us-fda-guidance-330d4a6bb7d391d5bb8e5261d45eacf1•The Use of Physiologically Based Pharmacokinetic Analyses — Biopharmaceutics Applications for Oral Drug Product Development, Manufacturing Changes, and Controls : Draft Guidance for Industry
The Use of Physiologically Based Pharmacokinetic Analyses — Biopharmaceutics Applications for Oral Drug Product Development, Manufacturing Changes, and Controls : Draft Guidance for Industry
us-fda-guidance-330d4a6bb7d391d5bb8e5261d45eacf1The Use of Physiologically Based Pharmacokinetic Analyses — Biopharmaceutics Applications for Oral Drug Product Development, Manufacturing Changes, and Controls : Draft Guidance for IndustryDraft Guidance
Administrative draft guidance, not enacted legislation. This captured publisher edition preserves the listed document and attachments; later developments are not independently consolidated.
- Docket Number:
- FDA-2020-D-1517
- Issued by:
- Guidance Issuing OfficeCenter for Drug Evaluation and Research
This guidance provides general recommendations regarding the development, evaluation, and use of physiologically based pharmacokinetic (PBPK) analyses for biopharmaceutics applications employed by sponsors of investigational new drug applications, and applicants for new drug applications, or abbreviated new drug applications, and supplements to these applications, for oral drug product development, manufacturing changes, and controls. PBPK analyses use models and simulations that combine physiology, population, and drug substance and product characteristics to mechanistically describe the pharmacokinetic (PK) and/or pharmacodynamic behaviors of a drug product.
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19190003dft.docx 09/28/20 The Use of Physiologically Based Pharmacokinetic Analyses — Biopharmaceutics Applications for Oral Drug Product Development, Manufacturing Changes, and Controls Guidance for Industry DRAFT GUIDANCE This guidance document is being distributed for comment purposes only. Comments and suggestions regarding this draft document should be submitted within 60 days of publication in the Federal Register of the notice announcing the availability of the draft guidance. Submit electronic comments to https://www.regulations.gov. Submit written comments to the Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. All comments should be identified with the docket number listed in the notice of availability that publishes in the Federal Register. For questions regarding this draft document, contact Paul Seo at 301-796-4874. U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) October 2020 Pharmaceutical Quality/CMC
The Use of Physiologically Based Pharmacokinetic Analyses — Biopharmaceutics Applications for Oral Drug Product Development, Manufacturing Changes, and Controls Guidance for Industry Additional copies are available from: Office of Communications, Division of Drug Information Center for Drug Evaluation and Research Food and Drug Administration 10001 New Hampshire Ave., Hillandale Bldg., 4th Floor Silver Spring, MD 20993-0002 Phone: 855-543-3784 or 301-796-3400; Fax: 301-431-6353; Email: druginfo@fda.hhs.gov https://www.fda.gov/drugs/guidance-compliance-regulatory-information/guidances-drugs U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) October 2020 Pharmaceutical Quality/CMC
Contains Nonbinding Recommendations Draft — Not for Implementation TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. 1 II. BACKGROUND ............................................................................................................... 2 III. IMPLEMENTATION OF PBPK MODELING FOR BIOPHARMACEUTICS APPLICATIONS .............................................................................................................. 3 IV. DEVELOPMENT AND EVALUATION OF PBPK MODELS FOR BIOPHARMACEUTICS APPLICATIONS .................................................................. 5 A. General Strategy ............................................................................................................................ 5 B. General Considerations ................................................................................................................. 7 1. Model Objective(s) ........................................................................................................................... 7 2. Model Development ......................................................................................................................... 7 3. Model Validation and Refinement ................................................................................................... 8 V. PBPK MODELING FOR BIOPHARMACEUTICS APPLICATIONS TO SUPPORT PRODUCT QUALITY ......................................................................................................... 9 A. Development of Clinically Relevant Dissolution Specifications (Method and Acceptance Criteria) .......................................................................................................................................... 9 1. Aid in Biopredictive Dissolution Method Development ................................................................... 9 2. Support Clinically Relevant Dissolution Acceptance Criteria....................................................... 10 B. Establishment of Clinically Relevant Drug Product Quality Specifications (Other Than Dissolution) ................................................................................................................................... 11 C. Quality Risk Assessment for Pre- and Postapproval Changes and Risk-Based Biowaivers . 12 GLOSSARY................................................................................................................................. 14 REFERENCES ............................................................................................................................ 16
