Category Archives: biotechnology

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

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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.

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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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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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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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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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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FDA Publish Guidance on Donor History Questionnaires for Screening Donors of Source Plasma

FDA Publish Guidance on Donor History Questionnaires for Screening Donors of Source Plasma

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This guidance recognizes the standardized full-length and abbreviated donor history questionnaires and accompanying materials, version 1.0.1 dated December 2010, prepared by the Plasma Protein Therapeutics Association (PPTA) as an acceptable mechanism that is consistent with the Food and Drug Administration’s (FDA’s) requirements and recommendations for collecting Source Plasma donor history information. We, FDA, may recognize other PPTA Source Plasma donor history questionnaires and accompanying materials (SPDHQ documents) as acceptable, and intend to make all of the acceptable SPDHQ documents available on the FDA website.
The SPDHQ documents will provide blood establishments that collect Source Plasma (referred to as “manufacturers” or “you”), with a specific process for administering questions to Source Plasma donors (referred to as “donors”) to determine their eligibility to donate. We are using the term “eligibility” in this guidance to refer to the donor suitability requirements described in Title 21 Code of Federal Regulations 640.63 (21 CFR 640.63). Acceptable SPDHQ documents are those documents that FDA has determined will provide Source Plasma manufacturers with one means of obtaining donor history information from a Source Plasma donor to determine if the donor is eligible consistent with the requirements in 21 CFR 640.63.
This guidance also advises Source Plasma manufacturers who choose to implement the acceptable SPDHQ documents on how to report the manufacturing change consisting of the implementation of the SPDHQ under 21 CFR 601.12 (§ 601.12).

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EMA Publishes Concept Paper on Process Validation in Protein Products

EMA Publishes Concept Paper on Process Validation in Protein Products

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This concept paper addresses the need to develop guidance on process validation of biotechnology derived active substances.

Guidelines related to the quality of Biotechnological/Biological products have been developed at the EU level, and several documents have been harmonised through the ICH process. However, these documents do not satisfactorily address the specific aspects of validation and evaluation for biotechnology derived products.

Validation and evaluation are essential concepts when setting the manufacturing process steps of biotechnology derived products. The evaluation/validation data provide essential information on the reproducibility and robustness of the process steps and are an important element to guarantee consistency in the quality of the product. The data encompass studies that are performed on product and process steps representative of the commercial process and may cover a wide range of situations and experiments (e.g. full scale, pilot scale, laboratory scale, scaled-down), depending on the objectives of the evaluation/validation studies carried out during development (e.g. consistency, viral safety evaluation, process-related impurity clearance).
The currently approved guidelines address the control of Biotechnological/Biological products (i.e. ICH Q6B on specification and ICH Q5C on stability), and/or some specific issues or aspects of the process (i.e. ICH Q5A on viral safety, ICH Q5B on genetic stability, ICH Q5D on cell substrates and ICH Q5E on comparability). ICH Q11, currently under development, is aimed at addressing the description, development, control strategy and process evaluation/validation of active substances of biotechnological and chemical origins. Although ICH Q5 and ICH Q11 documents address several important aspects or concepts relating to the evaluation/validation for medicinal products containing biotechnology derived proteins as active substance, as illustrated above there is no guidance to cover other aspects such as process- and product-related impurity clearance (e.g. host cell proteins, DNA), column/membrane sanitization and life time, hold time, reprocessing, pooling of intermediates and selection of batches to be included in evaluation/validation studies. All these elements do contribute to a good understanding of the process and the resulting product, and are needed for the assessors at the time of evaluation of a marketing authorisation application.
It is well acknowledged that ICH Q8, Q9 and Q10 guidelines are progressively being implemented in the routine practice of manufacturers and marketing authorisation holders. However, whereas these guidelines provide a new approach on the management of quality and build up the quality at every step of the life cycle of a medicinal product, they do not provide practical recommendations on the necessary evaluation/validation studies to be filed on these specific aspects (new application or variations).

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FDA Publish Guidance on Safety Reporting Requirements for INDs and BA/BE Studies

FDA Publish Guidance on Safety Reporting Requirements for INDs and BA/BE Studies

This document provides guidance to sponsors and investigators on enforcement of FDA’s final rule, “Investigational New Drug Safety Reporting Requirements for Human Drug and Biological Products and Safety Reporting Requirements for Bioavailability and Bioequivalence Studies in Humans” (75 FR 59935, September 29, 2010). This guidance contains information regarding the Agency’s intent to exercise enforcement discretion regarding the reporting requirements in the final rule until September 28, 2011.

