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BCS Guidance and Biowaivers BCS Monographs Vinod P. Shah, Ph.D., Pharmaceutical Consultant PQRI Board Member 2 nd FDA/PQRI Conference on Advancing Product Quality Emerging Regulatory Initiatives Biopharmaceutics BCS Biowaivers October 5-7, 2015, Bethesda

Emerging Regulatory Initiatives Biopharmaceutics BCS Biowaivers BCS Guidance and Biowaivers, BCS Monographs Vinod P. Shah, Ph. D. In vivo Predictive dissolution testing scientific progress in OrBiTo and enhanced industrial application Bertil Abrahamsson, Ph.D. Generic Drug Industry s Perspectives on BCS-based Biowaivers Yu Chung Ph.D. Implementation of BCS Guidance, Analysis of BCS submission to FDA and Guidance Update. Mehul U. Mehta, Ph.D. Panel Discussion

BCS Guidance and Biowaivers BCS Monographs BCS Guidance BCS Class 1 and 3 drugs for Biowaiver Updates on BCS related guidance BCS Monographs

Biopharmaceutics Classification System BCS is a scientific framework for classifying drug substances based on their aqueous solubility and intestinal permeability. When combined with the dissolution of the drug product, BCS takes into account three major factors that govern the rate and extent of absorption from IR solid oral dosage forms: dissolution, solubility and intestinal permeability. BCS Guidance: IR drug products non-nti drug products

Solubility Solubility is defined in terms of dose solubility, highest dose strength solubility in 250 ml of aqueous medium, ph 1.0-6.8. Classified as either high or low High defined as dose/solubility volume less than or equal to 250 ml Low defined as dose/solubility volume greater than 250 ml for any ph

Permeability Permeability is defined in terms of human permeability, absolute bioavailability (comparison with intravenous dose) or in terms of jejunum permeability. Highly permeable when the extent of drug absorption in human is >85% of an administered dose (compared to iv).

Biopharmaceutics Classification System It is a framework for classifying drug substance based on its solubility and permeability Drug Substance (API) classified into 4 classes: Class 1: Highly Soluble / Highly Permeable (HS/HP) Class 2: Low Solubility / Highly Permeable (LS/HP) Class 3: Highly Soluble / Low Permeability (HS/LP) Class 4: Low Solubility / Low Permeability (LS/LP) It is a drug development tool to justify biowaiver in conjunction with the dissolution of the drug product. GL Amidon, H Lennernas, VP Shah, JR Crison. A theoretical basis for a biopharmaceutics classification system: The correlation of in vitro drug product dissolution and in vivo bioavailability. Pharm Res. 12: 413-420, 1995

Biopharmaceutics Classification System Drug Substance Solubility Permeability High Low High Low Drug Product Dissolution Very Rapid Rapid Slow

Waiver of in vivo BA & BE for IR drug products based on BCS Criteria for biowaiver for BCS Class 1 and 3 Drugs * Solubility: - Highest strength soluble in 250 ml in ph 1.2 6.8 (Highly soluble) Permeability: - For Class 1 extent of absorption greater than 85% (Highly permeable) - For class 3, permeability can be less than 85%. Dissolution: Basket method at 100 rpm or paddle method at 75 rpm in 500 ml of ph 1.2, 4.5 and 6.8. - Class 1: 85% or greater in 15 or 30 minutes - Class 3: 85% or greater in 15 minutes For biowaivers Test (multisource) and Reference (comparator) products must have similar dissolution profile (f 2 ) in all 3 media, ph 1.2, 4.5 and 6.8. * Based on Draft BCS Guidance, May 2015.

BCS Based Biowaivers * BCS Class 1: HS/HP - VRD or RD Quantity of excipients should be consistent with intended function When new excipient or atypically large amount of excipient is used, additional information documenting the absence of an impact on BA may be needed BCS Class 3: HS/LP - VRD contains no inactive ingredients that are known to alter GI motility and/or absorption Inactive ingredients must be Q1 and Q2 (compared with RLD) For biowaivers Test (multisource) and Reference (comparator) products must have similar dissolution profile (f 2 ) in all 3 media, ph 1.2, 4.5 and 6.8. * Based on draft BCS Guidance, May 2015

BCS Class 1 and 3 Dissolution Methodology & Specifications* (After confirming BCS Class 1 or 3) Dissolution Method Basket Method (USP apparatus 1) 500 ml of 0.01M HCl aqueous media, 100 RPM, 37+ 0.5 C Paddle Method (USP apparatus 2) 500 ml of 0.01M HCl aqueous media, 100 RPM, 37+ 0.5 C Specification BCS Class 1: A single point dissolution specification of Q=80% in 30 minutes BCS Class 3: A single point dissolution specification of Q=80% in 15 minutes *Based on Draft IR dissolution guidance for BCS class 1,3 drugs. Aug 2015

BCS Related Guidance BCS Guidance: Waiver of in vivo bioavailability and bioequivalence studies for immediate release solid oral dosage forms based on a biopharmaceutics classification system - August 2000. Draft Guidance: Update on the (above) BCS biowaiver guidance - May 2015 Draft Guidance: Dissolution Testing and Specification Criteria for Immediate-Release Solid Oral Dosage Forms Containing Biopharmaceutics Classification System Class 1 and Class 3 Drugs - August 2015.

Conclusions Biowaiver based on BCS Class 1 and 3 provides opportunities for lowering regulatory burden with scientific rational. BCS-based biowaiver (approved) generic products are considered TE and TI with brand name drugs.

BCS-based Biowaiver Monographs Project - Overview Genesis of biowaiver monographs Project initiated by FIP/SIG - BCS; Now FIP/SIG Regulatory Science/FG - BCS and Biowaiver. No direct implication, no formal regulatory status, but represents best scientific judgment about eligibility for BCS based biowaiver. It provides a good starting point for the applicant. It is also used as a source of information by regulators. Drug substances selected based on WHO s List of Essential Medicines + other important drugs

Biowaiver Monographs Literature review - Solubility, permeability, dissolution, pharmacokinetic and bioequivalence data Document summarizing all known relevant information Review can suggest feasibility of biowaiver for a generic formulation Indicates criteria for in vitro equivalence test. Review can also indicate when biowaiver is not recommended, e.g., ciprofloxaxin, furosemide, mefloquin Published as a commentary in J Pharm Sci after peer review process. Also on virtual special issue of J Pharm Sci. Available on FIP web page: www.fip.org More than 35 biowaiver monographs, ranging from BCS class 1-4 have been prepared and published.

BCS Monograph J Pharm Sci will collate all Biowaiver Monographs and will place in a separate issue on-line. http://onlinelibrary.wiley.com/journal/10.1002/%2 8ISSN%291520-6017/homepage/chichester.htm Three of the ten most accessed papers in J Pharm Sci. in 2014 were Biowaiver Monographs.

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