Contains Nonbinding Recommendations Draft — Not for Implementation 1 The Use of Physiologically Based Pharmacokinetic Analyses — 1 Biopharmaceutics Applications for Oral Drug Product 2 Development, Manufacturing Changes, and Controls 3 Guidance for Industry1 4 5 6 7 8 This draft guidance, when finalized, will represent the current thinking of the Food and Drug 9 Administration (FDA or Agency) on this topic. It does not establish any rights for any person and is not 10 binding on FDA or the public. You can use an alternative approach if it satisfies the requirements of the 11 applicable statutes and regulations. To discuss an alternative approach, contact the FDA staff responsible 12 for this guidance as listed on the title page. 13 14 15 16 17 I. INTRODUCTION 18 19 This guidance provides general recommendations regarding the development, evaluation, and 20 use of physiologically based pharmacokinetic (PBPK) analyses for biopharmaceutics 21 applications employed by sponsors of investigational new drug applications, and applicants for 22 new drug applications, or abbreviated new drug applications, and supplements to these 23 applications,2,3 for oral drug product development, manufacturing changes, and controls. PBPK 24 analyses use models and simulations that combine physiology, population, and drug substance 25 and product characteristics to mechanistically describe the pharmacokinetic (PK) and/or 26 pharmacodynamic behaviors of a drug product.4 27 28 The application of PBPK modeling in support of drug product development is an evolving field. 29 We note that there are multiple terms used to describe PBPK analyses for biopharmaceutics 30 applications, including PBPK absorption modeling (Zhang et al. 2017), physiologically based 31 absorption modeling (Kesisoglou et al. 2016), and physiologically based biopharmaceutics 32 modeling (PBBM) (Heimbach et al. 2019). This guidance uses the term PBPK analyses (or 33 1 This guidance has been prepared by the Office of Pharmaceutical Quality in the Center for Drug Evaluation and Research at the Food and Drug Administration. 2 For the purposes of this guidance, sponsor refers to sponsors of investigational new drug applications, applicants for new drug applications and abbreviated new drug applications, and supplements to those applications. 3 The scientific principles described in this guidance are applicable regardless of whether an original clinical study demonstrated bioavailability/bioequivalence and are relevant whether or not an application is required. 4 Submission of PBPK analyses to FDA is discussed in the guidance for industry Physiologically Based Pharmacokinetic Analyses — Format and Content (August 2018). We update guidances periodically. For the most recent version of a guidance, check the FDA guidance web page at https://www.fda.gov/regulatory- information/search-fda-guidance-documents.
Contains Nonbinding Recommendations Draft — Not for Implementation 2 modeling) for biopharmaceutics applications to emphasize the focus on drug product quality 34 attributes and a mechanistic understanding of their interaction with physiology to affect in vivo 35 drug performance. 36 37 This guidance applies only to orally administered, systemically active drug products. It does not 38 apply to locally acting drug products, including orally delivered gastrointestinal (GI) drug 39 products that reach the site of action before entering systemic circulation. The use of PBPK 40 analyses for biopharmaceutics applications for locally acting drug products will be considered on 41 a case-by-case basis and via communication with FDA. 42 43 In general, FDA’s guidance documents do not establish legally enforceable responsibilities. 44 Instead, guidances describe the Agency’s current thinking on a topic and should be viewed only 45 as recommendations, unless specific regulatory or statutory requirements are cited. The use of 46 the word should in Agency guidances means that something is suggested or recommended, but 47 not required. 48 49 50 II. BACKGROUND 51 52 Several guidances for industry advocate the use of biopharmaceutics tools,5 such as in vitro 53 dissolution, and in vivo bioavailability (BA)/bioequivalence (BE) studies, along with modeling 54 approaches to support drug product quality. In addition, quality by design (QbD) principles 55 recognize that drug product quality cannot be tested into drug products; quality should be built 56 into drug products by design.6 In this regard, QbD enables an in-depth understanding of the 57 relationship among critical quality attributes (CQAs), critical material attributes (CMAs), critical 58 process parameters (CPPs), and predefined clinical performance metrics (e.g., systemic exposure 59 such as C max and area under the curve (AUC)). Data describing this relationship are essential for 60 establishing an in vitro-in vivo link. Establishing an in vitro-in vivo link supports clinically 61 relevant drug product specifications. 62 63 5 See the guidances for industry Dissolution Testing of Immediate Release Solid Oral Dosage Forms (August 1997), Extended Release Oral Dosage Forms: Development, Evaluation, and Application of In Vitro/In Vivo Correlations (September 1997), and Immediate Release Solid Oral Dosage Forms Scale-Up and Postapproval Changes: Chemistry, Manufacturing, and Controls, In Vitro Dissolution Testing, and In Vivo Bioequivalence Documentation (November 1995). 6 See the ICH guidance for industry Q8(R2) Pharmaceutical Development (November 2009).
