GPhA Urges Denial of AbbVie Petition on Interchangeability

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The Generic Pharmaceutical Association (GPhA) says that FDA should deny a 12/16/15 AbbVie petition asking the agency to require specific criteria before designating any product as an interchangeable biologic. AbbVie had called on FDA to require:

that interchangeability be established in each condition of use for which the reference product is licensed, regardless of whether the applicant intends to label its product for every such condition of use;

clarification that the statutory standards for interchangeability differ in both kind and scope from the standard for establishing biosimilarity; and

convening a Part 15 hearing to obtain public input on the topic and only subsequently issue guidance or regulations addressing interchangeability.



In comments submitted in opposition to the petition, GPhA argues that AbbVie’s petition “seeks to impede the development and approval of interchangeable biological products by asking FDA to impose overly-stringent, standards to establish interchangeability that are neither required by the statutory language nor justified by sound science.” The group says that granting the petition’s requests would lead to significant disincentives to the development of interchangeable biologics and “impair patient access to affordable alternatives to brand name biologics, contrary to Congressional intent.” Additionally, GPhA says that convening a Part 15 meeting is unnecessary and would delay issuance of guidance on interchangeability until after this meeting so that feedback from the meeting could be considered.

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