Transcript Quality of Bioequivalence Studies Evaluation of Quality and Interchangeability of Medicinal Products

Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
Evaluation of Quality and
Interchangeability of Medicinal Products
10 – 14 September 2007
Dar Es Salaam, Tanzania
Dr. Henrike Potthast; Temporary Advisor to WHO
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
 e.g. acc. to Directive 2001/20/EC:
“The verification of compliance with the standards of good
clinical practice and the need to subject data, information
and documents to inspection in order to confirm that they
have been properly generated, recorded and reported are
essential in order to justify the involvement of human
subjects in clinical trials.”
GCP & GLP
finding/definition of inspection triggers
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
 General Requirements
 BE studies as a substitute for clinical and
preclinical data
 Quality of the BE study is of decisive importance
for approval of the product
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
 Environmental triggers - examples
 random selection acc. to annual inspection program
 information from other regulatory authorities
 type of product (e.g. particular narrow therap. range)
 lack of previous inspections for product/applicant/location
 ……
 general indication for inspection
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
 Early phase triggers - examples
 history of (serious) problems for sponsor, CRO, sites, labs
 involvement of clinical site/CRO/labs in many studies
 business related issues (e.g. bankruptcy, mergers)
 lack of audit certificates
 …..
 Still general indication without direct implication of trial data
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
 Evaluation phase triggers - examples
 protocol gives incomplete/illogical information
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numerous protocol violations
unsatisfactory explanation for protocol violations
data too clean/too messy
number of missing values/drop outs/nds….
 Findings due to knowledge from literature and other
studies; type of generic product already known
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
 Evaluation phase triggers – contd.
 conflicting (PK-)results as compared to known data
 insufficient documentation (clinic, analytics, statistics)
 missing documentation
 implausibility/inconsistency of clinical or analytical data
(e.g. long half-life – short wash-out – no carry-over?!)
 doubtful statistics or change in the analysis….
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
 Information exchange
 evaluation of triggers
positive
(negative – non serious/’formal’)
negative – serious  request/list of questions
 e.g. EMEA inspection data base since 2004
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
 Evaluation/Inspection based on source
data/raw data
e.g.
 print-outs of chromatograms
 signed CRFs
 analytic protocols
 time schedules
 list of providers …….
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
Data verification & QA issues
 GCP compliance statement available?
 audit/monitoring reports available?
 protocol valid, i.e. signed (incl. amendments)?
 was the protocol followed?
 genuine study subjects/volunteers?
 archiving of source/raw data?
 violations of the protocol justified? ….
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
Data verification & QA issues ctd.
 excluded subjects - traceable?
 consistent trial results?
 final responsibility of investigators (signing)?
 source of investigative products?
 batch information available?
 handling of investigative products?
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
Data verification & QA issues ctd.
 validation of bioanalytical method?
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timing
validation characteristics
adherence to GLP
SOPs available……
 calibrated equipment?
 computer systems????
 archiving of bioanalytical raw data
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
Data verification & QA issues ctd.
 statistical plan adhered to?
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transfer of analytical data to statistics
main pharmacokinetic characteristics
method of determination
nd values considered?
 statistical outcome and conclusions consistent?
 archiving of statistical raw data
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
Regulatory & ethical issues
 independent ethics committee?
 ethical approval based on appropriate documentation?
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protocol
amendments
investigators brochure; SPC
subjects information informed consent
 approval of competent authority in time?
 subjects from vulnerable populations?
 signing of subjects available?
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
Regulatory & ethical issues ctd.
 insurance of subjects adequate?
 adequately instructed personnel?
 investigators
 technicians
 suppliers…..
 safety evaluation assured throughout the trial?
 retention samples sufficient?
 storage of retention samples?
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health
Federal Institute for Drugs
and Medical Devices
Quality of Bioequivalence Studies
THANK YOU FOR YOUR
ATTENTION
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The BfArM is a Federal Institute within the portfolio of the Federal Ministry of Health