considerations in pharmacovigilance for biosimilars · 2018-02-07 · 1 considerations in...
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Considerations IN Pharmacovigilance for Biosimilars
Dr. Shubhadeep Sinha, MD (Pharmacology, Mumbai)Vice-President &
Head- Clinical Development & Medical Affairs (CD&MA)Hetero Labs Limited, India
ISOPCON 2016, Agra, India19-OCT-2016
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• The views, opinions expressed in the following PowerPoint slides are those of the
individual presenter and should not be attributed to the conference organizers,
Hetero, its directors, officers, employees, volunteers, members, chapters, councils,
Special Interest Area Communities or affiliates, or any organization with which the
presenter is employed or affiliated.
• These are interpretations of the presenter and should not be used as reference in any
other presentations or discussions or in any publications or sharing or attributed to
any domestic or international, non-governmental, governmental or regulatory
agencies.
• These PowerPoint slides are the intellectual property of the individual presenter. To be
used by permission. All rights reserved.
Strictly Confidential
DISCLAIMER
AGENDA
1. Biosimilar News
2. Biosimilar Safety and Definitions
3. Biosimilar Pharmacovigilance Challenges - Manufacturing & Structure
4. Biosimilar Pharmacovigilance challenges – Product Naming
5. Biosimilarity and Pharmacovigilance Challenges- Interchangeability
6. Biosimilarity and Pharmacovigilance Challenges- Immunogenicity
7. Biosimilarity and Pharmacovigilance Challenges- Evolving Regulatory
Guidelines3 Strictly Confidential
4Strictly Confidential
BIOSIMILAR NEW(S)
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AGENDA
1. Biosimilar News
2. Biosimilar Safety and Definitions
3. Biosimilar Pharmacovigilance Challenges - Manufacturing & Structure
4. Biosimilar Pharmacovigilance challenges – Product Naming
5. Biosimilarity and Pharmacovigilance Challenges- Interchangeability
6. Biosimilarity and Pharmacovigilance Challenges- Immunogenicity
7. Biosimilarity and Pharmacovigilance Challenges- Evolving Regulatory
Guidelines9 Strictly Confidential
10Strictly Confidential
BIOSIMILAR AND SAFETY - DEFINITIONS
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BIOSIMILAR OR BIO-SIMILARITY MEANS: Similar biological or biosimilar
A biosimilar is a biological medicinal product that contains a version of the activesubstance of an already authorised reference product in the EEA, and
which has shown similarity to the reference product in terms of qualitycharacteristics, biological activity, safety and efficacy based on a comprehensivecomparability exercise
The biological product is highly similar to the reference product
not withstanding minor differences in clinically inactive components
There are no clinically meaningful differences between the biological product and the reference product in terms of the safety, purity, and potency of the product.
Pharmacovigilance is defined by the World Health Organization as “the science and activities relating to the detection, assessment, understanding and prevention of adverse effects or any other drug-related problems.”
Biosimilar or Biosimilarity
Pharmacovigilance
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BIOSIMILARITY AND PHARMACOVIGILANCE
Putting the two together has yielded a complex regulatory landscape with wide
variations and inconsistencies across countries and markets.
Difficult enough to build and maintain a robust PV program to meet regulatory requirements for small molecule drugs— and yet generic PV programs will not satisfy the requirements for Biosimilars.
Evolution is at different speeds and directions
FDA regulations with respect to biosimilars continue to evolve and continue to improve clarity with respect to pharmacovigilance.
European Medicine Agency has specific requirements for biosimilar pharmacovigilance (PV)—although the PV landscape continues to evolve in Europe, as well.
Companies developing biosimilars, need to be aware of several key issues with respect to
biosimilars that will impact their PV programs.
Challenges
AGENDA
1. Biosimilar News
2. Biosimilar Safety and Definitions
3. Biosimilar Pharmacovigilance Challenges - Manufacturing & Structure
4. Biosimilar Pharmacovigilance challenges – Product Naming
5. Biosimilarity and Pharmacovigilance Challenges- Interchangeability
6. Biosimilarity and Pharmacovigilance Challenges- Immunogenicity
7. Biosimilarity and Pharmacovigilance Challenges- Evolving Regulatory
Guidelines13 Strictly Confidential
14
BIOSIMILARITY AND PHARMACOVIGILANCE
Manufacturing methods.