Contains Nonbinding Recommendations Draft — Not for Implementation 3 Although the pharmaceutical industry has in some cases been successful in developing in vitro/in 64 vivo correlations (IVIVCs) to support biowaiver7 requests in lieu of in vivo BE studies for major 65 manufacturing changes (Nguyen et al. 2017), development of an adequate IVIVC for regulatory 66 submission remains challenging (Suarez-Sharp et al. 2016). FDA recognizes this challenge and 67 encourages the development and use of new tools and approaches for linking pharmaceutical 68 quality to clinical performance. Advances in modeling and simulation have enabled the 69 integration of factors such as the physicochemical properties of the active pharmaceutical 70 ingredient (API), dissolution data, and the physiology of the GI tract into the development of 71 PBPK models. As such, PBPK modeling has become a promising tool in predicting systemic 72 drug exposure (Kostewicz et al. 2014a) and has been used for dose selection, food effect 73 assessment, and drug interaction potential evaluation (Wagner et al. 2015a; Wagner et al. 2016; 74 Huang et al. 2013; Wagner et al. 2015b). 75 76 77 III. IMPLEMENTATION OF PBPK MODELING FOR BIOPHARMACEUTICS 78 APPLICATIONS 79 80 The application of PBPK modeling could be expanded to pharmaceutical drug product 81 development, manufacturing changes, and controls. One feasible approach is to combine an in 82 vitro drug product test (e.g., biopredictive dissolution) with PBPK models where in vitro 83 dissolution data provide input to predict absorption (Heimbach et al. 2019). As such, dissolution 84 testing is a key modeling input, because it probes both the extent and rate of in vivo drug product 85 release. 86 87 The purpose of PBPK analyses for biopharmaceutics applications is to combine dissolution 88 modeling/biopredictive dissolution or other in vitro testing inputs with PBPK modeling strategies 89 to quantitatively describe (or characterize) the potential interactions of formulation variants with 90 the body and their effect on drug exposure. This modeling approach should include relevant 91 mechanisms pertaining to the absorption process, such as GI tract local metabolism (if 92 applicable) and drug transport, and incorporate drug product quality properties to predict 93 systemic drug exposure. 94 95 7 In addition to waiver of an in vivo BE requirement under 21 CFR 320.22, there are certain circumstances in which BE can be evaluated using in vitro approaches under 21 CFR 320.24(b)(6). The scientific principles described in this guidance regarding waiver of an in vivo requirement also apply to consideration of in vitro data under that regulation. In such circumstances, an in vivo data requirement is not waived, but rather, FDA has determined that in vitro data is the most accurate, sensitive, and reproducible approach for establishing BE, as required under 21 CFR 320.24(a). Nonetheless, for ease of the reader, this guidance refers to either the decision to waive an in vivo BE requirement under 21 CFR 320.22 or the decision to accept in vitro BE data in accordance with 21 CFR 320.24(a) as a biowaiver.
Contains Nonbinding Recommendations Draft — Not for Implementation 4 With these mechanistic elements defined, PBPK modeling for biopharmaceutics applications 96 could predict the effect of variations from the CMAs, CPPs, and CQAs on drug exposure toward 97 the establishment of a safe space via either IVIVCs or in vivo-in vitro relationships combined 98 with virtual BE. A safe space (Abend 2018) is defined by the boundaries demarcated by in vitro 99 specifications (i.e., dissolution or, when applicable, other relevant drug product quality 100 attributes), within which drug product variants are anticipated to be bioequivalent to one another. 101 Less optimally, but still possible (e.g., for modified-release (MR) formulations with appropriate 102 additional supporting data), safe space represents specifications within which drug product 103 variants are anticipated to be bioequivalent to the pivotal clinical batch(es).8 Building a safe 104 space may also reduce the need for in vivo data to support regulatory assessment.9 Although safe 105 spaces can be used for new and generic drug products, building a safe space for a generic drug 106 product necessitates the identification of a range of virtual dissolution profiles within which the 107 proposed drug products are found to be bioequivalent to one another and to the reference or 108 target drug product (e.g., via virtual BE analysis). Also, the range of virtual dissolution profiles 109 should contain the target (i.e., biobatch or pivotal clinical batch) dissolution profile. 110 111 The implementation of PBPK analyses for biopharmaceutics applications to support drug 112 product quality should consider a risk-based approach (e.g., Kuemmel et al. 2020) and 113 contemplate several factors such as: (1) whether in vivo dissolution (as opposed to permeability) 114 is the rate-limiting step toward drug absorption; (2) the in vitro and in vivo data collected to 115 develop, verify, and validate10 the proposed model; and (3) the complexity of the drug product 116 formulation. For example, the use of PBPK analyses for biopharmaceutics applications to 117 support major manufacturing changes for immediate-release (IR) drug products containing high 118 solubility APIs generally is not warranted.11 119 120 121 8 If a clinical investigation (i.e., any experiment other than a BA study in which a drug is administered or dispensed to, or used on, human subjects) is necessary to demonstrate the safety or effectiveness of a proposed drug product, generally this type of study goes beyond the scope of information that may be relied upon as necessary for approval in an abbreviated new drug application (see 21 CFR 314.108(a) and the guidance for industry Determining Whether to Submit an ANDA or a 505(b)(2) Application (May 2019)). However, for ease of the reader, use of the term clinical in this guidance may refer to clinical investigations conducted to support the demonstration of safety or effectiveness in a drug product submitted in a new drug application, or to in vivo studies submitted to support a demonstration of BE or other requirements under section 505(j) of the Federal Food, Drug, and Cosmetic Act and FDA’s implementing regulations. 9 See for example 21 CFR 320.25(a) (“[t]he basic principle in an in vivo bioavailability study is that no unnecessary human research should be done”). 10 In the most general terms, verification refers to an assessment of model components, for example by examining computer codes and equations, to evaluate whether they accurately implement model assumptions; and validation refers to an assessment of the model performance in comparison with observed in vivo data. 11 See the guidance for industry Dissolution Testing and Acceptance Criteria for Immediate-Release Solid Oral Dosage Form Drug Products Containing High Solubility Drug Substances (August 2018).
