specific exception or alternative procedure does not necessarily mean that they can be generally applied to other manufacturers.



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EMA Publishes Concept Paper on Clinical and Non-Clinical Development of Similar Biological Medicinal Products Containing Heparins

EMA Publishes Concept Paper on Clinical and Non-Clinical Development of Similar Biological Medicinal Products Containing Heparins

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The Guideline on Similar Medicinal Products containing Low-Molecular-Weight Heparins (LMWH) lays down the non-clinical and clinical requirements for the development of LMWH claimed to be similar to a
reference product already authorised in the EU. This guideline came into effect in October 2009. So far, no biosimilar LMWH has been licensed in the EU.

LMWHs are complex sugar molecules and difficult to characterise. Structure-activity relationship is not fully elucidated and other mechanisms of action beyond Anti-Xa and Anti-IIa activity may be important for the pharmacological activity. The current CHMP guidance requires a comparative clinical trial demonstrating similar efficacy and safety of the biosimilar versus the reference LMWH in the prevention of venous thromboembolism (VTE) in patients undergoing major orthopaedic surgery. Based on scientific and analytical progress, e.g. in the field of physicochemical characterisation, it can
be discussed if in exceptional cases convincing analytical data can substitute for clinical data, at least for clinical efficacy.

The BMWP suggests discussing the inclusion of considerations about the possibility to modify clinical data requirements in the guideline taking into account the extent and quality of characterisation and the possibility to convincingly ensure similar efficacy and safety (including immunogenicity) of the biosimilar and the reference LMWH by other means. It should be discussed if a reduction in clinical data requirements could, in exceptional cases, be possible.



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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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EMA Announce Workshop on Advanced Therapy Medicinal Products

EMA Announce Workshop on Advanced Therapy Medicinal Products

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This workshop is the first event organised by the Committee for Advanced Therapies (CAT) in cooperation with a learned society. The workshop is bringing together industry, academia and regulators to discuss how to progress towards the development of advanced therapy medicinal products. It is addressing specific issues related to both gene therapy and cell-based medicinal products.



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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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EMA Publish Concept Paper on BioSimilars for Recombinant Human Insulin

EMA Publish Concept Paper on BioSimilars for Recombinant Human Insulin

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The current Guidance on Similar Medicinal Products containing Recombinant Human Insulin provides recommendations for the development of recombinant soluble (short-acting) human insulin claimed to
be similar to a reference product already authorised in the EU. This guideline came into effect in June 2006 but, so far, no biosimilar insulin has been licensed in the EU. Three products applied for by the same Applicant were withdrawn prior to Opinion.

More recently, several EMA scientific advices on the development of biosimilar insulins, particularly insulin analogues, have been requested. Insulin analogues and long-acting human insulin preparations are currently not covered by the above guideline. In addition, different study populations, study designs and insulin doses have been proposed for the pivotal PD study (clamp study). Moreover, the guideline does not appear to be clear on whether the PK study can be combined with the PD study. Questions were raised regarding the most suitable patient population and size of the clinical safety study. It has also been questioned whether non-clinical studies would always be needed in the development of biosimilar insulins.

Although similar considerations and scientific principles may apply to biosimilar insulin analogues and long-acting human insulin preparations as to soluble insulins, some thoughts may need to be given to the sensitivity of the clamp study for detection of potential differences in the duration of action or other summary measures between long-acting insulin formulations due to the flat PK profile of these insulins
and high variability in the tail part of the clamp study. In addition, further considerations regarding the study population (patients with type 1 diabetes versus healthy volunteers), study design (e.g. with
versus without basal insulin infusion) and insulin dose in the clamp study could be included. It may be clarified that the comparative PK evaluation is usually expected to be part of the clamp (PD) study. It could also be clarified that no formal non-inferiority testing for antibody frequency is expected in the safety study and that inclusion of patients with type 1 and type 2 diabetes may be appropriate. Regarding non-clinical requirements, a risk-based approach may be introduced.



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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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FDA Publishes Guidance on INDs for Minimally Manipulated, Unrelated Allogenic Placental/Umbilical Cord Blood Intended for Hemotopoietic Reconstruction

FDA Publishes Guidance on INDs for Minimally Manipulated, Unrelated Allogenic Placental/Umbilical Cord Blood Intended for Hemotopoietic Reconstruction

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We, the Center for Biologics Evaluation and Research (CBER), FDA, are providing advice to you, potential sponsors (e.g., cord blood banks, registries, transplant centers, or individual physicians serving as sponsor-investigators), to assist in the submission of an IND for certain hematopoietic progenitor cells, cord (HPC-C)1, when such HPC-Cs are not licensed in accordance with Title 21 Code of Federal Regulations Part 601 (21 CFR Part 601), and when a suitable human leukocyte antigen (HLA) matched cord blood transplant is needed for treatment of a patient with a serious or life-threatening disease or condition and there is no satisfactory alternative treatment available. If unlicensed HPC-Cs are made available for clinical use, they must be distributed under an IND meeting the applicable requirements in 21 CFR Part 312.
This guidance finalizes the draft guidance entitled “Guidance for Industry and FDA Staff: Investigational New Drug Applications (INDs) for Minimally Manipulated, Unrelated Allogeneic Placental/Umbilical Cord Blood Intended for Hematopoietic Reconstitution for Specified Indications” dated October 2009 (October 20, 2009, 74 FR 53751) (“draft IND guidance”).



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Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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