Compliance
★    

India,
2013-07-05 15:29
(4737 d 03:48 ago)

Posting: # 10943
Views: 8,286
 

 Submission in USA & Canada [Regulatives / Guidelines]

Dear All,

Is it possible to submit the same study conducted for USA in CANADA also? I have asked question for the reference product to be used for CANADA but unfortunately no one has replied me.

This time i am expecting your kind reply.

Regards,

Compliance
Helmut
★★★
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Vienna, Austria,
2013-07-05 16:15
(4737 d 03:02 ago)

@ Compliance
Posting: # 10944
Views: 7,773
 

 Canadian reference

Dear Compliance,

❝ Is it possible to submit the same study conducted for USA in CANADA also?


Possible? For sure. Will it be accepted? No way.
Do you know the Canadian section of the Guideline collection? See the Guidance Document: Conduct and Analysis of Comparative Bioavailability Studies:

For […] pivotal bioequivalence studies, the reference product should be the Canadian reference product as defined in Section C.08.001.1 of the Regulations:

  1. drug in respect of which a notice of compliance is issued pursuant to section C.08.004 [of the Regulations] and which is marketed in Canada by the innovator of the drug;
  2. drug, acceptable to the Minister, that can be used for the purpose of demonstrating bioequi­va­lence on the basis of pharmaceutical and, where applicable, bioavailability characteristics, where a drug in respect of which a notice of compliance has been issued pursuant to section C.08.004 [of the Regulations] cannot be used for that purpose because it is no longer marketed in Canada; or
  3. drug, acceptable to the Minister, that can be used for the purpose of demonstrating bioequi­va­lence on the basis of pharmaceutical and, where applicable, bioavailability characteristics, in comparison to a drug referred to in paragraph (a).

For further guidance see the Therapeutic Products Directorate policy document entitled Canadian Reference Product.


❝ I have asked question for the reference product to be used for CANADA but unfortunately no one has replied me.


Are you referring to this thread?

❝ This time i am expecting your kind reply.


Please note that members of the forum are posting in their free time; you should not expect an imme­di­ate answer (if any at all).
Please do your homework first (see also the sentence in my signature). Took me two minutes to locate Canada’s Drug Product Database.

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Compliance
★    

India,
2013-07-06 08:32
(4736 d 10:45 ago)

@ Helmut
Posting: # 10950
Views: 7,405
 

 Canadian reference

❝ Do you know the Canadian section of the Guideline collection?


I gone through it but after following the suggested section C.08.001.1, i could not get the require details.

❝ Please note that members of the forum are posting in their free time; you should not expect an immediate answer (if any at all).


I did't demand to give me the reply. just mentioned in the new post about my last post without and wrong intention.

❝ Please do your homework


Thank you for your suggestion but let me tell you i gone through the guidance page and unable to extract the information which i was looking for.
I think you are getting irritated and I am sorry for that.

Regards,

Compliance
Helmut
★★★
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Vienna, Austria,
2013-07-06 17:20
(4736 d 01:58 ago)

@ Compliance
Posting: # 10953
Views: 7,254
 

 Non-Canadian reference

Hi Compliance,

❝ I think you are getting irritated and I am sorry for that.


I was; already forgotten.

I have to modify my original response of “no way”. Actually there are some exceptions acceptable. See Canadian Reference Product ❝ Background.
If all applicable criteria are fulfilled, a foreign reference product may be used in a BE study for generic filing.

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jag009
★★★

NJ,
2013-07-07 01:29
(4735 d 17:48 ago)

@ Helmut
Posting: # 10955
Views: 7,321
 

 Non-Canadian reference

Hi Helmut!

❝ I have to modify my original response of “no way”. Actually there are some exceptions acceptable. See Canadian Reference Product ❝ Background.

❝ If all applicable criteria are fulfilled, a foreign reference product may be used in a BE study for generic filing.


Personally I think there is too much risk and time involved (what if you submit and they ultimately refuse). I rather spend some cash (for the extra arm) and run a three arm study to compare against references from both countries. This is assuming that you know the reference products from both countries are the same. Helmut, guru, correct me if I am wrong on this example ⇒ Procardia XL (USA) vs Adalat XL (CAN). I think they are the same product.

Note that Canadian ANDA requires potency correction BE analysis as well, US does not (but require potency difference between T and R to be within 5%).

John
Helmut
★★★
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Vienna, Austria,
2013-07-07 15:49
(4735 d 03:28 ago)

@ jag009
Posting: # 10958
Views: 7,309
 

 Non-Canadian reference

Hi John!

