relax [Regulatives / Guidelines]

posted by Helmut Homepage – Vienna, Austria, 2020-01-23 11:59 (451 d 21:16 ago) – Posting: # 21082
Views: 1,789

Hi Fabrice,

» » Doesn’t matter because we are interested in PK (I) and safety (II).
» OK but then how to justify in the dossier the extrapolation of some early phase outcomes, e.g. a food effect or an efficacy and/or safety exposure signal... should these key findings be evaluated/demonstrated again with the final formulation?

An example: The NDA of idelalisib. A lot of Phase I/II studies (women/men, Japanese/Caucasian, food effect, DDIs, renal/hepatic impairment) were performed in 6 (six!) to 12 subjects with early formulations.
There was also a study comparing formulations (n = 15, extremely underpowered for the x̃ CV of 29% in earlier studies). Some comparisons failed (e.g., 90% CI of Cmax 106–153%). Funny: What are the safety or efficacy issues, if any, for BE studies that fail to meet the 90% CI using equivalence limits of 80–125%?
None. The exposure for the different drug products is similar.

Quoting nobody: It’s originator, stupid!

Since idelalisib is in BCS II (where dissolution cannot predict in vivo performance), the FDA lamented about later manufacturing changes but accepted the package at the end of the day.

Dif-tor heh smusma 🖖
Helmut Schütz

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