FDA Nixes Additional Risk-based BE Testing Actions
FDA has denied in part a Therapeutic Proteins International petition asking that it take actions to advance the use of risk-based bioequivalence testing. To the extent that the petition asks the agency to undertake activities it is already doing, the letter says, it is granted.
The 2007 petition called on FDA to request comments on how modifications to dissolution testing can be used to substitute bioequivalence. It also said it wanted the agency to invite comments on the creation of novel dissolution systems that can be used to establish bioequivalence for all products where thermodynamic activity is feasible. FDA says it appeared that the petitioner thought such information was necessary to permit establishment of “risk-based bioequivalence testing.” The petition also said that risk-based testing is necessary because the protocols that have been used for bioequivalence testing are “based on assumptions that are no longer considered valid scientifically.”
The agency says it disagrees with the notion that the use of in vivo blood tests to establish bioequivalence is not scientifically valid. It also notes that for certain drug products, a traditional in vivo bioequivalence study comparing the rate and extent of absorption of the active ingredient into the bloodstream is of limited value. Thus, it says, publishing product-specific recommendations enables FDA to make recommendations about appropriate bioequivalence study designs on a case-by-case basis considering available information and provides the public with an opportunity to comment.
“We believe that the current system of publishing product-specific recommendations for generic drug development, in conjunction with our other efforts to obtain public input on and disseminate our current thinking on bioequivalence testing methodologies, is largely responsive to your request that we ‘open comment’ on novel dissolution tests that can be used to establish bioequivalence,” the letter concludes…. “Therefore your petition is granted to the extent that it asks us to open comment on novel dissolution tests that can be used to establish bioequivalence. To the extent that your petition asks us to undertake additional activities, it is denied.”