Quality of Medicinal Products

—

Biologicals, Regulatory and Compendial Approaches

Fouad Atouf, Ph.D.

Director, Biologics & Biotechnology

Outline

 Challenges Associated with Manufacturing and Regulation of Biologics and Biotechnology (B&B) Products  U.S. Food and Drug Administration (FDA) and Regulatory Pathways for Biological Products  Legal Recognition of USP’s Standards  USP Activities in Biologics

Biological Medicines: Challenges (1)

 Biological Medicines: Scope of Products – Blood and Blood Products – Cell, Gene, Tissue Therapies – Therapeutic Proteins, Recombinant and Naturally-derived – Vaccines  Multi-components (e.g. raw materials) manufacturing: – Potential supply chain issues (e.g. animal derived materials) – Testing of quality of components before manufacturing begins  Control of the quality, safety and efficacy of biologicals is difficult, despite technological advances – Orthogonal methods needed to address a single quality aspect – Higher order structure issues are often addressed by using a biological assay

Biological Medicines: Challenges (2)

 Complex manufacturing processes with impact on: – Quality attributes of finished products – Challenging regulatory approval pathways  Regulatory approaches: – Biologics = Subset of “Drugs” – Until recent biosimilars law passed, products approved through either the Federal Food, Drug, and Cosmetic Act (FDCA) or the Public Health Service (PHS Act) pathways • Depending on legacy approvals, sponsor preference, FDA Policy, and inter-center agreements

Regulation of B&B Products within the US FDA

 Office of the Commissioner  Office of Foods – Center for Food Safety and Applied Nutrition – Center for Veterinary Medicine  Office of Global Regulatory Operations and Policy – Office of International Programs – Office of Regulatory Affairs  Office of Medical Products & Tobacco – –

Center for Biologics Evaluation and Research (CBER)

– Center for Devices and Radiological Health

Center for Drug Evaluation and Research (CDER)

– Center for Tobacco Products – Office of Special Medical Programs  Office of Operations

Regulation of B&B Products - US FDA



CDER (NDAs and BLAs)

– Insulin and analogs – Hormones and analogs – Therapeutic protein, natural and recombinant – Monoclonal antibodies – Oligonucleotides – Synthetic peptide 

CBER (BLAs )

– Blood and Blood components – Plasma products – Medical devices – Vaccines – Allergenic extracts – Cell and gene therapy – Xenotransplantation – Tissue

NDA: New Drug Application BLA: Biological License Application

Biologics Regulated by CDER



IND/NDA (FD&C Act)

– Insulin – Growth Hormone – FSH, LH, hCG, TSH – Calcitonin – PTH – Aprotinin – Hyaluronidase – Heparins 

IND/BLA (PHS Act)

– Interferons – T-PA – Erythropoietin – Monoclonal Antibodies – Enzymes

IND: Investigational New Drug NDA: New Drug Application BLA: Biological License Application

Comparing and Contrasting BLAs and NDAs

 FDCA NDAs: – “Substantial Evidence” of safety and effectiveness; requires 1+ clinical studies; statutory bases for refusing approval, 505(d) – Abbreviated pathway is ANDA, 505 (j); does not have to submit evidence of the safety and effectiveness of the drug product, because it relies on FDA’s previous filing;  PHS Act BLAs: – Standard of “Safety, Purity and Potency,” although considered by FDA to be interchangeable with “safety and effectiveness” (Biosimilars ‘Scientific Considerations’ Guidance, p. 3 fn 8) – Even biosimilars require 1 or more clinical studies “sufficient to demonstrate safety, purity, and potency in 1 or more appropriate conditions of use . . . .”

351(k)(2)(A)(i)(I)(cc);

and see FDA Form 356h (Application to Market, 21 CFR 314 & 601)

What FDCA Requirements Apply to PHS Act BLAs?



PHS Act Recognizes Overarching Role of FDCA:

– PHS §262 (g): PHS may not be “construed as in any way affecting, modifying, repealing, or superseding” the provisions of the FDCA. – PHS §262 (j), added by 1997 FDA Modernization Act: The FDCA (including even 505 post-marketing studies, and REMS), applies to biologics approved with a PHS Act BLA, except 505 NDA not required. 

