Antibody Impurity Guidance Needs Specificity: Comments

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The Association for Accessible Medicines (AAM) says an FDA draft guidance on establishing impurity specifications for antibiotics is very general and lacks specific recommendations for setting thresholds for impurities in the products covered by the guidance. In its comment letter, AAM contrasts the FDA draft with one from the European Medicines Agency (EMA) that it says has more specific guidance on acceptance criteria that includes thresholds for reporting, identification, and qualification for certain categories of active substances.

“As FDA is aware,” the letter says, “many drug development programs are global in nature, and consistency across health regulatory authorities is important to support efficient development of critical medicines that can be made available around the world to patients who need them.”

AAM says some of its members have observed that some FDA reviewers seem to be applying the thresholds in the EMA guideline during their reviews, although FDA has not announced its intention to do so, and other FDA reviewers may be taking a different approach.

“To avoid adverse impacts on products under development associated with changing expectations and inconsistent approaches during reviews, FDA should issue more detailed guidance describing its expectations for establishing thresholds for irregularities in these critical products,” AAM says.

The association also asks for clarification of the agency’s expectations about the application of the principles described in the draft to marketed products, applications under development, and applications currently pending before FDA.

In its comment, the Parenteral Drug Association urges FDA to harmonize the terminology in the guidance with that in the applicable International Council for Harmonization (ICH) guidelines. It says it recommends the use of “drug substance” rather than “active pharmaceutical ingredient” and alignment of the terms “degradation products” and “impurities” to the ICH definitions.

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