Melkor
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Greece,
2014-01-20 14:59
(4543 d 20:49 ago)

Posting: # 12203
Views: 6,319
 

 Biowaiver for low-strength (<5%) [Regulatives / Guidelines]

Dear all,

According to EMA's Bioequivalence Guideline (General Biowaiver Criteria), a BE study for a certain strength can be waived in the case (3rd requirement of the Guideline) i and ii or i and iii are fulfilled. Criteria i reads:

"i. The amount of the active substance is less than 5% of the tablet core weight."

My question is whether this is referred to the active substance in the base form or in a salt form. According to definitions, an active substance is the one that has the therapeutic effect (usually the base or an active metabolite) which most probably answers my question.

Any advice on this? :confused:

Thank you.
Helmut
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Vienna, Austria,
2014-01-20 15:24
(4543 d 20:23 ago)

@ Melkor
Posting: # 12204
Views: 5,531
 

 API = salt?

Hi Melkor,

❝ My question is whether this is referred to the active substance in the base form or in a salt form. According to definitions, an active substance is the one that has the therapeutic effect (usually the base or an active metabolite) which most probably answers my question.


Very good point! Throughout the GL “active substance” refers to the active core molecule (base, acid); that’s what we find in the systemic circulation. Section 1.2 states:

The different salts, esters, ethers*, isomers, mixtures of isomers, complexes or derivatives of an active substance are considered to be the same active substance, unless they differ signifi­cantly in properties with regard to safety and/or efficacy.

(my emphasis)
So when it comes to in vivo the case is clear. Not sure about salts, derivatives in the formulation… See this post of Jean-Michel.


  • Never understood why ethers are mentioned here. They are not cleaved in the GIT and absorbed intact. Can someone enlighten me?

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Melkor
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Greece,
2014-01-20 16:28
(4543 d 19:20 ago)

@ Helmut
Posting: # 12207
Views: 5,532
 

 API = salt?

Hi Helmut,

Thanks a lot for the prompt response. That was exactly what i was thinking about this issue. Nevertheless, something that is still unclear to this part of the biowaiver: Both formulations: bio-strength and waiver-strength have to have less than 5% of the active substance? :confused:

Thanks again ;-)
Ohlbe
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France,
2014-01-20 17:21
(4543 d 18:27 ago)

@ Melkor
Posting: # 12208
Views: 5,387
 

 5 %: both formulations

Dear Melkor,

I think the guideline is quite clear on this aspect:

If there is some deviation from quantitatively proportional composition, condition c is still considered fulfilled if condition i) and ii) or i) and iii) below apply to the strength used in the bioequivalence study and the strength(s) for which a waiver is considered
i. the amount of the active substance(s) is less than 5 % of the tablet core weight, the weight of the capsule content

My understanding is that both the formulation used in the BE trial and the formulation you want to waive should contain less than 5 % of "active substance", whatever that may be.

Regards
Ohlbe
Helmut
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Vienna, Austria,
2014-01-20 18:04
(4543 d 17:44 ago)

@ Ohlbe
Posting: # 12209
Views: 5,393
 

 5 %: both formulations

Hi Ohlbe,

❝ … to the strength used in the bioequivalence study and the strength(s) for which a waiver is considered


So, how is the strength defined? AFAIK, it’s the core molecule, not the salt.

❝ … less than 5 % of "active substance", whatever that may be.


Hey, that’s the crucial point. I would follow the argument in Jean-Michel’s extreme example. Therefore, IMHO the 5% should be based on the API seen from a galenic perspective (e.g., the salt), not the PK perspective (“active moiety”).

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Ohlbe
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France,
2014-01-20 18:32
(4543 d 17:15 ago)

@ Helmut
Posting: # 12210
Views: 5,375
 

 5 %: both formulations

Dear Helmut,

❝ I would follow the argument in Jean-Michel’s extreme example. Therefore, IMHO the 5% should be based on the API seen from a galenic perspective (e.g., the salt), not the PK perspective (“active moiety”).


I'm not a specialist - but I would agree. This is the most conservative approach, the most protective from the patients' point of view.

Regards
Ohlbe
Melkor
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Greece,
2014-01-22 13:34
(4541 d 22:13 ago)

@ Ohlbe
Posting: # 12226
Views: 5,354
 

 5 %: both formulations

Thank you both for your help and advice. Concerning the strengths that should follow the rule of 5%, indeed imo bio-strength must comply also with the rule. The main issue is salt of base but i agree that one should better follow the more conservative option.

Thank you again.
Helmut
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Vienna, Austria,
2014-01-23 01:54
(4541 d 09:53 ago)

@ Ohlbe
Posting: # 12234
Views: 5,417
 

 Active moiety

Hi Ohlbe,

❝ I'm not a specialist…


… nor am I. I found an interesting draft from the FDA: “Naming of Drug Products Con­tain­ing Salt Drug Substances”

Active moiety - The molecule or ion, excluding those appended portions of the molecule that cause the drug to be an ester,* salt (including a salt with hydrogen or coordination bonds), or other noncovalent derivative (such as a complex, chelate, or clathrate) of the molecule responsible for the physiological or pharma­co­logical action of the drug substance.


  • The USP has announced plans to revise the USP Salt Policy definition of an active moiety so that it will no longer include “esters.”

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kumarnaidu
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Mumbai, India,
2014-06-27 12:54
(4385 d 23:53 ago)

@ Helmut
Posting: # 13154
Views: 4,844
 

 Change of API and fate of biostudy

Hi all,
I have one passed BE study. After that if I change the source of API do we need to conduct a repeat BE study or earlier passed BE study will suffice.

Kumar Naidu
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