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FOOD AND DRUG ADMINISTRATION
CENTER FOR DRUG EVALUATION AND RESEARCH
OFFICE OF MEDICAL POLICY
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DRAFT GUIDANCES RELATING TO THE
DEVELOPMENT OF BIOSIMILAR PRODUCTS
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PART 15 PUBLIC HEARING
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FRIDAY
MAY 11 2012
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The Hearing convened at the Food
and Drug Administration White Oak Campus
Building 31 Room 1503 10903 New Hampshire
Avenue Silver Spring Maryland at 830 am
Rachel Sherman Presiding Officer presiding
PANEL MEMBERS
RACHEL SHERMAN MD MPH Associate
Director for Medical Policy Center for Drug
Evaluation and Research Presiding Officer
LEAH CHRISTL PhD Associate Director for
Biosimilars Office of New Drugs Center for
Drug Evaluation and Research
DENISE ESPOSITO JD Deputy Director Office
of Regulatory Policy Center for Drug
Evaluation and Research
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PANEL MEMBERS STEVEN KOZLOWSKI MD Director Office of Biotechnology Products Office of Pharmaceutical Science Center for DrugEvaluation and Research
DIANE MALONEY JD Associate Director for Policy Office of the Center Director Centerfor Biologics Evaluation and Research
HEIDI C MARCHAND PharmD Assistant Commissioner Office of Special Health IssuesOffice of the Commissioner
MARYLL TOUFANIAN JD Associate Chief Counsel for Drugs Office of the Chief Counsel Office of the Commissioner
ROBERT A YETTER PhD Associate Director for Review Management Center for BiologicsEvaluation and Research
PRESENTERS
ROBERT YAPUNDICH MD Alliance for Patient Access ANDREW R SPIEGEL ESQ Colon Cancer Alliance ALEXEY SALAMAKHA Global Healthy Living Foundation
MARCIA BOYLE Immune Deficiency Foundation
DOLPH CHIANCHIANO JD MPA National Kidney Foundation IncRENE CABRAL-DANIELS National Patient Advocate Foundation
AL CORS RetireSafe PRESENTERS
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RICHARD DOLINAR MD The Alliance for Safe Biologic Medicines
SHEIN-CHUNG CHOW PhD Duke University
School of Medicine
MARCIE BOUGH PharmD American Pharmacists
Association
EVERETT NEVILLE Express Scripts
KRISTIN BASS Pharmaceutical Care Management
Association
NEAL PARKER ESQ Abbott Laboratories
JOSEPH P MILETICH MD PhD Amgen Inc
MICHELLE ROHRER PhD Genentech a Member of
the Roche Group
SUMANT RAMACHANDRA MD PhD MBA
Hospira Inc
JAY P SIEGEL MD Janssen RampD Inc
JAMES ROACH MD Momenta Pharmaceuticals
Inc
PATRICK VINK Mylan Inc
JAMES C SHELAN Novo Nordisk Inc
F OWEN FIELDS PhD Pfizer
MARK MCCAMISH MD PhD Sandoz International GmbH a Novartis CompanyKARL HEINZ EMMERT PhD Teva Global Branded Products Merckle GmbH Teva Group Member
PRESENTERS
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RONALD A RADER Biotechnology Information Institute
MICHAEL STRAUSS PhD CBR International CorporationBRUCE BABBITT PhD PAREXEL International LLC
SARA RADCLIFFE Biotechnology IndustryOrganizationCORNELIA ULM European Generic Medicines Association
KRISTIN VAN GOOR PhD RAC Pharmaceutical Research amp Manufacturers of America
OPEN PUBLIC COMMENTERS
JAMES E SYKES MPH HealthHIV
ANDREW SPERLING JD National Alliance on Mental Illness KALYAN R ANUMULA PhD Therapeutic ProteinsInternational LLC
GREGORY DAVIS PhD Eli Lilly and Company
AHAVIAH DIANE GLASER JD Generic Pharmaceutical Association
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CONTENTS Presiding Officer Opening Remarks
Rachel Sherman MD MPH 8
PRESENTATIONS
Robert Yapundich MDAlliance for Patient Access 15
Andrew R Spiegel EsqColon Cancer Alliance 28
Alexey SalamakhaGlobal Healthy Living Foundation 40
Marcia BoyleImmune Deficiency Foundation 50
Dolph Chianchiano JD MPANational Kidney Foundation Inc
Rene Cabral-Daniels 64
National Patient Advocate Foundation 75
Al Cors RetireSafe 86
Richard Dolinar MD The Alliance for Safe BiologicMedicines 95
Shein-Chung Chow PhDDuke University School of Medicine 107
Marcie Bough PharmDAmerican Pharmacists Association 119
Everett Neville Express Scripts 135
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CONTENTS (Cont)
Kristin Bass
Pharmaceutical Care Management
Neal Parker Esq
Association 148
Abbott Laboratories 158
Joseph P Miletich MD PhD
Amgen Inc 174
Michelle Rohrer PhD
Genentech a Member of the Roche
Sumant Ramachandra MD PhD MBA
Group 188
Hospira Inc 204
Jay P Siegel MD
Janssen RampD Inc 216
James Roach MD
Momenta Pharmaceuticals Inc 232
Patrick Vink
Mylan Inc 246
James C Shehan
Novo Nordisk Inc 261
F Owen Fields PhD
Pfizer 271
Mark McCamish MD PhD
Sandoz International GmbH a
Karl Heinz Emmert PhD
Teva Global Branded Products
Novartis company 287
Merckle GmbH - Teva Group Member 302
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CONTENTS (Cont)
Ronald A Rader
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Biotechnology Information
Institute 316
Jeanne Novak PhD and
Michael Strauss PhD
CBR International Corporation
Bruce Babbitt PhD
PAREXEL International LLC
324
333
Sara Radcliffe
Biotechnology Industry
Organization 347
Cornelia Ulm
European Generic Medicines
Association 360
Kristin Van Goor PhD RAC and
Sascha Haverfield PhD
Pharmaceutical Research amp
Manufacturers of America 367
Open Public Comments
Closing RemarksAdjournment
376
410
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P-R-O-C-E-E-D-I-N-G-S
(832 am)
PRESIDING OFFICER SHERMAN Good
morning We would like to welcome both the
attendees in the Conference Center and those
viewing the hearing through our live webcast
Welcome to the Part 15 hearing on the Draft
Guidances Related to the Development of
Biosimilar Products
I am Rachel Sherman Associate
Director for Medical Policy Center for Drug
Evaluation and Research at the FDA I will
serve as presiding officer for this hearing
And before I go on with the other
scripted announcements I will ask the
panelists to introduce themselves
PANEL MEMBER KOZLOWSKI Steven
Kozlowski Director of the Office of
Biotechnology Products in CDER
PANEL MEMBER ESPOSITO Denise
Esposito from the Office of Regulatory Policy
in CDER
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PANEL MEMBER CHRISTL Leah
Christl Associate Director for Biosimilars
Office of New Drugs CDER
PANEL MEMBER MALONEY Diane
Maloney Associate Director for Policy CBER
PANEL MEMBER MARCHAND Hello
Heidi Marchand Assistant Commissioner for the
Office of Special Health Issues of the Office
of the Commissioner
PANEL MEMBER TOUFANIAN Good
morning Im Maryll Toufanian Associate
Chief Counsel for Drugs in the Office of the
Chief Counsel
PANEL MEMBER YETTER Bob Yetter
Im the Associate Director for Review
Management in the Center for Biologics
PRESIDING OFFICER SHERMAN Before
we begin I will provide a few housekeeping
announcements
Please turn off any mobile
devices as they may interfere with the audio
in this room We ask that all attendees sign
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in The meeting is scheduled from 830 am
until 500 pm today and I will have another
comment on that in a moment
Restrooms are located in the lobby
to the left and the right hallways We are
planning for one 15-minute break during the
morning session and one 15-minute break during
the afternoon session Lunch break is from
1200 to 100 There will be sandwiches
salad and beverages available for purchase in
the lobby
The purpose of the hearing today
is to obtain broad stakeholder input on three
recently issues draft guidances relating to
the development of biosimilar products FDA
has issued the following draft guidances as
part of its initial implementation of the
Biologics Price Competition and Innovation Act
of 2009 the BPCI Act
The first is scientific
considerations in demonstration biosimilarity
to a reference product The second is
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questions and answers regarding implementation
of the BPCI The third is quality
considerations in demonstrating biosimilarity
to a reference protein product
FDA will consider the information
obtained from the public hearing in finalizing
these guidances In addition and this is
actually very crucial to us we are interested
in obtaining public input about the agencys
priorities for the development of future
policies surrounding biosimilars We
obviously have a limited number of resources
to devote to any one issue including
biosimilars
Turning to the speakers and the
agenda We have agenda speakers from about 30
organizations with scheduled slots In order
to keep the agenda as closely on time as
possible I will go over some ground rules
First this meeting is informal
The Rules of Evidence do not apply No
participant may interrupt the presentation of
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another participant Only FDA Panel Members
will be allowed to question a presenter
FDA may recall a presenter for
additional questions at the end of the day
assuming time allows and the presenter remains
available And this is actually quite useful
to us I believe Ms Esposito holds the
record for recalling three panelists at the
