Mauricio Sampaio
★    

Brazil,
2015-01-04 19:47
(3396 d 12:59 ago)

Posting: # 14214
Views: 5,166
 

 Recommendations to Brinzolamide from FDA [Design Issues]

Recently the FDA published nonbinding recommendations to ophthalmic products like Brinzolamide (http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM384099.pdf) and suggest bioequivalence study with Clinical Endpoint. On the other hand to Prednisolone acetate suspension drops the recommendations are bioequivalence study with pharmacokinetic endpoints in appropriate biological fluid like aqueous humor (http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM384160.pdf).

Is possible a study to Brinzolamide with pharmacokinetic endpoint or the fact that Brinzolamide is a carbonic anhydrase inhibitor decreases aqueous humor secretion is the reason to this impossibility ?
ElMaestro
★★★

Denmark,
2015-01-04 23:51
(3396 d 08:55 ago)

@ Mauricio Sampaio
Posting: # 14215
Views: 4,350
 

 Recommendations to Brinzolamide from FDA

Hi Mauricio,

❝ Is possible a study to Brinzolamide with pharmacokinetic endpoint or the fact that Brinzolamide is a carbonic anhydrase inhibitor decreases aqueous humor secretion is the reason to this impossibility ?


You're right PK may be a viable possibility. It is true that B. will decrease the aqueous humour and thus the measured concentration is in a sense a complex PD-endpoint as well as a PK-endpoint. But hey, if two products are bioequivalent thenthe phenomenon should affect both formulations equally and you'll be OK.
But i think the real reason for the difference in endpoint choice for Prednisolone and Brinzolamide is associated to a well-founded regulatory concern for the trial subjects; it isn't great fun for a trial subject when someone pokes a needle into her/his eye to drain some fluid every now and then. After period 1 when the PI says "Thank you, Mr Jones, for allowing us to mutilate your right eye today. Next week we'll have great fun with the left eye.", Mr Jones might be slightly inclined to withdraw his consent and run for the hills (actually he might not even do it in that order).
So when a noninvasive endpoint method is available, like intraocular pressure for Brinzolamide then by all means that's what you want to do. For Prednisolone there is no PD-endpoint, at least no well-defined and validated one, to the best of my knowledge. If there were I am quite certain FDA's guidance would change.

Pass or fail!
ElMaestro
Mauricio Sampaio
★    

Brazil,
2015-01-06 21:34
(3394 d 11:12 ago)

@ ElMaestro
Posting: # 14229
Views: 4,261
 

 Recommendations to Brinzolamide and Nepafenac from FDA

Thank you ElMaestro. I share of your position.

There is a same situation to Nepafenac 0,1% and 0,3%. The FDA suggest bioequivalence studies with clinical endpoints, however there are data that indicating low plasma concentrations, but quantifiable, of nepafenac and amfenac observed in most individuals 2 and 3 hours post dose, respectively, after bilateral ocular topical dose 3 times per day nepafenac ophthalmic suspension 0.1%. Therefore, if there are levels measurable in human plasm a pharmacokinetic approach could be applied. I could be wrong, but I do not understand the reason for option clinical. If you or anybody else can explain, I really appreciate!

Regards!
ElMaestro
★★★

Denmark,
2015-01-06 23:00
(3394 d 09:46 ago)

@ Mauricio Sampaio
Posting: # 14230
Views: 4,132
 

 Recommendations to Brinzolamide and Nepafenac from FDA

Hi again, Mauricio,

❝ Therefore, if there are levels measurable in human plasm a pharmacokinetic approach could be applied. I could be wrong, but I do not understand the reason for option clinical. If you or anybody else can explain, I really appreciate!


I share your views to a large extent.
If two products give rise to the same concentrations in the eye,
and
if the effect (safety) is directly a function of the eye concentration
and
if the drug is absorbed from the eye to the blood stream with quantifiable levels

then a comparative PK study would likely be ok scientifically speaking.

We have the same situation for inhaled asthma drugs (substitute eye for lung and the rest is the same). It took FDA more than 15 years to give green light for PK as a safety tool but for effect a PD-trial is still needed. It is extremely controversial, and there have been a million conferences about the topic. It all goes pear-shaped when the originator (who is afraid of generic competition and willing to do everything to stop it) starts arguing that blood levels are not indicative of effect and despite much effort to find consensus this is just an uphill struggle. Internally at agencies it is a very big hurdle for medical doctors, specialists in their field, to start thinking about PK in stead of PD. They just don't like it. Communication does not seem to be the solution.
:pirate:

Pass or fail!
ElMaestro
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