On September 29, 2010, FDA published a final rule “Investigational New Drug Safety Reporting Requirements for Human Drug and Biological Products and Safety Reporting Requirements for Bioavailability and Bioequivalence Studies in Humans” (75 FR 59935) and issued related draft guidance “Safety Reporting Requirements for INDs and BA/BE Studies” (75 FR 60129, Docket No. FDA-2010-D-0482). The final rule amended the investigational new drug (IND) safety reporting requirements under 21 CFR part 312 and added safety reporting requirements for persons conducting bioavailability (BA) and bioequivalence (BE) studies under 21 CFR part 320. The draft guidance contains definitions used for safety reporting, makes recommendations on when and how to submit a safety report, and provides advice on other safety reporting issues that have generated questions from sponsors and investigators.

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FDA Publish Guidance on Notification of Donor Deferral, Small Entity Compliance

FDA Publish Guidance on Notification of Donor Deferral, Small Entity Compliance

The Food and Drug Administration (FDA) has prepared this guidance in accordance with section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996 (Public Law 104-121). According to the Small Business Administration, a “small business” within the blood industry is an enterprise with $10 million in average annual receipts.1 This guidance is intended to help you, a small entity that collects blood or blood components for transfusion or for further manufacturing (blood or blood components), better understand and comply with the regulatory framework set forth in Title 21 Code of Federal Regulations 630.6 (21 CFR 630.6). This provision requires you to make reasonable attempts to notify donors, including autologous donors, that they are deferred based on the results of tests for evidence of infection with a communicable disease agent(s) as required by 21 CFR 610.41, or determined not to be suitable for donation due to failure to satisfy suitability criteria under 21 CFR 640.3 or 21 CFR 640.63. This provision also requires you to notify the referring physician of an autologous donor when the autologous donor is deferred based on tests for evidence of infection with a communicable disease agent(s).

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FDA Publish Guidance on Submission of Summary Bioequivalence Data for ANDAs

FDA Publish Guidance on Submission of Summary Bioequivalence Data for ANDAs

This guidance is intended to assist applicants who are submitting abbreviated new drug applications (ANDAs) in complying with FDA’s requirements for the submission of bioequivalence (BE) data. FDA’s final rule on “Requirements for Submission of Bioequivalence Data” (the BE data rule) requires an ANDA applicant to submit data from all BE studies the applicant conducts on a drug product formulation submitted for approval, including studies that do not demonstrate that the generic product meets the current bioequivalence criteria.2 All BE studies conducted on the same drug product formulation must be submitted to the Agency as either a complete study report or a summary report of the BE data.3 The amended regulations include a definition of same drug product formulation (section 320.1(g)).
This guidance provides information on the following subjects:
•Types of ANDA submissions covered by the BE data rule.
•Recommended format for summary reports of BE studies.
•Types of formulations the Agency considers to be the same drug product formulation for different dosage forms based on differences in composition.
This guidance does not address which formulations the Agency considers to be the same drug product formulation based on differences in methods of manufacture.

The guidance is applicable to BE studies conducted for ANDAs during both preapproval and postapproval periods.

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FDA Publish Guidance on Computer Crossmatch of Donor Cells

FDA Publish Guidance on Computer Crossmatch of Donor Cells

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“Computer crossmatch” is a process used to ensure that blood released for transfusion is compatible with the intended recipient.1 We, FDA, are issuing this guidance to assist you, blood establishments that perform compatibility testing using a computer crossmatch system to perform computerized matching of blood, consistent with current good manufacturing practice (CGMP) requirements in 21 CFR Parts 210, 211 and 606. Blood establishments must have standard operating procedures (SOPs) “to demonstrate incompatibility between the donor’s cell type and the recipient’s serum or plasma type” under the compatibility testing requirements in
21 CFR 606.151(c). This guidance describes practices that we believe satisfy the requirements in 21 CFR 606.151(c) to help ensure detection of an incompatible crossmatch when using a computerized system for matching a donor’s cell type with a recipient’s serum or plasma type.
Recipient – donor compatibility may be evaluated by using either a serologic crossmatch or a computer crossmatch. We consider computer crossmatch an acceptable method of compatibility analysis when it is properly designed, validated, implemented, and monitored. However, the use of the computer crossmatch requires a high degree of testing and validation to ensure accuracy.
In addition, this guidance contains recommendations for blood establishments performing compatibility testing that intend to implement a computer crossmatch procedure. For licensed establishments, this guidance also describes how to report this manufacturing change to FDA under 21 CFR 601.12. This guidance finalizes the draft guidance entitled “Guidance for Industry: ‘Computer Crossmatch’ (Electronic Based Testing for the Compatibility between the Donor’s Cell Type and the Recipient’s Serum or Plasma Type)” dated June 2007 (June 21, 2007, 72 FR 34259).