same time and having a very interesting
compared and contrast of views So if you are
able please do stay with us
Public hearings under Part 15 are
subject to FDAs policies and procedures for
electronic media coverage of FDAs public
administrative proceedings Representatives
of the electronic media may be permitted
subject to certain limitations to videotape
film or otherwise record FDAs public
administrative proceedings including the
presentations of the speakers today
This meeting will be transcribed
and copies of the transcript may be ordered
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through the docket or accessed on our website
approximately 30 days after this public
hearing
Each speaker has been given an
eight-minute time slot on the agenda with
five additional minutes allotted for the FDA
Panel Members to ask questions And that is
our only opportunity to question you We will
carefully scrutinize everything submitted to
the docket but the only opportunity we have to
ask you clarifying questions is today
So if any speaker goes over the
eight-minute slot the time allowed to
question will be reduced accordingly If a
speaker ends early we intend to go on to the
next speaker As I said if there are
additional questions at the end we would
recall the speaker
For those of you who did not
register to make an oral presentation but
would like to present your comments and we
did hear from a number of you after the
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registration period closed you may speak
during the open public comment period at the
conclusion of the hearing Those interested
in presenting during this open public comment
period but who have not expressed interest
please see Sandra Benton who is standing in
the back of the room you probably all know
her by now by the end of the first break to
be added to this list
And in the interest of
accommodating as many speakers as possible we
will extend this comment period longer if
needed Please recognize that that means that
we may well go beyond 500 pm And also
please recognize that with our apologies
there is one panelist who has a fixed prior
time commitment and will not be able to stay
past the allotted time and we apologize for
that
This hearing is not your last
chance to comment The docket will open until
May 25th and we strongly encourage all
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interested parties to comment Please see the
Federal Register notice for details and again
I emphasize the importance of this We
scrutinize these comments very closely They
are extremely helpful to us and I think those
of you that did comment and then read our
guidance can see that they certainly impact
what we say
Given the full agenda we again
request that each speaker keep the allotted
time so we will be able to keep to our very
tight time schedule We thank you for your
interest and your participation We look
forward to a very productive public hearing
We will now begin with
presentations The first speaker and I
apologize in advance if I butcher anybodys
name is Robert Yapundich MD Alliance for
Patient Access
DR YAPUNDICH I commend you on
pronouncing my name correctly Thank you
Good morning and I wish to thank
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the panel for allowing me to express comments
during this public comment period
I am here today actually wearing
two hats The first as a member and
representative of the Alliance for Patient
Access which I will refer to as AfPA
hereinafter And this is an organization
dedicated to the protection of patient access
to approve medical treatments
And my second hat is as a
neurologist in a small town in North Carolina
in private practice And I have experienced
the good and the bad of generic equivalents
And I strongly desire access to the most
effective and safe therapies for my patients
As the FDA formalizes by a similar
approval process the AfPA has a strong
interest in ensuring this is a safe and
balanced process We ask that you recognize
the unique complexities of each biologic
agent that you ensure patient safety through
rigorous testing and monitoring process of
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biologics and that also we ask that this
pathway be one that promotes access by
protecting and prescribing autonomy for all
practitioners
We recognize that the challenges
in perfecting a biosimilars pathway in many
ways is based on a biologic agents unique and
complex nature First of all the biological
molecules are often produced in cell cultures
And even small variations in how the cells
are grown can change the properties of the
protein produced For this reason any
comprehensive biosimilars pathway should
account for a variety of factors and I list
these up here They should be highly these
are highly sensitive in nature to the
biologics And because many of these
biologics are proteins they are significantly
larger than traditional pharmaceuticals
exceptionally sensitive to heat light and
being denatured by agitation
Also the dosing safety and
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efficacy is an important point determining and
ensuring these biologics and biosimilars is an
entirely different undertaking when compared
to the usual procedures for traditional small
molecule pharmaceuticals
And then finally the biological
therapies are costly The complexity inherent
in the manufacturing process of the biological
therapies results in high cost to patients as
well as the payers
Ultimately the ideal biosimilars
pathway should incorporate three main
elements One is patient safety it should be
affordable and again allow patient access
As the FDA moves forward in this
process the AfPA asks that the following
elements be incorporated into the approval
process of every biosimilar agent The first
is clinical trials These we feel should be
mandatory for each biosimilar product even if
it contains the same biologically active
component as a product that is already on the
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market
We feel that the FDA should
require animal toxicity in human clinical
trials evaluating the safety and efficacy as
these drugs carry the added risk of triggering
an immune response that can sometimes be life-
threatening
The second is the monitoring
aspect We feel that each step of the
manufacturing process must be monitored with
robust tracking system and includes unique
proprietary names and lot numbers And also a
comprehensive labeling system that must be
implemented to allow the precise tracking of
an individual dose of biological product to a
specific manufacturer Obviously if an
individual were to have an adverse event we
would want to be able to track exactly where
that may have come from
The third is the
interchangeability determinations These
should be made only after a biosimilar product
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has been fully investigated in the premarket
clinical trials and then been utilized in the
United States post-market in a sufficient
number of patients over a long enough period
of time to reflect its performance type in the
clinical practice
We feel that the pre- and the
post-market surveillance of these products is
very important Because of the diversity of
the biological products interchangeable
standards and determinations must be very
narrowly defined and there should be no
vagueness left in this for each specific class
of therapeutics
And then finally which is
important to me is the physician-patient
relationship and the physician clinical
decision-making process must be preserved
This is something I battle every day as a
practitioner Insurers and other third
parties must not be empowered to dictate what
therapies physicians can prescribe and what
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therapies patients can access
Only the physicians not the
insurers or other third parties have the
medical education and the understanding of
their patients needs that are necessary to
safely prescribe these very powerful
therapies
I am going to close and just share
a few disclosures about myself I have listed
up here my education my practice I do want
to mention that I have used biologics in my
practice in a variety of conditions I use
IVIG for myasthenia CIDP other conditions
botulinum toxins and interferons as well
At the bottom of my disclosures I
have served as a speaker as well as a
consultant for a variety of pharmaceutical
companies Some of these have used biologics
many of them do not
A little bit about the Alliance
for Patient Access We are a national network
of 400 physicians Our mission is to gain and
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protect patient access to approved medical
treatments including prescription
pharmaceuticals biologics and medical
devices This is our website
In 2011 we launched a group called
the National Physicians Biologics Working
Group And there is a white paper and web
video available at this website
In regards to our funding we are
funded by a variety of grants donations and
associate memberships These are the