❝ Personally I think there is too much risk and time involved (what if you submit and they ultimately refuse). I rather spend some cash (for the extra arm) and run a three arm study to compare against references from both countries. This is assuming that you know the reference products from both countries are the same.


Me too. Actually I would rather run two separate 2×2 studies. A three-way might be OK if the patient populations are separated by >3000 miles of salt water. US and Canada are not that far away. What if you are BE to one reference and not to the other? Of course you submit just results of the relevant parts to each authority, but the file will contain all data. Regulators might be wary to approve a product taking the chance of failure in tourists switching products into account. ;-)

❝ Helmut, guru, correct me if I am wrong on this example ⇒ Procardia XL (USA) vs Adalat XL (CAN). I think they are the same product.


THX for calling me गुरु. No qualified opinion on these products. Would not be possible to use the US RLD in Canada anyway (failing the criteria; ≠ immediate release, first-pass >40%).

❝ Note that Canadian ANDA requires potency correction BE analysis as well, US does not (but require potency difference between T and R to be within 5%).


Generally not any more. TGD harmonized last year with FDA and (especially EMA):

The measured drug content of the lots of the test and reference products, used in the study (expressed as percent of the label claim) should be within 5% of each other. Certificates of analysis documenting potency should be generated within 6 months prior to the start of the study.
In exceptional cases where a reference batch with a measured drug content differing less than 5% from the test product cannot be found, potency correction may be accepted. If potency correction is to be used, this intention should be pre-specified in the protocol and justified. The results from the potency assay of the test and reference products should be submitted. In such cases, the applicable bioequivalence standards should be met on both potency-corrected and uncorrected data.


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jag009
★★★

NJ,
2013-07-07 03:26
(4735 d 15:51 ago)

@ Helmut
Posting: # 10956
Views: 7,260
 

 Canadian reference

❝ Please note that members of the forum are posting in their free time; you should not expect an immediate answer (if any at all).

❝ Please do your homework first (see also the sentence in my signature). Took me two minutes to locate Canada’s Drug Product Database.


Exactly, we are doing this for free :-)

Thanks to Helmut, I have learned many new things and corrected a lot of my old believes from all the contributors here.

John
Helmut
★★★
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Vienna, Austria,
2013-07-07 16:49
(4735 d 02:28 ago)

@ jag009
Posting: # 10959
Views: 7,192
 

 North American POVs / posting statistics

Hi John,

❝ Thanks to Helmut, I have learned many new things and corrected a lot of my old believes from all the contributors here.


Thanks to you we got some opinions about North-American practices straight from the horse’s mouth. Unfortunately you guys are in the minority here (US 2.84%, Canada 2.36%, Mexico 0.83%).
  571 (67.49%) India
  121 (14.30%) Europe (107 = 12.65% EEA)
   55 ( 6.50%) Asia (except India)
   51 ( 6.03%) North America
   22 ( 2.60%) Africa and Middle East
   14 ( 1.65%) Central and South America
   12 ( 1.42%) Oceania
  ───
  846

In the last months I deleted hundreds of members who never posted or didn’t show up for more than five years. There are fewer active members than the actual number suggest. Hence, nobody should expect an immediate response. How many regular posters do we have?
≥ 20 posts: 70 members (8.27% of 846) from 22 countries ( of 66)
≥ 50 posts: 17 members (2.01%) made 6296 posts (58.48% of all)
            44.28% (from Austria, 2 members), 16.09% (Germany 3), 11.69% (Denmark 1),
            8.97% (France 1), 5.84% (India 5), 4.83% (USA 1),
            3.57% (Taiwan 1), 2.70% (Spain 1), 1.03% (UK 1),
            0.98% (Romania 1)
≥100 posts: 10 members (1.18%) made 5892 posts (54.73% of all)
            47.32% (Austria 2), 16.33% (Germany 2), 12.49% (Denmark 1),
            9.59% (France 1), 5.16% (USA 1), 3.82% (Taiwan 1),
            2.89% (Spain 1), 2.41% (India 1)


94 members fall into my private category of “information sinks”: Only one post and never showing up again (not even to say “THX”).

In short: If you post here, chances are high that you’ll get a biased answer (गुरुओं opinions).
Science ≠ democracy. ;-)

[image]

Since I’m guilty for almost ¼ of all posts –
maybe I should exercise restraint. Will try.
मैं सभी पदों में से लगभग एक चौथाई के लिए दोषी हूँ -
शायद मैं संयम बरतने चाहिए. कोशिश करेंगे.

