Law Firm Seeks Lower Bioequivalence Standards for Xarelto

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The Hyman, Phelps and McNamara (HPM) law firm says FDA’s bioequivalence recommendations for generic copies of Janssen Pharmaceuticals’ Xarelto (rivaroxaban) should be re-evaluated and revised. In just-posted comments submitted on behalf of an unnamed generic drug company client, HPM says revisions to a recent draft guidance should be made to lower bioequivalence standards based on the “known mechanism of action, the documented wide therapeutic range, well-established safety margins, moderate intra-subject variability in pharmacokinetics, and differences in food effect from lower to higher strengths of rivaroxaban.”



 

The current recommendation, according to HPM, calls for “fully replicated bioequivalence (BE) studies on the 20 mg strength under fasting and fed conditions with BE evaluation using average bioequivalence approach with limits of 80-125%, without any scope of utilizing reference scaled average BE approach in the view of a steep exposure-response relationship of rivaroxaban for both efficacy and safety. Moreover, the draft guidance also recommends a statistical comparison of the within-subject variability of test and reference products with resultant upper limit of the 90% confidence interval for the test-to reference ratio of the within-subject variability ≤ 2.5, as referred in the guidance on warfarin sodium — a typical narrow therapeutic index drug.”



 

Instead of the guidance’s BE recommendations, HPM urges FDA to revise these with the following study requirements: 

A single-dose, 2-way, cross-over in vivo study under fed conditions for the 10 mg tabletA single-dose, 2-way, cross-over in vivo study under fasting conditions for the 10 mg tabletA single-dose, 2-way, cross-over in vivo study under fed conditions for the 20 mg tablet

 

Overall, HPM argues that rivaroxaban does not fit in the typical definition of a narrow therapeutic index drug. Therefore, it says, if a potential generic product is bioequivalent with the innovator in a two-way cross over design, the two of them can be considered “switchable” in the view of their comparable rate and extent of absorption.

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