financial supporters of AfPA listed here
Finally in summary many
individuals both patients and providers are
looking at the FDA to adhere to its core
mission of protecting the public health by
assuring the safety effectiveness and the
security of biological products To this end
we ask that you recognize the unique
complexities of each biologic agent that you
help ensure patient safety through rigorous
testing and monitoring the process of
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biologics And finally as I mentioned
previously help us protect in prescribing
autonomy for all practitioners
Thank you
PRESIDING OFFICER SHERMAN Thank
you and thank you for getting us off to a good
start and being ahead of schedule
I will turn to the panel now to
see who has questions
PANEL MEMBER TOUFANIAN Thank you
for your presentation I was hoping you could
elaborate a little more about your concerns
with respect to the insurers or third-party
role and how you see the Agency involved in
that consideration
DR YAPUNDICH This is something
I battle every day I am in a small town
Our practice is we have about eight providers
I have one full-time person in my practice
whose only role is to deal with
preauthorizations for products
So in other words as
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practitioners we may see a patient We
evaluate that patient We feel that the
product that we would work for best for that
patient we want to prescribe and then the
insurance companies deny that They deny it
and oftentimes it is very interesting here
they deny it and they want us they force our
hand to use an agent that is not FDA-approved
first before we can use the FDA-approved
agent Its crazy
And so this is what I mean a lot
by the prescribing autonomy This is
something every day that we battle and it is
getting worse and worse
PANEL MEMBER TOUFANIAN And in
terms of FDA considering those issues do you
foresee a role of FDA bringing it sort of at
this Part 15 hearing do you see FDA inserting
themselves into something like that
DR YAPUNDICH No I recognize
this may be out of the auspices of the FDA but
I think that again as the FDA goes through
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Page 25
this biosimilars pathway anything you can do
to ensure that that agent that I may be forced
to utilize is as similar as possible to the
referenced product would be very much
appreciated
I very commonly on a weekly -- in
fact just this past Wednesday I was on-call
and I had a person show up to the emergency
room this actually happens almost every week
taking their agent This is not a biologic
agent This was another generic product for
seizures And they had seizures They are
taking their medicine and the patient didnt
know I didnt know that they had been
switched from their brand name to their
generic And this is a common problem that we
see You know the generics are very like I
said earlier in my presentation they are good
and they are bad I mean I have many
patients who wouldnt have their conditions
treated if it wasnt for the generic agents
but I have a number of patients whose
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Page 26
condition actually gets worse because of the
switching that may occur without my knowledge
and without the patients knowledge
PANEL MEMBER KOZLOWSKI Dr
Yapundich in your presentation you mentioned
that there should be mandatory trials and you
also mentioned that there should be class-
specific standards that are narrowly defined
So I wondered whether analytical similarity
plays any role in your thoughts on those
bullets basically
DR YAPUNDICH Yes And I think
the analytical aspect of this is very
important but I think you cannot rely on that
totally We are talking again about a class
of agents that is very unique and not similar
-- not identical to the routine pharmaceutical
agents that we utilize So these are agents
that are obviously grown in cell cultures and
even a small variation can result in an agent
down the line that triggers and immune
response and a very different outcome
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So again I think the analytical
process is very important but I think you need
to go a step beyond that And again my
feeling the AfPAs feeling is that clinical
trials need to be done in every one of these
with every one of these products
PRESIDING OFFICER SHERMAN If I
could follow up on Dr Kozlowskis question
Clinical trial it is a very broad spectrum
For example you talked about
interchangeability and you talked about
immunogenicity Are you thinking beyond those
two settings
DR YAPUNDICH No I think that
would suffice
PRESIDING OFFICER SHERMAN Any
other questions Thank you very much for your
comments
DR YAPUNDICH Thank you very
much
PRESIDING OFFICER SHERMAN Our
next speaker is Andrew Spiegel Esquire Colon
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Page 28
Cancer Alliance
MR SPIEGEL Good morning I
would like to thank the panel for providing me
an opportunity to give some remarks on this
important issue In terms of disclosures I
should say that the Colon Cancer Alliance is a
501(c)(3) non-profit organization and as a
non-profit we do rely in part upon the
generosity of industry to help bring our
program to patients In terms of full
disclosures I would say in 2011 we received
less than 10 percent of our budget from the
pharmaceutical industry So not significant
but I thought I should disclose that
So panel thank you for having me
My name is Andrew Spiegel I am the chief
executive officer of the Colon Cancer
Alliance And the Colon Cancer Alliance is
the largest national patient advocacy
organization in America dedicated to
colorectal cancer We are not only the
largest in America but we have recently
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Page 29
launched a venture with our European
counterparts EuropaColon in launching an
international patient advocacy organization
called Global Colon Cancer Alliance So I
believe it is now safe to say that we are the
largest colorectal cancer patient advocacy
organization in the world representing the
12 million Americans who have this disease
and the more than five million people
worldwide who have colon cancer
I come here today to tell you that
I have a personal connection to cancer that I
want to tell you about In 1999 I lost my
mother to colon cancer two days after losing
my father to pancreatic cancer So I
certainly know the devastating effects that
cancer can have on a family I was 35-yearsshy
old at that time And at the time we are
going back about 12 13 years now there were
very few treatment options for colon cancer
patients as well as pancreatic cancer
patients That remains true today by the
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way There have been only -- there is only
about six or seven approved drugs for
colorectal cancer and there has not been a new
drug approved in six years
Many do not realize that colon
cancer is the second leading cause of cancer
deaths in America and worldwide when you
combine the sexes The second leading cause
of cancer death not only in America but
worldwide and this is responsible for 50000
deaths in America each year and more than
600000 deaths worldwide
Pancreatic cancer by the way is
one of the fastest growing cancers in this
country and worldwide and these two cancers
alone account for more than 20 billion dollars
a year in treatment costs
We know that in this country
cancer is an epidemic One out of every two
men will develop cancer in their lifetime
One out of every three women will get cancer
So one thing is clear there is a
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great need for safe and effective therapies
and we know this because as our population is
aging and people are living longer lives the
number of Americans getting cancer in the
future will be beyond our wildest current
imagination In fact when talking about
colon cancer a recent study by the Lance
Armstrong Foundation predicted that by the
year 2020 colon cancer will be the number one
cause of cancer death worldwide As more
developing countries become more westernized
and as people stop smoking and lung cancer
incidents go down they do expect colon cancer
to become the number one cause of cancer death
in only seven years
I came here today to thank the FDA
for the cautious approach that it is taking to
establish a pathway that will bring
biosimilars to patients in the United States
And it is clear from the draft guidance that
the administration is following in the
footsteps of the European counterparts in
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using a science-based approach that refuses to
compromise on patient safety And that is my
point today that these drugs have to be safe
To that end we are encouraged to
see that the FDAs progress in creating an
approval process for biosimilars in the US
and we view the Agencys draft guidelines as
another important step toward providing a safe
biosimilars marketplace for Americas
patients
As patient advocates our role is
to always try to get drugs cheaper We always
