Helmut
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Vienna, Austria,
2012-11-04 18:25
(4981 d 19:46 ago)

Posting: # 9500
Views: 3,823
 

 Tox studies before generic BE [Regulatives / Guidelines]

Dear all,

in two countries ([image] and – according to this post[image]) preclinical toxicity studies of the API are required before initiating a BE study for generic application. No idea about India, but in Russia two rodent species are required. I’m wondering what might be the scientific (!) rationale behind:
  • Tox studies have been successfully performed by the innovator. Otherwise the drug would not even have been allowed to enter the early stages of phase I (FIM in particular).
  • Animal models are models. The innovator’s product is on the market for 10+ years without serious toxicity issues (in the target species – not in a model); otherwise the product would have been withdrawn from the market.
  • Why is a generic company allowed to refer to human data of the innovator, but not to animal data?
Please enlighten me.

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Helmut Schütz
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drgunasakaran1
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2012-11-05 11:02
(4981 d 03:09 ago)

@ Helmut
Posting: # 9501
Views: 3,063
 

 Tox studies before generic BE

Dear Sir,

❝ No idea about India, but in Russia two rodent species are required. I’m wondering what might be the scientific (!) rationale behind:

Tox studies have been successfully performed by the innovator.


As per Indian CDSCO Guidance on "Documents to be submitted for grant of permission to conduct Bioequivalence studies for export purpose", Pre-clinical single dose data and repeated dose toxicity data are required only if the drug is a new molecule not approved in India but approved in the other countries.

Whereas, in the case of Injectable preparation, the sub-acute toxicity should be submitted on the product of the sponsor, generated in two species for adequate duration.

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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Vienna, Austria,
2012-11-05 13:04
(4981 d 01:07 ago)

@ drgunasakaran1
Posting: # 9502
Views: 3,070
 

 Yes, but why the heck?

Dear Dr. Gunasakaran,

THX, I knew this document (August 2009, right?). IMHO such a requirement is fucking crazy (as is the Russian one); the scientific rationale behind (see the first two remarks in my original post) is beyond my intellectual reach. I know that the development process of guidelines in India and Russia is not the most transparent one (to say it politely)…

Did anybody ever try to challenge it?

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ElMaestro
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Denmark,
2012-11-05 14:08
(4981 d 00:03 ago)

@ Helmut
Posting: # 9503
Views: 3,002
 

 Clearly because...

Hi Helmut,

I know from experience that if you ask a person who has a lot of innovator experience and zero BE experience to come up with a concept on how to show BE then the outcome will be
  1. Irrational for experienced BE people.
  2. Reflective of standard practices for innovator developments.
I have a feeling this phenomenon must be in play here.

Rather than banging your head into the wall you should just be grateful that you haven't been asked to include placebo arms or show equivalence on basis of Kaplan-Meier plots...





















...yet.

Pass or fail!
ElMaestro
drgunasakaran1
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2012-11-06 05:43
(4980 d 08:28 ago)

@ Helmut
Posting: # 9506
Views: 2,969
 

 Yes, but why the heck?

Dear Sir,

I fully agree with your views. CDSCO is requesting the literature of toxicity data of the Innovator or other generic drugs marketed in other countries, if it is available in the public domain only for new drugs not approved in India for granting permission to conduct BE studies in Indian population with such drugs.

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
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