FDA Denies Belbuca Petition

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FDA has denied a 10/21/21 petition submitted by BioDelivery Sciences International, Raleigh, NC, asking the agency to take certain actions on applications for follow-on buprenorphine buccal film products. Specifically, the petition asked that the agency: 

  •          require any applicant for a low or high pH buprenorphine buccal film product citing BioDelivery’s Belbuca (buprenorphine buccal film) as the reference-listed drug to include in the application adequate safety data, including data from the relevant patient population, from a comparative clinical investigation using relevant safety endpoints;
  •          refuse to approve an ANDA and require submission of a 505(b)(2) NDA to the extent that FDA determines that other than “limited confirmatory testing” evidence is needed to address pH safety concerns; and
  •          revise the agency’s product-specific bioequivalence guidance for generic Belbuca and issue guidance for the approval of oral mucoadhesive films that address the pH concerns discussed in the petition.

The FDA 3/18 denial letter says the BioDelivery petition (1) did not provide any scientific support for its assertion that follow-on products with a different pH range than Belbuca’s will result in local irritation or changes in bioavailability due to local irritation; (2) did not demonstrate that studies of temperature and pH of liquids are necessary; and (3) did not demonstrate that the draft buprenorphine hydrochloride buccal film product-specific guidance should be revised or that guidance for oral mucoadhesive films to address pH concerns is necessary.

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