Contains Nonbinding Recommendations Draft — Not for Implementation 5 IV. DEVELOPMENT AND EVALUATION OF PBPK MODELS FOR 122 BIOPHARMACEUTICS APPLICATIONS 123 124 A. General Strategy 125 126 The general recommended process of developing (Zhang et al. 2011), evaluating, and applying a 127 PBPK model for biopharmaceutics applications for an oral dosage form is presented in Figure 1 128 and described in this section and section V., PBPK Modeling for Biopharmaceutics Applications 129 to Support Product Quality. 130 131 A complete study report of the modeling and simulation work using a PBPK model for 132 biopharmaceutics applications should be submitted to FDA for evaluation and included in the 133 electronic common technical document Module 5.3.1.3.12 134 135 12 When such a model is used for other purposes, other modules may be more appropriate. For additional information, see the guidance for industry Providing Regulatory Submissions in Electronic Format — Certain Human Pharmaceutical Product Applications and Related Submissions Using the eCTD Specifications (February 2020).
Contains Nonbinding Recommendations Draft — Not for Implementation 6 Figure 1. Recommended Workflow Describing Development and Evaluation of a PBPK 136 Model for Biopharmaceutics Applications 137 138 139 The data needed for model development include, but are not limited to: 140 141 • Drug data comprised of drug substance physicochemical properties; formulation 142 attributes; the drug product release mechanism; the absorption, distribution, metabolism, 143 and excretion properties of the drug product; as well as other relevant clinical data (e.g., 144 BA/BE or other PK data) 145 146 • System data (i.e., anatomical structure and physiological parameters) for the GI tract and 147 other organs and/or tissues, if applicable 148 Model Development (Section IV.B.2) Model Validation (Section IV.B.3) Model Refinement (IV.B.3) Model Application (Section V) Identification of Model Objective(s) (Section IV.B.1) Structure Assumptions Parameters Acceptable? Data collection/integration Model Verification No Yes
Contains Nonbinding Recommendations Draft — Not for Implementation 7 149 • Study design data (e.g., the tested drug product or formulation information, dosing 150 regimen, and study subject population) of the in vivo studies selected for model 151 development and validation. 152 153 B. General Considerations 154 155 The following subsections provide general considerations for model development and evaluation 156 in supporting pharmaceutical quality. 157 158 1. Model Objective(s) 159 160 The specific drug product quality issue(s) or question(s) to be addressed by PBPK modeling for 161 biopharmaceutics applications should be clearly described in the study report. Sponsors should 162 provide an analysis of how the specified quality issue(s) or question(s) affect the PK 163 performance of the drug product, the rationale for conducting the modeling and simulation, as 164 well as any strategies undertaken to mitigate the risk of the change to PK performance. The 165 analysis should also incorporate a description of the level of confidence in the modeling outcome 166 based on additional data available to support the verification and/or validation of the model, and 167 other factors, such as the model application, the therapeutic indication, and the therapeutic 168 window of the drug. FDA will evaluate on a case-by-case basis the adequacy of the model for the 169 intended purpose and data sufficiency for model verification and/or validation. 170 171 2. Model Development 172 173 Model development should consist of the following three general elements. 174 175 a. Model structure 176 177 The model structure should provide a mechanistic framework of drug oral absorption by 178 representing the in vivo drug absorption process and accounting for the relevant product quality 179 attribute(s) that affect drug dissolution and absorption. The construction of an absorption model 180 should consider the model objective(s), as well as multiple factors affecting drug dissolution and 181 absorption and their interactions. These factors include but are not limited to: physicochemical 182 properties of the drug substance; formulation/process characteristics; drug release mechanism; in 183 vivo drug dissolution process; supersaturation and precipitation processes; location and duration 184 of absorption; drug permeation and transport pathway; and the effect of GI tract physiology on 185 absorption. Finally, model construction should consider the supporting data and knowledge 186 available to justify the model structure. Sponsors should also document the approaches taken to 187 integrate quality attributes, such as dissolution, and other factors into the model. 188 189 Because the focus of the model is on in vivo dissolution and absorption, it is appropriate to 190 combine a mechanistic absorption model with a simplified disposition model (e.g., a classic 191 compartmental PK model or a reduced PBPK model that lumps tissue/organ compartments) for 192 the prediction of systemic exposure following absorption. Such simplification is recommended if 193 it does not compromise the ability to adequately describe processes governing the drug BA. 194