want to reduce costs and that is extremely
important for the patients that we represent
yet the number one concern is that patients
must be assured that these medications are not
only effective but that they are safe The
last thing a cancer patient needs to hear is
that a medication that they know works is not
working on them because of a problem with the
medication
So it is important the FDA
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recognize the inherent safety challenges
associated with biologic medicines and mandate
clinical testing of biosimilars to ensure
that they are as safe and as effective as the
approved products that are already on the
market
We also believe that the FDA
should place safeguards that will ensure
patients and physicians know what medications
that they are receiving and that are being
prescribed Patients have the right to know
exactly what is being put in their bodies
One way to do this would be a unique naming
system that includes nonproprietary names for
biologics and biosimilars so that physicians
patients and regulators can easily
differentiate products
Since physicians will know whether
they are prescribing a biologic or a
biosimilar and the physician will fully
understand their patients specific needs the
pharmacy should fill the doctors request as
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written or at a minimum at least notify the
physician within a reasonable period of time
that a substitution has occurred And I think
that sort of addresses I dont -- I cant
see your name here but I think you were
General Counsel I think that sort of
addresses your issue that you had asked about
The FDA does have an opportunity here to not
interfere with a patient physician
relationship and ensure that physicians are
notified promptly if a substitution does occur
or prevent the substitution from occurring to
begin with
Again patients have the right to
know that the drug they are getting is what
the doctor prescribed and only the doctors and
patients should decide what is best for them
not payers and not regulators
We understand that the legislative
language that granted the FDA the authority to
establish a pathway also gave the Agency the
ability to determine and approve biosimilar
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interchangeable with its referenced product
We greatly appreciate the Agencys signals in
the draft guidance to take this responsibility
seriously by indicating that more time is
needed to study the amount and the types of
clinical data that would be needed to deem a
biosimilar interchangeable
We have come a long way in
providing access to lifesaving drugs to colon
cancer and to all other cancer patients We
want to ensure that these efforts continue as
biosimilars are introduced and above all else
we want to ensure that patient safety and drug
efficacy is the priority for the FDA
I thank you for the opportunity to
speak here today and I am grateful that the
FDA has taken time to hear from all the
patient advocates who have come today like
the colon cancer alliance Thank you
PRESIDING OFFICER SHERMAN Thank
you for your comments and also for remaining
on schedule
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Would anyone on the panel like to
ask a question
PANEL MEMBER KOZLOWSKI Mr
Spiegel you had talked about naming and
substitution issues Are there any other
comments on the guidances because they do not
deal with naming that you would like to make
for your organization Any other suggestions
MR SPIEGEL You want to know if
there are suggestions on that issue of the
naming of substitutions
PANEL MEMBER KOZLOWSKI On other
issues I mean you discussed that In other
words you mentioned that these guidances seem
to be heading in the right direction Are
there any other comments on what is in them
that you would like to make
MR SPIEGEL Well I think I
touched on the fact that we would ask that the
FDA take all necessary steps to make sure that
these drugs are safe which may require
clinical trials to some extent to ensure
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that these follow-on products are as safe and
as effective as the original product So
things along those lines are extremely
important to us But as patient advocates
what we are most concerned with is efficacy
and safety and then of course costs as well
PRESIDING OFFICER SHERMAN If I
could follow up on that Your comment was
mandate clinical testing yet your response to
Dr Kozlowski was not quite as -- well I dont
know if it was Could you expand a little bit
on mandate clinical testing Again you are
thinking about the interchangeability arena or
another arena
MR SPIEGEL No I think
mandating clinical testing is the way to
properly ensure that the follow-on product is
as safe and effective as the originator
product I cant think of another way that
you can possibly ensure that this follow-on
product will work as well and more importantly
be as safe or equally importantly be as safe
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as the original product other than clinical
testing
We recognize that that increases
costs but to not do that we think that the
downside risk is extremely high The last
thing a cancer patient wants to hear is that
they have hope from getting a drug that they
know works and then the drug gets substituted
and this one may not work
So I think that that is an
important opportunity for the FDA to address
PRESIDING OFFICER SHERMAN Any
other questions from the panel Ms Maloney
PANEL MEMBER MALONEY Thank you
for your comments I had a question with
regard to your comments about that patients
and physicians ought to decide what is best
for the patients and not the regulators I am
trying to understand how do you see FDA
potentially interfering with that
MR SPIEGEL Well weve heard
stories about how a patient will be prescribed
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a certain medication and they go to pick up
that medication from the pharmacy and they
receive a different medication And I dont
mean that they receive a generic medication of
the original chemical compound I mean that
they receive an entirely different medication
within the same class of drugs We worry that
if that is allowed to occur with biologics
that a doctor may write a prescription for a
biologic drug and that a different drug will
be substituted the patient will not know
about that and the doctor will never be told
that the drug they prescribed was not given to
the patient
And I think the FDA has the unique
role here of stopping that from happening
That in your guidance in your final rulings
you will be able to address that issue to
either require that no substitutions take
place or at least that doctors are notified
within a reasonable period of time that a
substitution has occurred to make sure that
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the doctors is okay with that and that the
patient is informed about that I think
patients have the right to know what drugs are
going into their bodies and certainly have the
right to know that if a drug was substituted
that that occurred
PRESIDING OFFICER SHERMAN Other
questions Thank you for your comments
MR SPIEGEL Thank you
PRESIDING OFFICER SHERMAN Our
next speaker is Alexey Salamakha
MR SALAMAKHA I have no
disclosures to make regarding my travel here
today The GHLF accepts grants and charitable
contributions from many pharmaceutical
companies as well as governments private
foundations and individuals
Good morning On behalf of the
Global Healthy Living Foundation I want to
thank this committee for allowing me to speak
GHLF is a 501(c)(3) patient advocacy group
that works to improve access to care for
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people with chronic disease often focusing on
those least likely to advocate for themselves
We represent more than 55000
members in our CreakyJoints arthritis
organization Approximately 70 percent have
rheumatoid arthritis and many safe biologics
Other groups we have created and nurtured
like CreakyBones for osteoporosis and
RedPatch for psoriasis Of course many
patients in these groups take biologics too
My name is Alexey Salamakha the
national program manager for the Global
Healthy Living Foundation I am speaking for
these patients as well as our president and
co-founder Seth Ginsberg who was diagnosed
with arthritis 17 years ago when he was 13
Seth regrets not being able to deliver our
remarks personally
Dr Sherman and members of the
Panel in sports there is a winner and a
loser Infrequently there is a tie We know
in medicine that it can be all three at the
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same time The clicheacute a level playing field
comes from sports because fairness is the
foundation that protects players and ensures a
credible outcome that each team respects win
lose or tie
In medicine we cant always have
clear winners or clear losers Sometimes
medications work and sometimes they dont
But we need to strive for the level playing
field so patients are protected and all
parties respect the process The Global
