FDA发布针对两个专注达仿制药的撤市听证会通知
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FDA发布针对两个专注达仿制药的撤市听证会通知
笔记 2016-10-18 Lachman CONSULTANTS 10月17日,FDA通过两份联邦公报(FR)通告分别宣布两家公司的盐酸哌甲酯缓释片撤市听证会通知(NOOH, Notice of Opportunity for Hearing)【FR通告一 所有这些都发生在近两年前,现在FDA正在启动最后的行政措施以永久性的从市场上撤回这两个产品。 识林相关资讯
FDA过去曾被批评没有对治疗不等效报告做出及时回应(即安非他酮缓释产品);然而这需要一个过程(尽管比较拖延)。FDA非常认真的对待治疗不等效报告,因为他们需要在采取任何执法行动之前弄清楚。这也是为什么FDA花费更长的时间批准产品的复杂剂型,以确保产品获得正确地批准,以免损害公众对仿制药的信心。FDA做得漂亮,因为在Hatch-Waxman法案通过后批准了超过两万件ANDA的情况下,只有一小撮针对药品批准后的行动是基于TE关注。 Lachman CONSULTANTS - Bob Pollock先生 Notice of Opportunity for Hearing Issued for Two Methylphenidate Generics to Concerta By Bob Pollock | October 17, 2016 Yesterday, FDA published two separate Federal Register Notices (here and here) announcing a Notice of Opportunity for Hearing (NOOH) for the withdrawal from marketing of two firms’ methylphenidate extended-release tablets. The Agency had previously expressed concerns regarding the Therapeutic Equivalence (TE) of these two products based on significantly higher reports of therapeutic failure later in the day than the reference listed drug product (and/or authorized generic). The FDA changed the TE code from AB to BX and requested that the firms either voluntarily withdraw their products from the market or repeat new bioequivalence (BE) studies based on new guidance, which the FDA had issued that changes the metrics for establishing BE to conform with new information that became available to the Agency (see here and here). Neither firm chose to voluntarily withdraw its product from the market at that time. One firm submitted a new BE study that also failed the new BE requirements; the other firm did not submit the results of a new study. That all occurred almost 2 years ago and now the FDA is initiating the beginning of a final administrative action to permanently remove the products from the marketplace. Leading up to the decision to request an NOOH to withdraw the applications for the products, the FDA:
Reanalyzed data from the original submitted studies in accordance with the new requirements of the revised BE guidance.
FDA has been criticized in the past for not responding to reports of therapeutic inequivalence in a timely manner (i.e., the bupropion extended-release product); however, there is a process (albeit protracted) to do so. FDA takes reports of therapeutic inequivalence very seriously, as they need to get that right before taking any enforcement action. That is also why FDA takes a longer time to approve complex dosage forms of products to be sure it gets the approval right, so as not to undermine the public’s confidence in generic drugs. FDA does a pretty darn good job, as there have only been a handful of actions against products post-approval based on TE concerns, and that is after the approval of over 20,000 ANDAs since the passage of Hatch-Waxman. |