1. More complex than for conventional small-molecule drugs.
2. Small differences between manufacturing methods can significantly
impact a biosimilar’ s biological properties, purity and clinical
activity.
3. No guarantee that resulting biosimilar will be comparable to its
reference product
Challenges
Biotherapeutics’ structure & manufacturing underscore the importance of pharmacovigilance (PV)
• A complex production process
– Intrinsic variability
• A complex structure- difficult to make exact biological copy, hence “biosimilar”
• A potential for generating unwanted immune responses
– Potential for both rapid and delayed onset adverse reactions
• Potential impact of post-marketing changes
Specifically traceability is of ImportanceSpecifically traceability is of Importance
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• Microheterogeneity
– alternative disulfide pairings/disulfide shuffling, deamidation, (methionine) oxidation, crystallization of N-terminal glutamine residues, and partial enzymatic cleavage
• Aggregation
• Glycosylation
– Only a problem for glycosylated proteins
– Virtually impossible to replicate glycosylation
• Excipients
• Syringe
– A known source of problems
MANUFACTURED PRODUCT RELATED PROBLEMS
GLYCOSYLATION IN BIOLOGICAL DRUGS IS IMPORTANT FOR TWO MAIN REASONS:
• Glycan may affect many of the protein properties: pharmacokinetics (uptake and length of time in the body), bioactivity, secretion, in vivo clearance, solubility, recognition, and antigenicity
• Quantitative and qualitative aspects of glycosylation affected by production process in culture, including cell line, method of culture, extracellular environment, and protein itself
Comprehensive Characterization
• Physicochemical as well as biological
• Against multiple batches of innovator spanning a number of years
• Understand innovator variability
• Specification changes over life of product
• No label change
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The Solution: Characterization
AGENDA
1. Biosimilar News
2. Biosimilar Safety and Definitions
3. Biosimilar Pharmacovigilance Challenges - Manufacturing & Structure
4. Biosimilar Pharmacovigilance challenges – Product Naming
5. Biosimilarity and Pharmacovigilance Challenges- Interchangeability
6. Biosimilarity and Pharmacovigilance Challenges- Immunogenicity
7. Biosimilarity and Pharmacovigilance Challenges- Evolving Regulatory
Guidelines19 Strictly Confidential
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BIOSIMILARITY AND PHARMACOVIGILANCE
Product names.
Multiple distinct biosimilars in development, multiple manufacturers may be producing
same biosimilar—names not necessarily distinctive---traceability issues in c/o an ADR.
Even slight variations in the manufacturing process from one company to another may
have untoward consequences. It is critical to record complete batch information as part of
the PV program.
Product identification compromised across healthcare settings.
Both spontaneous adverse event reporting systems & active surveillance systems
depend on accurate identification of the product dispensed or given to patients, yet
there is great variability in how health professionals and patients refer to
medications in these settings.
Challenges
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AGENDA
1. Biosimilar News
2. Biosimilar Safety and Definitions
3. Biosimilar Pharmacovigilance Challenges - Manufacturing & Structure
4. Biosimilar Pharmacovigilance challenges – Product Naming
5. Biosimilarity and Pharmacovigilance Challenges- Interchangeability
6. Biosimilarity and Pharmacovigilance Challenges- Immunogenicity
7. Biosimilarity and Pharmacovigilance Challenges- Evolving Regulatory
Guidelines25 Strictly Confidential
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BIOSIMILARITY AND PHARMACOVIGILANCE
Interchangeability –
Generics and brand name products can be prescribed
interchangeably in most cases. Biosimilars—although comparable to
the innovator drugs—cannot.
“Automatic” interchangeability would require data showing that a
biosimilar produces equivalent clinical result in any given
individual.