আমি সব পোস্ট এর প্রায় এক চতুর্থাংশ জন্য দোষী নই দেখাও -
হয়তো আমি যম ব্যায়াম করা উচিত. চেষ্টা করবে.

నేను అన్ని పోస్ట్స్ ని దాదాపు త్రైమాసికంలో నేరాన్ని రెడీ నుండి -
నేను నిగ్రహం వ్యాయామం చేయాలి. ప్రయత్నిస్తుంది.

मी सर्व पोस्ट जवळजवळ एक तिमाहीत दोषी am असल्याने -
मी संयम व्यायाम करावा. प्रयत्न करू.

நான் எல்லாம் கிட்டத்தட்ட ஒரு காலாண்டில் குற்றவாளி இல்லை என்பதால் -
ஒருவேளை நான் கட்டுப்பாடு பின்பற்ற வேண்டும். முயற்சிக்கும்.

میں نے تمام خطوط کے تقریبا ایک سہ ماہی کے لئے مجرم ہوں چونکہ
شاید میں سنیم چاہئے. کوشش کریں گے.

હું બધી પોસ્ટ્સ લગભગ એક ક્વાર્ટર માટે દોષિત છું ત્યારથી -
કદાચ હું સંયમ વ્યાયામ કરીશું. પ્રયત્ન કરશે.

ನಾನು ಎಲ್ಲಾ ಪೋಸ್ಟ್ಗಳನ್ನು ಸುಮಾರು ಒಂದು ತ್ರೈಮಾಸಿಕ ತಪ್ಪಿತಸ್ಥ ಮನುಷ್ಯ ನಂತರ -
ಬಹುಶಃ ನಾನು ಸಂಯಮ ವ್ಯಾಯಾಮ ಮಾಡಬೇಕು. ಪ್ರಯತ್ನಿಸುತ್ತೇವೆ.


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jag009
★★★

NJ,
2013-07-07 01:22
(4735 d 17:56 ago)

@ Compliance
Posting: # 10954
Views: 7,264
 

 Submission in USA & Canada

Hi,

❝ Is it possible to submit the same study conducted for USA in CANADA also? I have asked question for the reference product to be used for CANADA but unfortunately no one has replied me.


No. My previous company was specialized in ANDAs and 505b2 (controlled release). You cannot submit USA ANDA studies for Canadian submission or vice versa due to the reference product being different.

Even 505b2 we had to run BA (or BE) studies to compare against the reference from each country if we want to submit.

If you run a BE /BA study with three treatments (Test, US Reference, CAN reference) then I think you can do it. I did this kind of study before for a NDA / NDS submission in USA and CAN (actually 2 NDS submissions)

Hope this helps.

John
luvblooms
★★  

India,
2013-07-08 08:06
(4734 d 11:11 ago)

@ jag009
Posting: # 10961
Views: 7,088
 

 Submission in USA & Canada

Dear Jag and Others

Good Morning

I have an experience with one derma product where the clinical studies (PK and PD both) has been done using US innovator product and the same was submitted to Health Canada (along with the tests and data showing that both the reference i.e. US and Canada are same).

After a few basic question on the testing methodology and few suggestions the product got approved!


So yes, there is a risk but it could be done. ;-)


Hope this will help

Regards

~A happy Soul~
Compliance
★    

India,
2013-07-08 11:01
(4734 d 08:16 ago)

@ luvblooms
Posting: # 10964
Views: 7,191
 

 Submission in USA & Canada

To all,

Thank you very much for your reply. I found few links which give us direct access to the Canada Reference product. Site having some confusion (at least at my end).

Hope this link will be helpful.

http://www.hc-sc.gc.ca/dhp-mps/prodpharma/applic-demande/regist/reg_innov_dr-eng.php

Regards,

Compliance
jag009
★★★

NJ,
2013-07-08 17:12
(4734 d 02:05 ago)

@ luvblooms
Posting: # 10965
Views: 7,133
 

 Submission in USA & Canada

Hi Luvbloom,

❝ I have an experience with one derma product where the clinical studies (PK and PD both) has been done using US innovator product and the same was submitted to Health Canada (along with the tests and data showing that both the reference i.e. US and Canada are same).


❝ After a few basic question on the testing methodology and few suggestions the product got approved!


Same here, mine was a 3-way oral admin study for a 505(b)2 filing of a once daily ER vs innovator twice daily. We submitted both CAN and US reference data. No issue with TPD in Canada (or USA FDA). Product was approved.

John
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