Contains Nonbinding Recommendations Draft — Not for Implementation 8 When drug disposition involves complexity (e.g., nonlinear PK, saturation of clearance 195 pathway), we recommend an alternative approach, such as incorporating enzyme kinetics in the 196 disposition model. Any modification to the initial model structure should include sufficient 197 justification (e.g., the addition of structural elements may be supported by comprehensive 198 sensitivity analyses and/or appropriate proof that clearly demonstrates the significance of the 199 metrics of interest). 200 201 b. Model assumptions 202 203 The assumptions that underly the model structure and parameters should be clearly presented 204 (e.g., the assumptions made upon drug disintegration, dissolution, precipitation, degradation, 205 transport, first-pass effect, distribution, and clearance). The assumptions should be scientifically 206 justified with supportive information and data, when available. The effect of these assumptions 207 on model structure and/or parameter(s) should be described. 208 209 c. Model parameters 210 211 The approach taken to incorporate drug product quality attributes into the model and the 212 selection of parameters and parameter values as model inputs should be clearly presented and 213 scientifically justified. Selection and evaluation of CMAs (such as drug substance 214 physicochemical properties and excipient(s) level), CPPs (such as compression force), and CQAs 215 (such as hardness, disintegration, and in vitro dissolution) as model inputs should consider 216 whether these attributes and parameters can affect drug in vivo dissolution and absorption. 217 218 3. Model Validation and Refinement 219 220 The predictive performance of a model should be validated for its intended purpose. Depending 221 on the clinical risk and the intended purpose, the amount and type of data needed for model 222 validation may vary. Independent datasets not used in model development are recommended to 223 evaluate the predictive performance of the model. In general, for addressing pharmaceutical 224 development and quality issues, the adequacy of the model to predict the effect of model inputs 225 on the PK performance of the studied drug product should be demonstrated by establishing a 226 clear rank-order relationship between in vitro testing (e.g., in vitro release/dissolution) and in 227 vivo PK study results. 228 229 To increase confidence in the model, we strongly recommend that sponsors demonstrate the 230 model’s predictive performance based on PK data from batches exhibiting unacceptable BA, in 231 addition to those that exhibited acceptable BA (compared to a target and/or reference product). 232 In this context, BA would be considered unacceptable when, based on BE criteria, the 90 percent 233 confidence interval of the test-to-reference geometric mean ratio of C max and AUC fall outside 234 the range of 80 to 125 percent. Model validation acceptance criteria should be established a 235 priori and the criteria should be appropriate for the specified application. For instance, the 236 acceptance criteria for a mechanistic IVIVC model to support biowaiver should comply with the 237 criteria provided in the guidance for industry Extended Release Oral Dosage Forms: 238 Development, Evaluation, and Application of In Vitro/In Vivo Correlations. 239 240
Contains Nonbinding Recommendations Draft — Not for Implementation 9 To demonstrate model predictive performance, sponsors should provide graphical and numerical 241 comparisons of the predicted and observed in vivo drug concentrations (e.g., in plasma) versus 242 time profiles as well as PK parameter estimates (e.g., C max, Tmax, and AUC) and statistical 243 analysis of those estimates (e.g., confidence intervals). Any significant deviation of the model 244 prediction from clinical PK observation (e.g., failure to meet pre-defined model acceptance 245 criteria) will be subject to evaluation by FDA. 246 247 When model refinement or optimization is necessary, we recommend uncertainty analyses on 248 model structure and parameters. Such analyses can be performed by reevaluation of model 249 assumptions and/or parameter sensitivity analysis. The model structure and/or parameters that 250 are modified should be clearly presented and scientifically justified. When a model parameter is 251 optimized, sponsors should provide, in addition to the scientific justification(s) and rationale, the 252 selected initial values and range of parameters, the estimation method and optimization 253 algorithm, and the in vitro and in vivo data used for optimization. 254 255 256 V. PBPK MODELING FOR BIOPHARMACEUTICS APPLICATIONS TO 257 SUPPORT PRODUCT QUALITY 258 259 The in vivo prediction capability provided by PBPK modeling for biopharmaceutics applications 260 allows for a wide array of uses in the pharmaceutical industry, including formulation 261 development, biopredictive dissolution method development, clinically relevant product 262 specifications setting, quality risk assessment, and drug product life cycle management. The 263 implementation of PBPK modeling for biopharmaceutics applications may reduce the number of 264 in vivo BA/BE studies (e.g., due to formulation and/or manufacturing process changes) 265 conducted during the initial approval process, as well as support product scale-up and 266 postapproval changes (SUPAC). The major regulatory uses of PBPK models for 267 biopharmaceutics applications with respect to supporting product quality are presented below. 268 For cases not discussed in this guidance, sponsors are encouraged to contact FDA. 269 270 A. Development of Clinically Relevant Dissolution Specifications (Method and 271 Acceptance Criteria) 272 273 1. Aid in Biopredictive Dissolution Method Development 274 275 Although progress has been made with the use of biorelevant media and appropriate testing 276 conditions to create physiologically based dissolution methods (Kostewicz et al. 2014b), the use 277 of in vitro dissolution data to quantitatively predict drug absorption is challenging. A 278 biopredictive dissolution method can be used to generate a dissolution profile. This profile can 279 be used to predict systemic exposure after oral administration of solid dosage forms (Suarez- 280 Sharp et al. 2018). The dissolution data could be effectively used as a surrogate to assess the 281 clinically relevant effect of drug product variants, thereby streamlining drug product 282 development. 283 284 We encourage development of biopredictive dissolution methods at the early stage of a drug 285 product development program, especially for drug products with dissolution as the rate-limiting 286