Challenges
AGENDA
1. Biosimilar News
2. Biosimilar Safety and Definitions
3. Biosimilar Pharmacovigilance Challenges - Manufacturing & Structure
4. Biosimilar Pharmacovigilance challenges – Product Naming
5. Biosimilarity and Pharmacovigilance Challenges- Interchangeability
6. Biosimilarity and Pharmacovigilance Challenges- Immunogenicity
7. Biosimilarity and Pharmacovigilance Challenges- Evolving Regulatory
Guidelines27 Strictly Confidential
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BIOSIMILARITY AND PHARMACOVIGILANCE
Preapproval immunogenicity in the entire premarketing clinical study
population mandatory but not sufficient to rule out rare occurrences
Post-approval surveillance for immunogenicity and rare adverse
events may be needed and/or required over the long term, once a
biosimilar is on the market.
Such monitoring is expected across regulatory guidelines varying in
conditions from guideline to guideline.
Challenges- Immunogenicity
Safety Issue Explanation
tuberculosis with the use of
tumour necrosis factor (TNF)-a
inhibitors, especially Infliximab
and adalimumab
TNFa has a role in the immune response to the
mycobacteria responsible for tuberculosis.
Inhibition of TNFa will lead to an increase of
the activity of the bacilli and cause disease
dramatically increased incidence of pure red cell aplasia in patients treated with one particular formulation of recombinant human epoetin (containing polysorbate)
immunogenic response to endogenous
molecules, which occurred following changes in the manufacturing of epoetin alfa
Giezen et al. Drug Safety 2009
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Complexity of immunogenicity: Exaggerated pharmacology
3011/28/2016
3111/28/2016
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Risk Based Approaches to Immunogenicity Testing
Risk = Probabilityharm x Severityharm
•Severity outweighs the probability of a risk occurring.
•The overall Risk Score depends on an assessment of the various
factors that influence immunogenicity
How many patients are
likely to mount an immune
response?
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What happens to the patient
if they mount an immune
response?
AGENDA
1. Biosimilar News
2. Biosimilar Safety and Definitions
3. Biosimilar Pharmacovigilance Challenges - Manufacturing & Structure
4. Biosimilar Pharmacovigilance challenges – Product Naming
5. Biosimilarity and Pharmacovigilance Challenges- Interchangeability
6. Biosimilarity and Pharmacovigilance Challenges- Immunogenicity
7. Biosimilarity and Pharmacovigilance Challenges- Evolving Regulatory
Guidelines34 Strictly Confidential
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BIOSIMILARITY AND PHARMACOVIGILANCE
Evolving guidelines. As guidelines for biosimilar approvals and PV evolve,
pharmaceutical companies will need to stay vigilant so that their PV
programs can rapidly adapt to evolving regulatory criteria.
Challenges
Key Regulatory Countries for Biosimilars
2000-2004 2008 2009 2010, 2016
2011, 2015, 2016
EuropeCanada
Australia Japan
United States(established
legal pathway)
Europe
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2012, 2016
India (CDSCO)
biosimilar guideline
11/28/2016
3711/28/2016
3811/28/2016
CLINICAL STUDY REQUIREMENTS
Design trials with right endpoints and right population
Difficulty in identifying sites and patients in Phase I and III
Can take a long time and a lot of patients
Phase IPhase I studies supporting dose(s) for targeted indications
Phase I Study:
•Healthy volunteers vs patients
•Ethics committee considerations•Part 1 - Initial safety and comparative PK arms (at labeled dose)•Part 2 - Comparative PK/PD, Immunogenicity and Safety/Efficacy run in parallel to Phase III study submissions•N>40 for Interim Analysis for PK/PD powering
Difficulties• Cross-over designs
• Sentinel dosing group for Phase I
Phase III
•Single Pivotal (therapeutic category)
• PK/PD assessments with shorter cycles
of therapy
•Immunogenicity determined with full
regimen of therapy
•“Interchangeability” not yet addressed
by FDA
Thank you for attention!
THANK YOU FOR ATTENTION!
Strictly Confidential 40