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EMA Procedural Advice on Combination Advanced Therapy Medicinal Products (ATMPs)

EMA Procedural Advice on Combination Advanced Therapy Medicinal Products (ATMPs)

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Advanced Therapy Medicinal Products (ATMPs) are medicinal products for human use, including gene therapy, somatic cell therapy and tissue engineered products.ATMPs may incorporate, as an integral part of the product, one or more medical devices, in which case they are referred to as “Combined ATMPs” as defined in Article 2 of the Regulation (EC) No 1394/2007 on Advanced Therapy Medicinal Products .
ATMPs offer new treatment opportunities for diseases and injuries of the human body. The regulatory framework established by the new legislation on ATMPs is designed to ensure the free movement of these medicines within the European Union (EU), to facilitate their access to the EU market, and to foster the competitiveness of European pharmaceutical and medical technology companies in the field, while guaranteeing the highest level of health protection for patients.
All ATMPs are evaluated via the centralised procedure as defined in Article 8 of Regulation (EC) No 1394/2007, thus ensuring that they benefit from a single evaluation and authorisation procedure applicable across the EU. This makes it easier for companies to market their products and for patients in the different Member States to gain access to these products.
The Committee for Advanced Therapies (CAT) following its evaluation, drafts an opinion on the quality, safety and efficacy of each ATMP subject to marketing authorisation application (MAA). This opinion is then sent to the Committee for Medicinal Products for Human Use (CHMP), the committee responsible for human medicines at the European Medicines Agency (EMA). Based on the CAT opinion, the CHMP adopts a recommendation on the granting, variation, suspension or revocation of a marketing authorisation. The recommendation is then sent to the European Commission for a decision binding in all Member States. Such evaluation is done in line with the “Procedural Advice on the Evaluation of Advanced Therapy Medicinal Product in accordance with Article 8 of Regulation (EC) No 1394/2007” (EMEA/630043/2008) published in EMA website:

Regulation (EC) No 1394/2007 states that ATMPs may incorporate medical devices or active implantable medical devices as defined in Directive 93/42/EEC and 90/385/EEC respectively. In order to ensure an appropriate level of quality and safety, those devices should meet the essential requirements laid down in the relevant Directive. A Notified Body (NB) for medical devices may be or may have been involved in the assessment of the medical device part of a combined ATMP. As the CAT prepares the draft opinion on a combined ATMP, it will therefore be this Committee who primarily interacts with a NB in the context of the procedure described in this document.
Further information on various scenarios for the provision of NB assessments is provided in section 4 of this document.

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EMA Concept Paper on Potency Declaration / Labelling for Modified Biologicals

EMA Concept Paper on Potency Declaration / Labelling for Modified Biologicals

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There is an increasing interest of Industry to develop new biopharmaceuticals based on modifications of established protein therapeutics with the aim to alter the in vivo properties of these products. The introduced modifications could be a removal or replacement of one, or a few, amino acids in the molecule, which is achieved by modification of the gene, or by chemical modifications such as conjugation to a carrier molecule (e.g. pegylation) applied after biosynthesis of the protein. Some of these modified products have already entered the market, many more are in clinical development. Well known examples of modified products are insulin analogues and pegylated (PEG) proteins. EMA guidance documents related to aspects of potency labelling and declaration of composition for these classes of compounds have been published (ref 1, 2). Currently, more representatives for PEG modified biopharmaceuticals are under development, e.g. pegylated coagulation factors. The issue of calibration / standardisation and labelling of such products has been the subject of a number of Scientific Advices given by CHMP. Modified products could be considered as analoguous to the “parent” products in particular when they are intended for the same therapeutic indication and are given the same activity unitage as their parent counterpart, leading to potential confusion and misinterpretation in the dosing in daily practice. Thorough consideration should be given to the expression of strength of modified products in units of activity. Modified products will likely have similar responses as their “parent” compounds in in vitro biological assays for potency assignment, where the structural modification(s) do not modify the interaction between the test molecule and the effector. Nevertheless, units thus assigned in vitro may correlate differently with the clinical activity for the modified and the parent compound, particularly if the modification has changed the pharmacokinetic profile. This concept paper aims to provide the rationale for drafting a guidance document for potency assignment of modified proteins for which an International Standard exists or where a clinical recognised unit exists (without an International Standard established) for the non-modified product. It should be noted that the terminology “modified proteins”, used throughout this concept paper, refers to proteins which are modified in any way (e.g. pegylated or amino acid modifications) in order to alter the in vivo properties of these molecules. The terminology “parent product” refers to the non modified protein which the modified protein is derived from and for which the first (International) Unitage has been established.

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