Contains Nonbinding Recommendations Draft — Not for Implementation 10 step for absorption, such as MR drug products and IR drug products containing poorly soluble 287 APIs. 288 289 With the mechanistic platform to delineate the complex mechanisms underlying drug absorption, 290 PBPK modeling for biopharmaceutics applications can provide an estimation of a drug product’s 291 in vivo dissolution profile, based on the simulation of in vivo process of drug absorption in the 292 GI tract. Although the estimated in vivo dissolution profile may be used as a reference, 293 understanding of the physicochemical properties of the API and drug product quality attributes, 294 as well as their potential effect on in vivo dissolution, is critical for the development of a 295 biopredictive/clinically relevant dissolution method. The critical physicochemical properties of 296 the API and drug product quality attributes include, but are not limited to: (1) its solubility in 297 aqueous media within physiological pH range (e.g., 1 to 6.8) and/or biorelevant media (e.g., 298 simulated gastric and intestinal fluid mimicking fasted or fed conditions); (2) saturation or 299 supersaturation and precipitation properties; (3) mechanism of release; and (4) the in vitro 300 dissolution characteristics in media at different pH within the physiological range. 301 302 By exploring dissolution methodologies (e.g., medium, apparatus, and hydrodynamics), an in 303 vitro dissolution method can be developed with the intention to predict the in vivo dissolution 304 profile of a drug product. The use of biorelevant dissolution methodology is encouraged as a 305 starting point in the development of a biopredictive dissolution method. 306 307 To evaluate whether a dissolution method is biopredictive, sponsors should incorporate 308 dissolution profiles generated by such method into the PBPK model and the predicted systemic 309 exposure should be comparable (±10 percent) to the observed in vivo PK data. To evaluate the 310 method, we recommend that sponsors use observed in vivo PK data of formulations with 311 different release rates. 312 313 Implementation of a biopredictive method is encouraged for establishing a quality control (QC) 314 dissolution test. If a biopredictive method is determined inappropriate to be employed for routine 315 use (e.g., due to method complexity), an alternative dissolution method can be selected as the 316 primary method for the QC dissolution test while the biopredictive dissolution method can be 317 retained as an alternate testing approach for aiding in quality assessment when needed. For 318 instance, dissolution data from a biopredictive method can supersede the primary QC dissolution 319 testing results to support chemistry, manufacturing, and controls (CMC) changes in terms of 320 maintaining desired in vivo performance. 321 322 2. Support Clinically Relevant Dissolution Acceptance Criteria 323 324 The term clinically relevant dissolution acceptance criteria is defined as a metric that can 325 identify and reject drug product batches that are not bioequivalent to the pivotal clinical drug 326 product (Abend et al. 2018). It often refers to the acceptance criteria set for a dissolution method 327 to minimize the possibility of releasing batches that would have clinical performance differences. 328 A clinically relevant dissolution acceptance criterion can be wider than that set based on the 329
Contains Nonbinding Recommendations Draft — Not for Implementation 11 average dissolution data of pivotal clinical batches (e.g., beyond plus or minus 10 percent 330 variation range for an extended-release (ER) drug product).13 331 332 PBPK modeling for biopharmaceutics applications links in vitro dissolution to PK performance 333 and hence supports the establishment of clinically relevant dissolution acceptance criteria. PK 334 predictions from PBPK models for biopharmaceutics applications (e.g., virtual BE studies) based 335 on in vitro dissolution profile(s) representing the desired limits and/or range of dissolution rate 336 can be used to justify the clinical relevance of proposed acceptance criteria. The approach should 337 consider comparing PK predictions based on in vitro dissolution profile(s) representing the 338 desired dissolution limits and PK predictions based on dissolution profile of pivotal clinical 339 batches (as a reference). Sponsors should consider the following when conducting virtual BE 340 studies: (1) the estimated intra- and intersubject variability for PK parameters (such as C max and 341 AUC) should be representative of the observed intra- and intersubject variability; (2) the number 342 of subjects for virtual BE trials should be justified and comparable to in vivo BE studies; and (3) 343 the number of virtual BE trials used to estimate the probability of concluding BE should be 344 justified. 345 346 If the outcome of the analysis meets BE acceptance criteria, the proposed dissolution acceptance 347 criterion could support clinical relevance. For ER drug products, clinically relevant dissolution 348 acceptance criteria preferably should be set such that all lots/batches that have dissolution 349 profiles within the upper and lower limits of the specification are bioequivalent to one another. 350 Less optimally, lots/batches exhibiting dissolution profiles at the upper and lower dissolution 351 limits should be bioequivalent to the clinical/BA lots/batches or to an appropriate reference 352 standard, but not necessarily to one another.14 For generic drug products, the predicted PK 353 performance corresponding to the upper and lower limits of dissolution should support that 354 product variants are bioequivalent to each other and to the reference listed drug. 355 356 Parameter sensitivity analysis (PSA) also can be performed to evaluate the effect of the 357 dissolution rate change on systemic exposure using validated PBPK models for 358 biopharmaceutics applications, in support of the clinical relevance of proposed dissolution 359 acceptance criteria. 