jag009
★★★

NJ,
2012-03-14 17:57
(5219 d 07:46 ago)

Posting: # 8275
Views: 5,735
 

 BA/BE on Prodrug [Regulatives / Guidelines]

Gentleman,

Could you please provide guidance on ANDA criteria for a prodrug on the following scenario?

For prodrugs, BE assessment will be made based on the active metabolite because the levels of the prodrug is too low, yes? What if for a drug product both a fasting and a fed study is needed and the prodrug levels in the fed study is measurable.

Thanks
drgunasakaran1
★★  
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2012-03-16 07:24
(5217 d 18:19 ago)

@ jag009
Posting: # 8282
Views: 5,091
 

 BA/BE on Prodrug

Dear Mr.Jag,

As per Canadian BE guidance “Conduct and Analysis of Comparative Bioavailability studies”, a pro-drug is to be treated as a 'parent drug'. That is, if the substance released from the dosage form is absorbed intact and is reliably measurable in the systemic circulation, it should be used in the assessment of Bioequivalence.

Fasting state:
Bioequivalence estimation of the active metabolite of the prodrug is allowed if
  1. Concentration of the prodrug cannot be reliably measured
  2. Pro-drug is not detectable due to rapid biotransformation
Fed state:
If the prodrug levels are measurable in the fed state, you need to analyse Prodrug for bioequivalence estimation.
However, quantification of its metabolite levels may sometimes be helpful, e.g., to explain extreme values caused by metabolic changes within a subject. In the above case, bioequivalence estimation will be based both on the Pro-drug and its metabolite.

Dr Gunasakaran Sambandan MD
Disclaimer: The replies/posts are my personal opinions, and they do not represent my company's views on the same. LinkedIn
Helmut
★★★
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Homepage
Vienna, Austria,
2012-03-16 13:27
(5217 d 12:15 ago)

@ drgunasakaran1
Posting: # 8283
Views: 5,387
 

 Prodrug (FDA)

Dear Gunasakaran & John!

❝ As per Canadian BE guidance […]



Since John mentioned the term “ANDA” in his/her post I guess we should refer to FDA’s practice – which is inconsistent. The prodrug should be targeted whenever possible. If we have a look at product-specific guidances, we find different cases, e.g.,Supportive data are: Individual and mean concentrations, individual and mean PK metrics, geometric means and ratios of means for AUC and Cmax.

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jag009
★★★

NJ,
2012-03-16 21:05
(5217 d 04:38 ago)

@ Helmut
Posting: # 8288
Views: 5,060
 

 Prodrug (FDA)

Thanks Gunasakaran & Helmut,

Here is the issue,

The immediate release innovator I am looking at is to be given with meal (as per product monograph) due to it's higher bioavailability. FDA does not have a guidance on whether both fast and fed studies are needed (none on their website). The parent compound is a prodrug with little or no detectable concentrations under fasting (because it's rapidly converted into the active metabolite form); The active metabolite has high concentrations. When given under fed conditions, both compounds increase in concentrations and are detectable.

Do I need to do both fasting and fed studies for an ANDA? If so, does that mean for the fasting ANDA study I need to demonstrate equivalence based on the active metabolite since parent prodrug is mostly BLQ? And for the fed study then I will need to demonstrate equivalence based on the parent drug (prodrug) since it's measurable?

Thank you.

Jag
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