More Support for Treating All Biologics the Same
The Association for Accessible Medicines and its Biosimilars Council say they support FDA’s approach to applying the same principles to postapproval manufacturing changes for all 351(k) biological products, regardless of whether they are licensed as biosimilar or interchangeable. “Importantly, and consistent with FDA regulations and guidance, these same principles, namely evaluating comparability of the prechange and postchange product, apply to all biological products irrespective of the licensure pathway,” the comment letter says.
The organizations say they are concerned that an FDA draft guidance with questions and answers on postapproval manufacturing changes to biosimilar and interchangeable biosimilar products suggests that a separate demonstration of adequate assurance that a postchange product remains biosimilar to or interchangeable with the reference product may be needed, even when the applicant submits sufficient data to enable an informed prediction that no adverse impact on the quality, safety, or efficacy of the postchange product is expected. “This introduces unpredictability to the process and could lead to unnecessary work and delays in implementing important manufacturing changes to the detriment of patients,” they say.
The associations recommend specific changes to the guidance text.
In its response, Pharmaceutical Research and Manufacturers of America recommends a clarifying revision to the discussion of product quality data in the draft guidance, in addition to supporting the FDA approach to using historical analytical data in analytical comparability data.