360 361 B. Establishment of Clinically Relevant Drug Product Quality Specifications 362 (Other Than Dissolution) 363 364 QbD is a systematic approach for pharmaceutical development and manufacturing to enhance 365 drug product quality with more consideration of the drug product’s intended use by the patients; 366 nevertheless, it is often challenging to establish clinically relevant specifications for drug 367 substances, excipients, in-process materials, and finished drug products. Current quality testing 368 or control is largely based on in vitro testing/performance (including in vitro dissolution) of 369 clinical, development, and registration batches. Although clinical data alone are often insufficient 370 to inform appropriate drug product specifications, the overall clinical pharmacology and 371 13 See the guidance for industry Extended Release Oral Dosage Forms: Development, Evaluation, and Application of In Vitro/In Vivo Correlations. 14 See the guidance for industry Dissolution Testing of Immediate Release Solid Oral Dosage Forms.
Contains Nonbinding Recommendations Draft — Not for Implementation 12 biopharmaceutics information gathered during drug product development can be leveraged for 372 the development of PBPK models for biopharmaceutics applications. These models may help in 373 establishing a desired in vitro-in vivo link, a key element in building clinical relevance for drug 374 product quality attributes. 375 376 Provided that the quality attributes and process parameters are incorporated either directly or 377 indirectly in the model, the effect of these attributes and parameters on in vivo dissolution and 378 absorption can be assessed. The quality attributes can include: (1) drug substance quality 379 attributes (e.g., particle size distribution, physical form, polymorphic form); (2) excipient quality 380 attributes (e.g., type and/or level of release rate controlling excipient); (3) in-process quality 381 attributes (e.g., granule particle size, coating weight gain); and (4) finished drug product 382 attributes (e.g., disintegration). Manufacturing process parameters include, but are not limited to, 383 coating parameters and compression force. A biopredictive dissolution profile can be used to 384 assess the in vivo effect of the quality attributes and process parameters that cannot be directly 385 input into the model. 386 387 Similar to setting clinically relevant dissolution acceptance criteria, clinically relevant drug 388 product specifications for quality attributes other than dissolution can be established based on 389 modeling predictions to ensure BE of batches within the specification limits to the pivotal 390 clinical/BA batches (see section V.A.2., Support Clinically Relevant Dissolution Acceptance 391 Criteria) or to the reference listed drug for generic drugs. 392 393 C. Quality Risk Assessment for Pre- and Postapproval Changes and Risk-Based 394 Biowaivers 395 396 Sponsors can employ PBPK analyses for biopharmaceutics applications as an advanced tool for 397 quality risk assessment and management in pharmaceutical development and drug product life 398 cycle. Specifically, enhanced understanding can be provided by the modeling approach on how 399 quality attributes affect clinical performance, thereby aiding in risk assessment as part of 400 formulation and process development and the establishment of the control strategy, as well as 401 supporting postapproval changes. 402 403 The use of PBPK analyses for biopharmaceutics applications at pre- and postapproval stages can 404 include: 405 406 • Preapproval Stage 407 408 ‒ Establishing clinically relevant manufacturing design space and control strategy to 409 mitigate quality risks in support of patient-centric drug product development 410 411 ‒ Bridging clinical batches to the to-be-marketed commercial product accounting for 412 the CMC changes such as formulation, manufacturing process, and manufacturing 413 site changes made during pharmaceutical development 414 415
Contains Nonbinding Recommendations Draft — Not for Implementation 13 • Post-approval Stage 416 417 ‒ Conducting risk assessment/risk classification as per SUPAC and/or the draft ICH 418 guidances for industry Q12 Technical and Regulatory Considerations for 419 Pharmaceutical Product Lifecycle Management: Core Guideline (November 2017) 420 and Q12 Technical and Regulatory Considerations for Pharmaceutical Product 421 Lifecycle Management: Annex (November 2017)15 on postapproval CMC changes 422 such as formulation, manufacturing process, and manufacturing site changes 423 424 ‒ Supporting biowaivers for postapproval changes 425 426 Risk assessment can be performed using the same approach as illustrated in section V.A. and B. 427 in setting clinically relevant drug product specifications. In this regard, model prediction(s) or 428 PSA results may be used to support high-impact CMC changes that may otherwise need an in 429 vivo BE study per the guidances for industry Immediate Release Solid Oral Dosage Forms 430 Scale-Up and Postapproval Changes: Chemistry, Manufacturing, and Controls, In Vitro 431 Dissolution Testing, and In Vivo Bioequivalence Documentation and SUPAC-MR: Modified 432 Release Solid Oral Dosage Forms Scale-Up and Postapproval Changes: Chemistry, 433 Manufacturing, and Controls; In Vitro Dissolution Testing and In Vivo Bioequivalence 434 Documentation (September 1997). FDA may grant a biowaiver request supported by PBPK 435 modeling for biopharmaceutics applications after evaluation of the outcome of the risk 436 assessment, the level of impact of the proposed change, and the totality of the provided 437 information. 438 439 15 When final, these guidances will represent the FDA’s current thinking on these topics.
