kumar
☆    

2009-04-25 15:14
(6276 d 07:21 ago)

Posting: # 3611
Views: 6,973
 

 BE Studies for OTC-drug [Regulatives / Guidelines]

I am working on a simple old molecule that used to be a common household remedy for common ailments and was no more than an OTC drug for more than 80 years. Lot of literature is available for that old indication. Not used much now for that particular indication because of the availability of newer and better molecules. But now it has found a new indication at a lower / or same dose orally and can be used in extreme emergency / life threatening toxicity conditions only for 10-14 days and is not of the category of daily use. I am working for that new indication and intend to market it in EU.

There is a scarcity of clinical trial data on its safety and efficacy for new indication as it is difficult to carry out the clinical trials as the emergency / toxicity conditions for which it is used do not happen daily and it is difficult to simulate such conditions as well. Most of the information available is because of its past use in such circumstances by coincidence.

I would like to know is it necessary to conduct the BE for this drug with new indication? How can I demonstrate its BA / Bio- Equivalence to the reference product already marketed in EU and USA?

Can some learned members help me in this case?

Regards

Kumar

--
Edit: Subject line changed. Helmut
ElMaestro
★★★

Denmark,
2009-04-25 16:32
(6276 d 06:03 ago)

@ kumar
Posting: # 3612
Views: 6,039
 

 BE Studies for OTC-drug

Hi Kumar,

I am not sure I can follow you so well here: is there a product authorised in the EU which has this new emergency indication?
If this is the case then
1. a straightforward BE study should do it, provided the drug is not locally acting or some other obscure phenomenon.
2. there will be an SPC somewhere where you can learn some basic things about the drug, which may be helpful for the design of the trial intended to evaluate BE.

Best regards
EM.
kumar
☆    

2009-04-25 16:58
(6276 d 05:37 ago)

@ ElMaestro
Posting: # 3613
Views: 6,071
 

 BE Studies for OTC-drug

Dear EM,

Thank you for the mail. This product is already authorised in EU & USA as an innovator. The drug is not locally acting. We have seen the SPC and is not of much help. As a generic product, we need to demonstrate its BE with the innovator. We do not have much bibliographic reference to ask for a waiver? We do not know in what way we can conduct clinical trials and BE Studies.
Need help.

Regards
Kumar

--
Edit: Full quote removed. Please delete anything from the text of the original poster which is not necessary in understanding your answer; see also this post! Helmut
Helmut
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Vienna, Austria,
2009-04-25 17:34
(6276 d 05:01 ago)

@ kumar
Posting: # 3614
Views: 6,297
 

 No full quotes, please!

Dear Kumar,

when answering messages, please delete anything from the text of the original message which is not necessary in understanding your answer; see also this post and the Forum's Policy.

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kumar
☆    

2009-04-27 09:52
(6274 d 12:42 ago)

@ Helmut
Posting: # 3616
Views: 5,984
 

 No full quotes, please!

Dear Helmut,

My apologies and thanks for reminding me. However, I felt that the original text message should not appear by default when we click the reply button !!!! Trust you concur.

Regards
Kumar
Helmut
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Vienna, Austria,
2009-04-27 15:46
(6274 d 06:48 ago)

@ kumar
Posting: # 3621
Views: 6,146
 

 Off topic: Full quote

Dear Kumar!

❝ [...] I felt that the original text message should not appear by default when we click the reply button !!!! Trust you concur.


The administrative team of the forum had a discussion two weeks ago about your suggestion. We edited 8.3% of posts in the last year to remove 'Full quotes'.
Our decision was:
  • Post a follow-up additionally to the 'Edit:...' message in the original message because we felt that users probably don't read their original post again.
  • The link on top of the message area

    Please! Avoid full quotes (TOFU) and delete non required quoted text! --> delete text completely (JavaScript)

    is not working if JavaScript is disabled. This may be the case due to some companies' IT policies. Instructions to delete the entire text without JavaScript are given in this post and the Forum's Policy.
  • We rejected the option of not giving the original message by default. Right now users don't find the link on top of the message area; we assumed that they will not find any link to restore the quote as well. Additionally to JavaScript server-side scripting would have to be implemented (the text is not available at the client's side and has to be queried from the SQL-database).
    We were afraid that with empty quotes something like this would happen: A user is referring to a statement of the previous post which is visible only above (in mix view) or even worse just as a link (in thread view) - and not as a quote. Misunderstandings or even conflicts may arise, which simply bothers all readers. This is not impossible with quotes, but we considered the probability to be much lower.

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kumar
☆    

2009-04-27 17:18
(6274 d 05:17 ago)

@ Helmut
Posting: # 3622
Views: 5,961
 

 Off topic: Full quote

Dear Helmut,

Thank you for the mail. I have arguments both in favour and against. I feel that once a person reads a messsage and then feels strongly to reply to that and clicks on the "reply" button, his mind is still fresh with the original message and is working inside the mind what to reply !!!!! However, in case of a lengthy message, when one has to reply formally point wise, then one needs to refer back to the original message.

