Treat all Biologics the Same: Stakeholders

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Responding to an FDA draft guidance on questions and answers about post-approval manufacturing changes to biosimilar and interchangeable biosimilar products, Samsung Bopepis questions the need for an additional guidance since all biologics should be treated the same. “Regulatory consistency and the application of the same regulatory science by regulators at FDA, and ideally elsewhere, across all biologics is crucial,” the comment letter says. “Regulators should not be considering the business model of sponsors and once approved a biosimilar is first and foremost always a biologic. This is the only way to be fair and the only way to enhance all stakeholder confidence in all biologics, including biosimilars.”

Samsung says it is concerned about having a separate guidance unique to the U.S. for post-approval manufacturing changes to biosimilar and interchangeable biosimilar products. “It is not needed,” it says, “and worse, it could be used to imply that there are additional or merely different risks for 351(k) products compared to other biologics already licensed under 351(a). Fundamentally, biosimilar and interchangeable biosimilar products are already biologics, just like their reference products, and all issues pertaining to quality, safety, and efficacy (safety, purity, and potency) of biologics already must and do apply. There are very real risks created by two separate guidances that attempt to address the same regulatory issues as they could be amended differently over time and get out of sync.”

In its response, the Biosimilars Forum says that overall it supports the guidance and the process outlined in it. The letter says it would be important for FDA to state that the principles in the guidance apply to all biologics, regardless of the approval pathway. The Biosimilars Forum also makes specific recommendations for changes to the guidance.

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