Contains Nonbinding Recommendations Draft — Not for Implementation 14 GLOSSARY 440 441 Biopharmaceutics: The study of the physical and chemical properties of a drug, its dosage form, 442 and formulation, as related to the onset, duration, and intensity of drug action. 443 444 Biopredictive dissolution method: A set of testing conditions for which in vitro dissolution 445 profiles are capable of predicting PK profiles. These are typically based on classical or 446 mechanistic IVIVC. 447 448 Biorelevant dissolution method: A set of testing conditions (e.g., media and hydrodynamics) 449 for monitoring in vitro dissolution designed to closely mimic a relevant biological fluid and a 450 physiological environment. 451 452 Clinically relevant dissolution specification: A specification that takes into consideration the 453 clinical effect of variations in dissolution ensuring a consistent safety and efficacy profile. 454 455 Critical process parameter (CPP): A process parameter whose variability has an effect on a 456 CQA and therefore should be monitored or controlled to ensure the process produces the desired 457 quality.16 458 459 Critical quality attribute (CQA): A physical, chemical, biological, or microbiological property 460 or characteristic that should be within an appropriate limit, range, or distribution to ensure the 461 desired drug product quality.17 CQAs are generally associated with the drug substance, 462 excipients, intermediates (in-process materials), and drug product. 463 464 Design space: The multidimensional combination and interaction of input variables (e.g., 465 material attributes) and process parameters that have been demonstrated to ensure quality. 466 Working within the design space is not considered to be a change. Movement out of the design 467 space is considered to be a change and would normally initiate a regulatory postapproval change 468 process. Design space is proposed by the sponsor and is subject to regulatory assessment and 469 approval.18 470 471 In vitro/in vivo correlation (IVIVC): A predictive mathematical model describing the 472 relationship between an in vitro property of an ER dosage form (usually the rate or extent of drug 473 dissolution or release) and a relevant in vivo response (e.g., plasma drug concentration or amount 474 of drug absorbed).19 475 476 In vitro-in vivo relationship: A qualitative rank-order relationship between a relevant in vivo 477 response and in vitro release profiles. 478 16 See ICH Q8(R2). 17 Ibid. 18 Ibid. 19 See the guidance for industry Extended Release Oral Dosage Forms: Development, Evaluation, and Application of In Vitro/In Vivo Correlations.
Contains Nonbinding Recommendations Draft — Not for Implementation 15 479 Parameter sensitivity analysis (PSA): A series of analyses targeting the same estimand, with 480 differing assumptions to explore the robustness of inferences from the main estimator to 481 deviations from its underlying modeling assumptions and limitations in the data.20 482 483 Physiologically based pharmacokinetic (PBPK) analysis: An analysis using models and 484 simulations that combine physiology, population, and drug characteristics to mechanistically 485 describe the PK and/or pharmacodynamic behaviors of a drug product.21 486 487 Risk assessment: A systematic process of organizing information to support a risk decision to be 488 made within a risk management process. It consists of the identification of hazards and the 489 analysis and evaluation of risks associated with exposure to those hazards.22 490 491 Safe space: Boundaries defined by in vitro specifications, such as dissolution or other relevant 492 drug product quality attributes, within which drug product variants are anticipated to be 493 bioequivalent to one another. 494 20 See the draft ICH guidance for industry E9(R1) Statistical Principles for Clinical Trials: Addendum: Estimands and Sensitivity Analysis in Clinical Trials (June 2017). When final, this guidance will represent the FDA’s current thinking on this topic. 21 See the guidance for industry Physiologically Based Pharmacokinetic Analyses — Format and Content. 22 See the ICH guidance for industry Q9 Quality Risk Management (June 2006).
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