All FDCA Requirements Except 505 License Apply

– IND Approval for Clinical Research

FDA Form 1571

– Post-approval adverse event reporting – Labeling not false or misleading – 503 Presc Drug Mktng Act

re Marketing, Samples, Distribution

505D Pharmaceutical Security – 501 & 502 Adulteration and Misbranding requirements • •

GMPs (501(a)(2)(B)) USP Identity/Quality Standards (501(b); 502(e)(3) USP Packaging & Labeling Standards (502(g))

By 2020, All “Biologic

Products

” Licensed With BLA

§351(k) “Biologic Product” defined as “a virus, therapeutic serum, toxin, antitoxin, vaccine, blood, blood component or derivative, allergenic product,

protein

(except any chemically synthesized polypeptide), or analogous product, . . . , applicable to the prevention, treatment, or cure of a disease or condition of human beings.” PHS §351(i) After March 23, 2020, all legacy FDCA biologics will be deemed to be licensed under PHS §351 (see transition rules BPCI §7002(e))

By 2020, All “Biologic Products” Licensed With BLA (2) Applicants seeking a BLA will continue to have two options: 

PHS §351(a)

, based on a demonstration the biological product is “safe, pure and potent.” 

PHS §351(k)

, which requires one or more clinical studies “sufficient to demonstrate safety, purity, and potency in 1 or more appropriate conditions of use,” as part of information sufficient for FDA to determine that the biological product is “biosimilar” to a specified §351

(a)

reference product, PHS §351(k)(2)((A)(i),

and

disclosure of confidential information, patent/exclusivity requirements. §351(l)

Role of USP – What Are Compendial Standards?

  

Drugs/Biologics (articles) are recognized in USP-NF

when a standard is published and an official date is assigned. GN* 2.20

Standards are expressed in terms of an article’s Monograph, applicable General Chapters, and General Notices. GN 3.10

Monographs include article’s

Name

, and specifications (with tests and assays) to help ensure

Identity

, as well as

Strength, Quality and Purity

. GN 4.10

 USP Reference Standards key standard component. GN 5.80

 May also include other requirements, e.g. related to Packaging, Storage, and Labeling. GN 4.10

• *See USP

General Notices www.usp.org

What is USP’s Role in Law?



Adulteration –

Drug/biologic “shall” be deemed adulterated “If it purports to be or is represented as a drug the name of which is recognized in an official compendium, and its strength differs from, or its quality or purity falls below, the standards set forth in such compendium.” FDCA 501(b) – “Official compendium” means the current version of

USP

or

NF

deemed official by USP, including any supplements. FDCA 201(j) Current official version is

35 USP-30-NF

, 5/1/2012 – 4/30/2013 

Tests –

“Such determination as to strength, quality or purity shall be made in accordance with the tests or methods of assay set forth in such compendium, . . . .” FDCA 501(b) 

Misbranding –

Drug/biologic “shall” be deemed misbranded “if it purports to be a drug the name of which is recognized in [

USP-NF

],” unless “packaged and labeled as prescribed therein.” FDCA 502(g) 

Enforcement –

USP has no role in enforcement of USP standards; responsibility of FDA and other authorities in U.S. and elsewhere.

USP B&B Expert Committees and Expert Panels General Chapters Biological Analysis <1044> Cryopreservation <1240> Viral Testing for Human Plasma Glycoprotein & Glycan Analysis <30> Residual DNA Testing Immunological Test Methods <1106> Immunogenicity <1239> Viral Vaccines <1050.1> Viral Clearance <57> Protein Determination Procedures Glycoconjugate Vaccines Chapters Recombinant Therapeutic MAbs Residual Host Cell Proteins (to be formed) Monographs 1 Glucagon Pharmaceutical Enzyme Preparations Low Molecular Weight Heparin Epoetin Unfractionated Heparin Insulin Monographs 2 Tissue and Tissue Based Products Plasma Protein Analytical Coagulation Factors

USP Standards —Biologicals

Horizontal Standards - Procedural

Benefits:

 Access to validated procedures and procedure performance criteria early in development  Solid anchor point for product characterization  Facilitated comparability during development stages

Challenges in Standard Development:

 Assuring suitability and performance across products and analytical platforms  Defining and developing associated reference material(s)  Evolution of analytical technology - when is a method ready for the compendium? When is the compendium ready for revision?

 Determination of equivalence between analytical procedures and establishment of performance criteria

Vertical Standards – Monographs

Role and Use:

 Clearly define identity, strength and purity, as well as other important quality attributes at the product level  Allow independent testing and verification based on a public standard

Considerations for Standard Development:

 Complexity of specifications and system suitability criteria  Biological potency assignments and unit maintenance – Across manufacturers – Internationally  Product- specific vs. common product class requirements  For well-characterized and legacy products: inclusion and bridging to new analytical technology

Official USP Biologics Monographs by Product Class

B&B Overall Monograph Distribution by Product Class peptide carbohydrate Tissue product Vaccine enzyme glycosaminoglycan IgG/serum Other complex extract other Blood component/protein Product Class 3% 1% peptide 4% enzyme 8% complex extract 5% 39% carbohydrate 4% glycosaminoglycan 8% 9% 9% 10% other Tissue product IgG/serum Blood component/protein Vaccine Number of monographs 47 12 6 9 5 3 11 11 9 5