Healthy Living Foundation is asking the
committee to build a level playing field for
biosimilars so that all parties physicians
patients care givers insurers
pharmaceutical companies regulators and
advocacy groups like ours will respect the
process
We believe the committees current
guidance can become the foundation for the
level playing field our constituencies require
and we thank the committee for this important
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beginning Everyone is here today to help
guide the process and we would like to do this
in the following categories 1) the
biosimilars definition 2) clinical testing
issues 3) the physician-patient relationship
4) interchangeability and substitution 5)
pharmacovigilance in naming
Because biosimilars are comprised
of living unique and complex structures
they are not easily replicated Small changes
in the creation of biosimilars have the
potential to help or hurt a patient They are
not identical copies of the innovator drug and
we want to ensure that the populations we
serve understand this Therefore a
comprehensive definition is necessary
Because of the inherent difference
between the innovator drug and the biosimilar
we believe clinical trials are crucial There
are no shortcuts to safety or efficacy that
might be otherwise appropriate with
traditional small molecule drugs We support
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testing and post-approval monitoring
Physician organizations and the
innovator companies themselves recognize there
is an increased risk of infection with
biologics It is the physician who is charged
with mitigating the risk by monitoring
treatment and knowing patient history
Despite the fact that biologics are well-
tolerated and safe the physician is the
person most qualified to make the right
medical decision not a third-party that will
make the decision based on economics that
translate into profit
Medical decisions are not
arbitrary and neither are those that promise a
greater return to the payer As a society we
have to decide whether we want physician-based
or profit-based care The Global Healthy
Living Foundation recommends physician-based
care which prevents payer-initiated automatic
substitution and interchangeability
Our last request asks the
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committee to allow all constituencies to
readily tell the difference between
biosimilars and the original biologics We
have spoken with several people on both sides
of the biosimilars issue and we have not heard
a substantive reason for abandoning unique
biosimilars names and distinctive labels so
physicians can make informed decisions and
regulatory bodies can track any quality or
safety issues Our community deserves to know
what drug it has taken and that all drugs have
successfully passed safety and efficacy
trials
We believe a clear definition
stringent testing preserving the physician-
patient relationship eliminating substitution
interchangeability and the naming system that
provides a clear audit trail is imperative if
the committee is to continue to build on its
foundation of providing a level and healthy
playing field for all parties
When the analogy of a level
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playing field is applied to sports it means
all parties have an equal chance to pursue
victory When profit intrudes to the benefit
of one team it is illegal and it is called
game fixing When the level playing field
analogy applies to medicine it means all
parties enjoy the support of fair rules of
government and society so the patient and
physician can pursue an individualized
productive health and improved quality of life
strategy
We respectfully request that the
committee consider our point of view and
although I am standing in for Mr Ginsberg
today I can either answer your questions or I
can refer them to him so he can respond
directly
Thank you again for allowing us to
speak on this important issue
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel
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PANEL MEMBER KOZLOWSKI Mr
Salamakha you mentioned education as one of
your first points So I was wondering Do
you have any thoughts on the right way of
educating various stakeholders and consumers
and physicians on biosimilars
MR SALAMAKHA I can only share
on my personal experience of working with the
Global Healthy Living Foundation for over six
years and putting together a wide variety of
education programs for patient community HCB
community and other stakeholders So we can
regularly apply this experience and our skills
in organizing those educational programs in a
format of seminars webinars phone talks and
live events so that the patient community is
well aware of all the issues and questions
concerning the biosimilars and biologic drugs
PRESIDING OFFICER SHERMAN Other
questions Okay so thank you
So each of the speakers so far
have mentioned payers And I dont believe we
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have any payers speaking today but what would
you say to them in addition to what you have
already said
MR SALAMAKHA Our position is
that the relationship between the physician
and the patient is sacred And when there is
a third-party who is not a physician is trying
to interfere in this relationship it will
lead to negative outcomes and a worse outcome
for the patients
So I am not ready to say anything
to the payers directly I wish that we can
all work together to make sure that we can
eliminate barriers to care and also try to
achieve the best care and best treatment
possible for the patient community
PRESIDING OFFICER SHERMAN
Maryll
PANEL MEMBER TOUFANIAN You
mentioned one important component of your
thinking is distinctive labeling Can you
elaborate a little bit more if your
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organization has specific ideas and what that
would constitute And I know that others
today are also going to be speaking on this
issue so I would encourage if anyone has sort
of specific ideas with respect to labeling to
share those as part of your presentation
within eight minutes
MR SALAMAKHA Sure but as far as
this question I will probably need to refer
to Seth Ginsberg and ask him to get back to
you
PRESIDING OFFICER SHERMAN We
would look forward to seeing those comments on
our docket That would be great
Other questions I cant resist
given the sports analogy that we are a
Washington-based organization and we did not
exclude Rangers fans from todays meeting If
anyone follows hockey you will understand
what I mean We do strive for a level playing
field Thank you for your comments
MR SALAMAKHA Thank you
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PRESIDING OFFICER SHERMAN The
next speaker is Marcia Boyle from the Immune
Deficiency Foundation
MS BOYLE Well thank you for
convening todays meeting I appreciate the
continued efforts of the FDA to ensure patient
safety while implementing a biosimilars
pathway and the opportunity to share the
perspective of the patients I represent
My name is Marcia Boyle and I am
the President and founder of a 501(c)(3)
organization the Immune Deficiency Foundation
or IDF Founded in 1980 IDF is the national
patient organization dedicated to improving
the diagnosis treatment and quality of life
of persons with primary immunodeficiency
diseases through advocacy education and
research I am also the mother of a now grown
son living with a primary immunodeficiency
disease Therefore I am here to talk to you
today about key issues for patients and
parents everywhere
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The patients we represent have an
enormous stake in the FDA regulatory framework
for biosimilars In IDFs testimony in
November 2010 to the FDA on the biosimilars
pathway we outlined our thinking on
biosimilarity interchangeability and
clinical trials as they relate to patient
safety especially for individuals with
primary immunodeficiency diseases
IDF is keenly interested in the
IDFs development of a regulatory framework
and guidance documents for biosimilar
manufacturers We believe the Agencys
foremost responsibility is to ensure the
biosimilars are manufactured and prescribed
safely
When thinking of our patient
population I urge you to think zebra Our
patients are unique the zebras of the medical
world In medical school physicians are told
to focus on the likeliest possibilities when
making a diagnosis They are told when you
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hear hoof beats think horses However for
our patients you must think zebras and look
for the unusual possibilities and
consequences
Primary immunodeficiency diseases
are a constellation of disorders disrupting
the immune system resulting in a spectrum of
illnesses There are more than 150 different
primary immunodeficiency diseases currently
recognized by the World Health Organization
The number of Americans now living with
primary immunodeficiency is estimated to be in
the range of 250000 with between 35000 and
55000 on immunoglobulin replacement therapy
