Alcon Wants Specific Ciprodex BE Requirements

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Alcon is asking FDA to require only in vivo bioequivalence testing for ANDAs that cite its Ciprodex (ciprofloxacin 0.3% and dexamethasone 0.1%) sterile otic suspension as the reference-listed drug. It also asks that the agency revise its product-specific guidance on ciprofloxacin and dexamethasone.

Specifically, the petition calls on FDA to: 

  •          require any ANDA applicant citing Ciprodex as the reference-listed product to establish bioequivalence through in vivo clinical endpoint studies or, if the agency retains an in vitro option, through specific studies requested by Alcon;
  •          promptly issue a final version of its product-specific draft guidance consistent with the request for bioequivalence studies;
  •          confirm that ANDA applicants referencing Ciprodex may not rely on in vitro studies alone;
  •          confirm that an ANDA applicant proposing different pH adjusters than those for Ciprodex will not be eligible for approval;
  •          confirm that ANDA applicants cannot obtain approval if the proposed generic product contains a different exception excipient from Cirpodex and the applicant cannot demonstrate that the change does not affect the safety and/or efficacy of the proposed generic product; and
  •          refuse to permit an ANDA applicant to omit Ciprodex’ pediatric AOM (acute otitis media) indication from its labeling or deviate from Ciprodex’ prescribing information with respect to dosage and administration for use in AOM.

The petition says that a recently revised FDA draft guidance that allows an in vitro bioequivalence option departs from the agency’s historic practice for topical products such as otic suspensions and diverges from its original 2012 draft guidance.

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