ANDA Oligonucleotide Guides Needed: AAM
The Association for Accessible Medicines (AAM) says FDA should publish guidance for oligonucleotide product development for ANDAs, particularly for topics not included in product-specific guidances such as recommendations for immunogenicity and inflammation risk assessments and for demonstration of comparability of impurities. The request is included in AAM’s comments on an FDA draft guidance on nonclinical safety assessment of oligonucleotide-based therapeutics.
AAM says the guidances it seeks “would support early product development decisions for generic oligonucleotide products,” noting that its members have experienced challenges in obtaining clarity on the agency’s expectations for immunogenicity for peptides and would like to avoid such issues for the oligonucleotide class of drug products.
AAM also recommends that FDA:
- be forward-looking and consider recommendations for follow-on oligonucleotides developed with a drug substance of recombinant DNA origin;
- accept nonclinical immunogenicity assessments for such products; and
- harmonize with the European Medicines Agency on guidance on these topics to facilitate global product development and timely access for U.S. patients to affordable lower-cost generic products.