Purdue Wants Butrans Follow-on Restrictions
Purdue Pharma is asking FDA to ensure that follow-on products citing its Butrans (buprenorphine) transdermal system for transdermal administration as the reference-listed drug are as safe and effective as Butrans. The company’s petition specifically asks the agency to:
- require that applications referencing Butrans contain appropriate toxicology and extractable leachable study data sufficient to evaluate any differences in the proposed formulations/products; and
- require that any proposed follow-on buprenorphine patch products incorporate a patch disposal system that has been shown to be as safe and effective as the Butrans patch-disposal unit through comparative extraction, senior use, and child resistant testing.
Purdue argues that Butrans’ safety was established, in part, through extensive preclinical and chemistry, manufacturing, and controls extractable leachable data tailored to the Butrans formulation and packaging components. It also says that the Butrans patch-disposal unit enhances the product’s safety by reducing the risk of accidental exposure to and intentional abuse of used patches. “Proposed generic versions of Butrans without disposal systems, or with disposal systems that have not been shown through comparative extraction, senior use, and child resistance testing to perform as well as the Butrans patch-disposal unit are not as safe as Butrans, cannot duplicate the Butrans labeling, and do not have the same performance characteristics, operating principles, and critical design attributes as Butrans,” it says. It also says that a proposed 505(b)(2) buprenorphine patch that lacks a disposal system or has one that does not perform as well as the Butrans system has an unfavorable risk/benefit profile and should not be approved.