I feel that very few people read the terms and conditions fully in such sites including the sites like yahoo. msn or gmail when one signs for the first time; unless and until there is some indication of a "price / cost" factor. Trust you concur. I admit, I was one of those people.

My best regards,

Kumar
Helmut
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2009-04-27 18:00
(6274 d 04:34 ago)

@ kumar
Posting: # 3623
Views: 6,041
 

 Off topic: Full quote

Dear Kumar!

❝ I feel that once a person reads a messsage and then feels strongly to reply to that and clicks on the "reply" button, his mind is still fresh with the original message and is working inside the mind what to reply !!!!!


[image]sss !!!!! Are you suffering from blocked keys? :-D
I believe that your mind may be fresh, but any forum lives from the public exchange of opinions (that’s where the word comes from). It’s cumbersome for other readers to follow a chain of arguments if they are not visible. Only in ‘Mix view’-mode of the forum the previous post is displayed in the same webpage. Although this mode is the Forum’s default, users may set the ‘Thread view’ in their profile as well. In such a case only the subject line of the original post is displayed.

❝ However, in case of a lengthy message, when one has to reply formally point wise, then one needs to refer back to the original message.


Agree.

❝ I feel that very few people read the terms and conditions fully in such sites including the sites like yahoo. msn or gmail when one signs for the first time; unless and until there is some indication of a "price / cost" factor.


Fine. During the registration procedure a message is displayed in bold:

By the registration I confirm that I have read and accepted the Policy of the Forum.

I’m running this site at my costs; so please accept my rules. Furthermore all people answering questions do so in their leisure time.
If you want to discuss this topic further, please open a new thread in the
Forum Internals category.
This category is open for registered users only and is not displayed in public.

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kumar
☆    

2009-04-27 09:58
(6274 d 12:37 ago)

@ Helmut
Posting: # 3617
Views: 5,997
 

 BE Studies for OTC-drug

Dear Helmut

I just noticed that you changed the subject line of my mail; and it was too late to be edited by me !!!!

The drug in question was an OTC for earlier indication. But for the new indication it has to be taken on the advise of the Physician only.


Regards,

Kumar
Helmut
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2009-04-27 13:55
(6274 d 08:39 ago)

@ kumar
Posting: # 3620
Views: 6,131
 

 Off topic: Subject line

Dear Kumar!

❝ I just noticed that you changed the subject line of my mail; and it was too late to be edited by me !!!!


OK, but you could have changed the subject lines of your later posts if you felt the one I have chosen not to be adequate. I considered the one you originally gave (‘BE Studies’) rather uninformative. To quote the Forum's Policy:

Give a short description of your question in the subject line; try to be as specific as possible (something like ‘HELP!!!’ or ‘BE statistics?’ is just not a good idea).


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ElMaestro
★★★

Denmark,
2009-04-26 00:43
(6275 d 21:52 ago)

@ kumar
Posting: # 3615
Views: 6,080
 

 BE Studies for OTC-drug

Hi Kumar,

❝ We have seen the SPC and is not of much help.


OK, but I think in the absence of a drug name and some more info from your side your chances are slim that someone here is able to help you design the right trial.
As for bibliographical/biowaiver I think this will not work. If I get you right, the new indication is... well... new, which suggests it does not have "well-established use". So, I think it would be a good idea that you describe the drug better here and hope somebody knows the details you need, or you conduct a pilot in order to get at least some basic idea about the PK characteristics incl. intra- and inter-subject variability.

EM.
kumar
☆    

2009-04-27 10:14
(6274 d 12:21 ago)

@ ElMaestro
Posting: # 3618
Views: 5,983
 

 BE for new indication under POM category of an OTC-drug

Dear EM,

Thank you for the reply. I am afraid I can not disclose the name of the drug as I am bound by a non-disclosure agreement with the sponsor. As I told earlier, the drug is an old molecule. Hence, PK data is available in healthy individuals at "that" dose which is little higher than the "new dose".

But for the new indication, the clinical data is scarce. We have only 3 live reports of emergency conditions worldwide wherein this drug was used effectively by the Governments. And in one of the situations, a follow-up study was done post dosing to assess its side effects.

Best regards,

Kumar
ElMaestro
★★★

Denmark,
2009-04-27 20:44
(6274 d 01:50 ago)

@ kumar
Posting: # 3624
Views: 5,979
 

 BE for new indication under POM category of an OTC-drug

Dear Kumar,

❝ I am afraid I can not disclose the name of the drug (...)


Well, in the absence of a drug name and some information it is a little difficult to suggest anything.

❝ But for the new indication, the clinical data is scarce. We have only 3 live reports of emergency conditions worldwide wherein this drug was used effectively by the Governments.


