FDA Denies Ipsen Somatuline Depot Petition
FDA has denied an Ipsen Pharmaceuticals 10/15/2019 petition asking that the agency take specific actions on any ANDA that references Ipsen’s Somatuline Depot (lanreotide acetate) subcutaneous solution. The FDA 5/21 response says Ipsen asked that FDA require:
- ANDA applicants referencing Somatuline Depot to demonstrate bioequivalence through an in vivo study capable of demonstrating that a proposed generic product causes lanreotide acetate to release into systemic circulation at the same rate and to the same extent as the reference-listed drug (RLD) for the dosing interval;
- ANDAs to include comparable impurity analysis on samples of finished drug products and control for peptide-related impurities to the same extent and same level as the RLD;
- ANDAs to include comparative performance testing of the delivery device to ensure it is equivalently functional and useable;
- ANDA sponsors to conduct a partial Area Under the Curve analysis as part of the in vivo bioequivalence study to ensure the generic is bioequivalent to the RLD over the required dosing interval; and
- FDA to reissue its 7/2014 product-specific draft guidance based on its action on the petition.
The FDA petition denial made these points:
- the petition failed to show that in vivo bioequivalence evidence is required;
- FDA will assess a proposed generic drug’s impurity profile at the time of review and determine if it is acceptable;
- FDA does not agree that all ANDAs referencing Somatuline Depot should be required to include comparative use human factors data;
- for multiple reasons, FDA does not agree that ANDA applicants for generic Somatuline Depot should be required to perform a partial Area Under the Curve analysis; and
- since the petition action requests are denied, there is no need to reissue the product-specific guidance.