Apotex Petitions to Hold Neulasta Biosimilars to Higher Approval Bar
Apotex has petitioned FDA to impose stricter requirements for applicants seeking approval for a biosimilar product referencing Amgen’s Neulasta (pegfilgrastim). The petition wants applicants to “conduct their comparative clinical efficacy studies (including pharmacokinetics (PK) and pharmacodynamics (PD) studies and immunogenicity studies) in at least one intended patient population.” Apotex maintains that comparative clinical studies administering pegfilgrastim alone would not demonstrate “no clinically meaningful differences” between a proposed biosimilar and Neulasta for one of the indications for Neulasta.
“To the extent that FDA accepts a clinical study design only in healthy subjects, FDA should require such biosimilar applicants to demonstrate that there is a correlation in ANC [absolute neutrophil counts] activity and a reduced incidence of infection over the duration of exposure to pegfilgrastim in the indicated patient population,” Apotex says. “This is because the literature demonstrates that cancer chemotherapy patients process pegfilgrastim more slowly and are exposed to pegfilgrastim for much longer than healthy subjects, thus undermining the conclusion that the comparison does not reveal clinically meaningful differences in the intended patient population.” Apotex also asks FDA to require that biosimilar applicants conduct immunogenicity studies over at least four and preferably six cycles, which reflects a typical initial chemotherapy course.