Wow, silly me, I thought drugs were used by the medical profession. This drug is used by 'Governments'. Say no more, hush hush, or 'they' will come and get you. :cool:
Efficacy proven in three subjects? "4.1: Governocin is indicated for males aged 46-53 who choke on a pretzel while on board a Belgian schooner south of Equator". I bet the marketing people in the originator company do not have an easy job selling it. :crying:

You know what Kumar? You need a consultant, to whom you can disclose a bit more info, after which it will be much easier for you to receive useful feedback. I recommend you to contact Bebac (http://bebac.at). The owner is a competent fellow, so I've heard.

Best regards,
EM.
Helmut
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Vienna, Austria,
2009-04-27 22:34
(6274 d 00:01 ago)

@ ElMaestro
Posting: # 3625
Views: 6,028
 

 No CSI Miami

¡ ElMaestro !

❝ "4.1: Governocin is indicated for males aged 46-53 who choke on a pretzel while on board a Belgian schooner south of Equator".


Belgian schooner? Are you sure Governocin {:rotfl:} is not indicated on Dutch schooners only? I’ve heard about Belgian master brewers & chocolate-makers, but the Belgian seamanship, well… :vomit:

❝ I recommend you to contact Bebac (http://bebac.at). The owner is a competent fellow, so I've heard.


You’ve gotta be kidding!

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ElMaestro
★★★

Denmark,
2009-04-28 21:35
(6273 d 00:59 ago)

@ Helmut
Posting: # 3629
Views: 6,065
 

 No CSI Miami

¡ El consultor competente !

Belgian schooner? Are you sure Governocin {:rotfl:} is not indicated on Dutch schooners only? I've heard about Belgian master brewers & chocolate-makers, but the Belgian seamanship, well... :vomit:


I assure you there is nothing wrong with Belgian beer or with Belgian seamanship and there is absolutely nothing negative to say about the combination of the two.

EM.
Helmut
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Vienna, Austria,
2009-04-28 21:43
(6273 d 00:52 ago)

@ ElMaestro
Posting: # 3630
Views: 5,944
 

 Belgian seamanship

¡ ElMaestro !

❝ I assure you there is nothing wrong with Belgian beer


Yes, I know!

I like your proficiency in finding relevant facts in the net!

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kumar
☆    

2009-04-28 10:28
(6273 d 12:06 ago)

@ ElMaestro
Posting: # 3626
Views: 5,938
 

 BE for new indication under POM category of an OTC-drug

Dear EM,

Thank you for the mail and the advise....like it and could say a lot! But I think we have skidded off the track. With this limited information, can you or somebody suggest me if the BE is really necessary for this product or how can I ask for a waiver?

Regards
Kumar
Ohlbe
★★★

France,
2009-04-28 13:34
(6273 d 09:01 ago)

@ kumar
Posting: # 3627
Views: 5,997
 

 Clinical trials for new indication

Dear Kumar,

A BE trial will never give you a therapeutic indication that the reference product does not have.

If you want to get a new indication:
  • you can refer to the literature. In your case it seems this won't help, as there is no literature available to demonstrate a well-established use;
  • or you will have to run clinical trials.
If you can't refer to the literature, and can't run clinical trials, then you just can't get the new indication. It's as simple as that.

One suggestion if you decide to start a real development anyway: ask for orphan drug status.

Regards
Ohlbe
kumar
☆    

2009-04-29 14:42
(6272 d 07:52 ago)

@ Ohlbe
Posting: # 3634
Views: 5,897
 

 Clinical trials for new indication & Orphan status

Dear Ohlbe,

Thank you for the advise. Clinical trials in patients are difficult as such "accidental" conditions do not happen on daily basis and this drug is used prophylactically to prevent further damage, toxicity and death.

As regards the Orphan drug status, I am not sure because I thought this status is granted to drugs used in diseases affecting no more than 5 in 10000 people. And our drug will be used by masses or the whole population, if required.

Regards
Kumar
Ohlbe
★★★

France,
2009-04-29 15:53
(6272 d 06:42 ago)

@ kumar
Posting: # 3635
Views: 5,799
 

 Clinical trials !

Dear Kumar,

❝ Clinical trials in patients are difficult as such "accidental" conditions do not happen on daily basis and this drug is used prophylactically to prevent further damage, toxicity and death.


❝ And our drug will be used by masses or the whole population, if required.


You will never get an indication for primary prevention of whatever disease with an administration possibly to the whole population, just based on the description of 3 cases in the literature !

When statins requested an indication for primary prevention of myocard infarction in patients with high cholesterol, they had to run trials in thousands (or even tens of thousands) of patients, to get enough events.

Unless of course you are dealing with a disease which is not supposed to happen naturally at all... But then you need to discuss with the Ministry of Defense, not of Health :-|

Regards
Ohlbe
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