Many patients diagnosed with primary
immunodeficiency require biologic medicines
for long-term management Specifically
antibody or immunoglobulin replacement therapy
is used to replace missing or incorrectly
functioning antibodies needed to fight
infection Without lifelong immunoglobulin
treatments individuals with primary
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immunodeficiency would be unable to fight off
even minor infections including the common
cold
Primary immunodeficiency is one of
the FDA-approved indications for
immunoglobulin replacement and represents a
major use of the immunoglobulin therapy in the
US Therapeutic immunoglobulins are complex
biologics available in intravenous and
subcutaneous modes of administration These
medicines are derived from human blood product
or plasma sourced from over a thousand
donors Manufacturing changes the composition
of donor pools and final formulations can
impact our patients tolerability the
infusion rate and potential efficacy and
safety of the product Currently the FDA
recognizes each immunoglobulin brand as unique
and requires each drug to develop and complete
an individual clinical trial protocol to
receive licensure even if it is from the same
manufacturer This reflects the many
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processing steps involved in plasma
fractionation purification stabilization
and virus inactivation or removal that yields
products that are distinct from one or
another
As biosimilars are developed and
approved in the US we urge the FDA to take
steps that uphold patient safety above all
else IDF patients face additional risks from
adverse reactions to biosimilars that have not
been adequately tested for safety and
efficacy The following measures should be
incorporated into the IDFs -- or excuse me -shy
the FDAs final biosimilar guidance documents
restrict immunoglobulin therapies from the
biosimilars pathway require clinical and non-
clinical trials for biosimilars track and
trace and automatic substitution policies must
reflect the safety of biosimilars and the
sensitivities of patients with primary
immunodeficiency diseases
Unlike small molecule drugs
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plasma therapies such as immunoglobulin are
natural proteins of the human body and can
differ in terms of processing and in
composition The fragility of this class of
medicines is demonstrated by the worldwide
voluntary withdrawal of an immunoglobulin
product in 2010 by a major manufacturer due to
increased reports of thromboembolic events
thought to be caused by a small change in the
manufacturing process approved by the FDA
The FDA should exempt immunoglobulin
properties from the biosimilars pathway until
the science advances significantly This
policy will be in keeping with the European
medicines agency which opted to exclude
immunoglobulin from its regulatory pathway for
biosimilars It will also ensure that the FDA
is appropriately focusing on international
harmonization
For patients with primary
immunodeficiency whose lives depend on
frequent antibody replacement antibody titers
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and diversity are extremely important in
ensuring protection against infections
In 2008 IDF performed a national
survey to examine treatment experiences and
preferences among patients with primary
immunodeficiency That survey highlighted
ongoing challenges to safety and efficacy of
this therapy Nearly half of subcutaneous
users and 37 percent of IVIG users reported
that they tolerate some immunoglobulin
products better than others And among
patients that are no longer being treated with
Ig therapy eight percent cited safety issues
or side effects as the reason for stopping
Given the divergent therapeutic
responses to FDA-approved products clinical
and analytical studies should be required to
establish the safety and efficacy of all
biologic and biosimilar products Clinical
data not animal studies are the best
indicator of patient responses from a new
biological product Physicians rely on
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clinical trial results when making informed
decisions about treatment options To
demonstrate the safety of these products for
vulnerable patient populations this
requirement should not be waived
And our treatment survey found
patients are at greater risk of adverse events
when switched to a new product Of the
patients who reported having side effects from
the immunoglobulin therapy 28 percent
reported having a serious side effect to
reaction when they tried a new Ig product for
the first time Twenty-four percent of
patients refused a particular product and 15
percent delayed their infusion due to concerns
about product tolerability
Current science cannot demonstrate
that two products will provide the exact same
clinical result in a large cohort of patients
or that switching patients from one product to
another will pose no additional risks It is
therefore necessary that the FDA require
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products to undergo clinical trials to
determine that a proposed interchangeable
biological product can be expected to produce
the same clinical result as the reference
product in any given patient Additional
post-marketing surveillance also is needed to
protect patients especially as new products
are made available
All products including
biosimilars should carry unique nonproprietary
names as well as brand and lot information to
quickly trace a product to an adverse event
Finally the FDA must take
concrete steps to prohibit automatic
substitution of a biosimilar with an original
biologic Unlike generic drugs biosimilars
can never be identical copies of a referenced
product The choice of products should not be
determined by a pharmacist regulator or
insurer but by a physician in consultation
with his or her patient
In summary all medicines must be
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thoroughly tested and meet the highest safety
standards set by the FDA Immunoglobulin
therapy should be exempt from the biosimilars
pathway until the science advances
significantly However at minimum given the
unique properties of biosimilars and
immunoglobulin therapies in particular the
focus should be on making sure that
biosimilars approval process meets the same
strict criteria required for current
manufacturers
On behalf of patients with primary
immunodeficiency diseases I want to thank
you for your consideration and look forward to
the final guidance documents that give
thoughtful deliberation to our patients
concerns
Thank you
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel
PANEL MEMBER MALONEY Thank you
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Just a question on the survey You talked
about a number of the patients or users
reporting difficulty in tolerating
MS BOYLE Correct
PANEL MEMBER MALONEY And I guess
the question I have is do you have a sense of
how many of the patients are actually using or
switching now having been exposed to multiple
treatments
MS BOYLE Our patient surveys
are nationally distributed based on over a
thousand responses I dont remember the
exact data but lets say you know 50 to 60
percent had never changed Some patients have
in some surveys Later surveys patients have
changed more because we had in the last
decade there was a shortage so patients did
have to switch products
And essentially I have seen my
son collapse on the floor in having an
infusion of a new product going from a five
percent to a ten percent solution from the
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same manufacturer Patients report to our
organization frequently I indicated the
statistics as well that concerned when they
have to change products because they had some
products that they cannot tolerate such as
patients who have auto antibodies to IgA
And again going back to the
biosimilars discussion these are unique
products They are made from antibodies from
thousands of individuals They are
manufactured differently Patients will react
differently because they have different
bodies
PANEL MEMBER MALONEY Just as a
follow-up the survey is that something that
you would like to submit to the docket if you
think that would be helpful to us
MS BOYLE I would be delighted
to submit our surveys and we will do that
PANEL MEMBER MALONEY Thank you
PANEL MEMBER KOZLOWSKI A
question for clarification So you had
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mentioned that to achieve interchangeability
there would need to be clinical trials But
later you also said that the Agency should
take steps to prohibit automatic substitution
So could you clarify that Because
interchangeability I think is defined in the
statute to mean substitution
MS BOYLE For immunoglobulin
products they are unique They have to
undergo clinical trials There cannot be any
substitution
I mean frankly what I am saying is
please do not consider immunoglobulin products
as a reference product and then biosimilars
They should be exempt from the biosimilar
pathway
