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Compliance ★ India, 2013-07-05 15:29 (4737 d 05:07 ago) Posting: # 10943 Views: 8,287 |
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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 |
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Helmut ★★★ ![]() Vienna, Austria, 2013-07-05 16:15 (4737 d 04:21 ago) @ Compliance Posting: # 10944 Views: 7,774 |
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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:
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. — Dif-tor heh smusma 🖖🏼 Довге життя Україна! ![]() Helmut Schütz ![]() The quality of responses received is directly proportional to the quality of the question asked. 🚮 Science Quotes |
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Compliance ★ India, 2013-07-06 08:32 (4736 d 12:04 ago) @ Helmut Posting: # 10950 Views: 7,406 |
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❝ 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 |
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Helmut ★★★ ![]() Vienna, Austria, 2013-07-06 17:20 (4736 d 03:16 ago) @ Compliance Posting: # 10953 Views: 7,255 |
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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. — Dif-tor heh smusma 🖖🏼 Довге життя Україна! ![]() Helmut Schütz ![]() The quality of responses received is directly proportional to the quality of the question asked. 🚮 Science Quotes |
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jag009 ★★★ NJ, 2013-07-07 01:29 (4735 d 19:06 ago) @ Helmut Posting: # 10955 Views: 7,322 |
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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 |
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Helmut ★★★ ![]() Vienna, Austria, 2013-07-07 15:49 (4735 d 04:47 ago) @ jag009 Posting: # 10958 Views: 7,310 |
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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. — Dif-tor heh smusma 🖖🏼 Довге життя Україна! ![]() Helmut Schütz ![]() The quality of responses received is directly proportional to the quality of the question asked. 🚮 Science Quotes |
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jag009 ★★★ NJ, 2013-07-07 03:26 (4735 d 17:10 ago) @ Helmut Posting: # 10956 Views: 7,261 |
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❝ 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 |
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Helmut ★★★ ![]() Vienna, Austria, 2013-07-07 16:49 (4735 d 03:47 ago) @ jag009 Posting: # 10959 Views: 7,193 |
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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 ───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 (⅓ of 66)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. ![]() ![]() Since I’m guilty for almost ¼ of all posts – — Dif-tor heh smusma 🖖🏼 Довге життя Україна! ![]() Helmut Schütz ![]() The quality of responses received is directly proportional to the quality of the question asked. 🚮 Science Quotes |
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jag009 ★★★ NJ, 2013-07-07 01:22 (4735 d 19:14 ago) @ Compliance Posting: # 10954 Views: 7,265 |
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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 |
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luvblooms ★★ India, 2013-07-08 08:06 (4734 d 12:29 ago) @ jag009 Posting: # 10961 Views: 7,089 |
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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~ |
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Compliance ★ India, 2013-07-08 11:01 (4734 d 09:35 ago) @ luvblooms Posting: # 10964 Views: 7,192 |
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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 |
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jag009 ★★★ NJ, 2013-07-08 17:12 (4734 d 03:23 ago) @ luvblooms Posting: # 10965 Views: 7,134 |
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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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