Mylan Petitions FDA for Strict Bioequivalence on Advair Generics

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Mylan has petitioned FDA to require specific bioequivalence study designs for ANDA applicants seeking to market generic versions of GlaxoSmithKline’s asthma therapy Advair Diskus (fluticasone propionate and salmeterol xinafoate) inhalation powder. The Mylan petition asks FDA to refrain from approving any ANDA that “relies on multiple-batch pharmacokinetic (PK) bioequivalence (BE) study designs unless, after conducting an appropriately rigorous review under the established standards for establishing BE, generally, and for this product specifically, FDA concludes that such a study design is valid and will ensure patients receive a robust and reliable therapeutically equivalent product.”

 

The petition acknowledges that Mylan has already filed an ANDA referencing Advair Diskus. It says based on its development work, “we know that a sponsor need not turn to unvalidated alternative methods as it is possible, with an adequate understanding of the RLD [reference-listed drug] and a well-designed proposed generic, to demonstrate BE using straightforward and established single-batch BE studies designed in accordance with FDA’s guidance, experience, and precedent.”

 

Mylan says it is concerned that “applicants may be attempting to rely on novel, unprecedented PK/BE study designs to support bioequivalence of a proposed product to the RLD because they have not adequately performed the necessary development work to understand the RLD product and the proposed generic and, as a result, are unable to demonstrate PK BE using accepted methods as provided by the guidance. Such an unprecedented design has not been demonstrated to constitute valid, reliable data that could support ANDA approval, and sponsors who have failed to show BE using more straightforward and well-established methods should not be permitted to take failed studies and attempt to instill them with meaning using an atypical multiple-batch study design — specially when the more straightforward, well-understood design provided for in the guidance is sufficient to establish BE.”

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