All other as far as I am
concerned I agree with all of the other
comments made as far as biologics should be
viewed as unique with brand names and no
automatic substitution
PANEL MEMBER MARCHAND Ms Boyle
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thank you very much for your comments I
appreciate the thoughtfulness and the
thoroughness of them
I wanted to just focus on the
point that you make about asking for
additional post-marketing surveillance So
given what we currently have as our standard
post-marketing surveillance how would you
envision there to be something beyond what
currently exists for this particular scenario
in biosimilars
MS BOYLE I mean well even I can
really only speak for immunoglobulin But
even with immunoglobulin we are finding some
products have more thromboembolic events than
other products do and we do not feel and I
believe some people at the FDA agree they
would like to see more surveillance of the
experience of patients on individual products
and their reactions
PRESIDING OFFICER SHERMAN Thank
you very much for your comments
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MS BOYLE Thank you very much
PRESIDING OFFICER SHERMAN Our
next speaker is Dolph Chianchiano from the
National Kidney Foundation
MR CHIANCHIANO Good morning and
thank you for your pronunciation
The National Kidney Foundation
with its 50000 patient and professional
members appreciates the opportunity to
summarize the response to the guidance
documents concerning a pathway proposed for
the approval of biosimilars The National
Kidney Foundation annual meeting is taking
place across the river at the Gaylord Hotel
and National Harbor and my travel expenses to
this hearing will be part of the cost of the
National Kidney Foundation annual meeting
In previous communications with
the Agency on this subject we have emphasized
and we will continue to focus on protecting
patient outcomes patient safety and
clinician discretion We also believe that
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the pathway for approval of biosimilars should
be constructed in such a way that innovation
is not stifled
Anemia is a common complication of
progressive loss of kidney function The
kidney community has had more experience
perhaps with biologics than any other
stakeholder group since there has been a
biologic erythropoiesis stimulating agent in
use in the United States to treat anemia
caused by chronic kidney disease since 1989
As other speakers have noted with
biosimilars even seemingly insignificant
changes in drug formulation manufacturing
processes packaging storage or handling can
result in severe health consequences and those
unintended consequences could be life-
threatening
For example a decade ago the Food
and Drug Administration collected information
on 82 patients worldwide who had developed
pure red cell aplasia as a result of changes
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in the manufacturing andor packaging of a
reference product ESA with the brand name of
EPREX Because of that experience the kidney
community has been especially cautious about
the development of an approved pathway for
biosimilars in general and regarding the
possibility of substituting or alternating
between reference drugs and biosimilars or
between biosimilars
There are approximately 400000
people on dialysis in the United States today
most of them receive treatment with a biologic
ESA for some period of time during the year
Moreover the annual rate of incidents in the
prevalent cases of kidney failure has ranged
between 19 percent and 24 percent since
2003 Finally there are an estimated 700000
Americans with Stage 4 kidney disease many of
them are candidates for ESA treatment These
data should suggest the magnitude of impact
should a problem with a biosimilars ESA
develop
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With respect to
interchangeability we have been concerned
that interchangeable products may be
substituted for the reference product without
the intervention of the prescribing healthcare
provider We recognize that that is a feature
of the legislation that created this pathway
that we are discussing here today And
therefore we support stringent standards for
interchangeability And we note that in the
draft guidance there is a statement that
clinical comparisons with non-US licensed
product would not provide an adequate basis to
support a determination of interchangeability
We support that statement However we note
that the guidances that we have seen so far
describe situations in which a finding of
interchangeability would not be appropriate
We understand and certainly expect that an
additional guidance may be forthcoming as to
the requirements that will be recommended to
prove interchangeability affirmatively And
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we look forward to the opportunity to provide
input on that supplementary guidance
In the meantime when approving a
biosimilar before an interchangeability
guidance is finalized we urge the Agency to
indicate that the approval does not constitute
a determination of interchangeability
With respect to packaging we urge
the Agency to reconsider the response in the
QampA document about packaging which states that
some design differences in the delivery device
or container closure with proposed biosimilar
product may be acceptable
As noted previously in regard to
the history of pure red cell aplasia organic
compounds leached by polysorbate 80 from the
rubber plungers used in prefilled syringes of
EPREX may have had a role in the ESAs
immunogenicity Another potential cause of
the increased immunogenicity might have been
the use of silicone oil as a lubricant in the
prefilled syringes
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In addition the answer in the QampA
would appear to be inconsistent with a
statement in the guidance for scientific
consideration in that the latter guidance
acknowledged that protein modification and
high order structure can be affected by
packaging materials container closure
systems and delivery and device materials
With respect to extrapolating
clinical data the following statement is not
clear The potential exists for the
biosimilar product to be licensed for one or
more additional conditions of use for which
the referenced product is licensed If the
referenced product receives a new indication
after the biosimilar has been approved how
will this affect the biosimilar Will a
biosimilar manufacturer need to file a
supplemental application for the new
indication
With regard to the totality of
evidence approach we question the principle
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that slight differences in rates of
occurrence of adverse events between two
products ordinarily would not be considered
clinically meaningful differences We do not
believe that this is a workable standard for
the approval of biosimilar and are concerned
that such a standard might also be applied in
post-marketing safety monitoring
As other speakers have urged
today we note that the draft guidances do not
describe how biosimilars should be named And
we maintain that the naming of biosimilars is
a quality consideration that the FDA should
address in the final guidance
The National Kidney Foundation has
maintained that each biosimilar product should
be given a unique nonproprietary name andor
identifier code This is important for
purposes of prescribing as well as for
identifying the specific product by a
manufacturer that a particular patient
receives In the event that said patient has
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a negative reaction to the medicine or there
is a quality control problem with the product
tracking through NDC codes will not capture
all cases because payers do not universally
use NDC codes and these codes are not
necessarily found in patient records
We call upon the FDA to include a
provision for naming in the final iteration of
the guidance for approval of biosimilars We
also as other speakers draw attention to the
issue of labeling The only direction that
the guidance provides is that the labeling of
a proposed product should include all the
information necessary for a health
professional to make prescribing decisions
We maintain that the package insert for a
biosimilar should provide testing information
including the number of studies the study
circumstances the number of study
participants and the duration of the study
both for the referenced product as well as
data provided for the purposes of establishing
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bioequivalence
Finally with respect to post-
marketing safety we hope that the brief
description of post-marketing safety
monitoring in the guidance does not represent
the totality of the Agencys plans in this
regard As previously noted or as previously
stated unintended consequences of biosimilars
could be life-threatening Even seemingly
insignificant changes in drug formulation
manufacturing process packaging storage or
handling can result in severe health
consequences For this reason NKF has
recommended that FDA track reports of
unintended consequences through MedWatch and
in an early communication with the Agency
with respect to pack rate for biosimilar
approval the National Kidney Foundation
called on the Agency to require that
biosimilar manufacturers conduct post-
marketing surveillance and that the Agency
enforce that requirement strictly
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In response to the current set of
guidances we are calling for as we said
earlier the unique names and identifiers for
biosimilar products so that adverse events can
be tracked and attributed with dispatch and
with least burden for patients and clinicians
Thank you very much for your
consideration of the reservations that the
National Kidney Foundation has expressed in
response to the guidance documents published
for public comment to this date
PRESIDING OFFICER SHERMAN Thank
you for your comments
We have time for one or two
questions Dr Kozlowski
PANEL MEMBER KOZLOWSKI So you
mentioned that slight changes in delivery
devices and container closures can have
consequences And you also stated that even
slight differences potential differences in
adverse events should not be tolerated So do
you think that if an originator manufacturer
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makes a change in container closure or dosage
form that they would be required to do a study
large enough to detect rare adverse events
MR CHIANCHIANO Well I certainly
think that the Agency should be aware of any
changes in manufacturing process or dosage and
then within the Agencys discretion as to what
to do with that information
PRESIDING OFFICER SHERMAN
Another question
PANEL MEMBER TOUFANIAN To follow
up on Dr Kozlowskis question with respect to
your concern about the slight differences in
occurrence of adverse events you indicate a
concern that such a standard also might be
applied in the post-marketing surveillance
context Could you elaborate a little bit
more on that concern
MR CHIANCHIANO Well it has to
do with how the Agency tracks and monitors any
post-marketing problems that develop If in
fact slight differences will be tolerated
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then there would be no reason to recall a drug
or take any other action
We urge the Agency to consider
every instance in which there is an adverse
event as a unique problem with a biosimilar
PRESIDING OFFICER SHERMAN Thank
you We appreciate in particular the
specificity of your comments and encourage
you to the extent possible where you believe
you have found inconsistencies or would like
to see revisions to be very specific in what
you would like to see
MR CHIANCHIANO Thank you We
will submit additional commentary
PRESIDING OFFICER SHERMAN Our
next speaker is Rene Cabral-Daniels
MS CABRAL-DANIELS Good morning
I would like to thank you for the opportunity
to present these comments on behalf of the
National Patient Advocate Foundation NPAF is
a non-profit organization dedicated to
improving patient access to healthcare
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services through both federal and state policy
reform Its mission is to be the voice for
patients who have sought care after a
diagnosis of a chronic debilitating or a
life-threatening illness NPAF has a 15-year
history of serving as the trusted patient
voice The advocacy activities of NPAF are
informed and influenced by the collective
experiences of patients who receive direct
sustained case management services from our
companion organization the Patient Advocate
Foundation Those experiences have been
quantified in the PAF patient data analysis
report which illustrates the data collected
across 260 variables by PAF senior case
managers
In 2011 PAF resolved 110000
patient cases and has received more than five
million additional inquiries from patients
nationwide PAFs ability to assist patients
confronting a wide spectrum of challenges
enables NPAF to competently serve as a patient
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voice
NPAF supports the promise of
improved patient care as a result of
biosimilar development and approval We are
keenly aware of the critical public health
benefit biosimilars and interchangeable
biologic products represent as well as the
resulting benefit to potentially offer a
lifesaving or a life altering therapies at
reduced cost to patients
Today NPAF will focus its comments
on the second component of FDAs meeting
notice the Agencys future policies and
priorities regarding biosimilars NPAF
believes that a critical component of FDAs
biosimilar policies should be patient and
consumer education The following passage of
the Biologics Price Competition and Innovative
Act of 2009 FDA posted a brief information for
consumers page on its website regarding
biosimilars As the panel certainly knows
the page essentially explains what a biologic
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product is what a biosimilar is and that some
biosimilars may be determined interchangeable
which would allow for pharmacy substitution
This page however could be
improved upon to educate patients about many
other important issues such as the risks and
benefits of biosimilars how the products
would be developed studied and approved for
marketing by FDA and which facts should be
considered when discussing the possible use of
a biosimilar with their physicians NPAF
believes that patients need complete
information about how biosimilars work and
have been tested in order to make fully
informed choices about their use
Consumer understanding of new
technology is critical to its uptake and
successful integration into the healthcare
system but it is highly unlikely that many
consumers currently have a good or any
understanding of biosimilars This situation
should be remedied as soon as possible even
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before the first biosimilar products are
approved for marketing
The experience of generic drug
marketing and consumer perception may prove
informative A recent GAO report on generic
drug use specifically pointed out the effect
consumer perceptions can have on the
utilization of the generic drugs The January
2012 report is entitled Drug Pricing
Research on Savings from Generic Drug Use In
it GAO noted that physicians pharmacists
consumers may have perceptions about the
safety and efficacy of generic drugs compared
to brand named drugs which in turn affect
what drugs they choose to use These
perceptions are based on a number of factors
including prior experience results of
relevant studies or advertising Negative
perceptions of generic drugs may be more
common where questions have been raised about
the medical appropriateness of generic or
therapeutic substitution
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The history of generic drug
acceptance by patients in the medical
community provides FDA with important
information about how to proceed with
implementing the nations biosimilar policy
Of course biosimilar products will need to be
approved before they can be utilized but once
they are available perceptions about safety
and efficacy of the products will be a
decisive factor in whether they are
prescribed dispensed and used As has been
the case with generic drugs patients and
healthcare professionals as well as health
plans must have a stake in the biosimilar
system if it is to be successful
Accordingly NPAF respectively
urges FDA to undertake a patient-focused
proactive educational campaign on biosimilars
that utilizes creative approaches to educate
consumers about these important issues and
more The educational materials that have
been developed on generic drugs are an
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excellent starting template FDA has made
available to the community slides brochures
pharmacy mats posters audio files and much
more on generic drugs The FDA website also
provides facts about generic drugs and
questions and answers about generic drugs in
consumer-friendly formats Public service
announcements and coverage on public radio and
television networks might also be beneficial
to teach consumers about biosimilars
NPAF encourages FDA to establish
public-private partnerships with non-profit
patient advocate community to assure its
patient education efforts are impactful
Patient ability to afford medical
care is a significant challenge for them The
recently released 2011 patient data analysis
reports reveals debt crisis and cost of living
issue category was the most frequently
reported and represents 31 percent of all
issues This is a 19 percent increase from
2009
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As we note from the recent GAO
report the retail price of a generic drug is
75 percent lower than a retail price of a
brand name drug Although it is unclear what
the cost-saving potential of biosimilars will
be given their complex manufacturing
processes there will certainly be some cost
savings for patients The Federal Trade
Commission estimated in 2009 that price
discounts for biosimilars may be 10 to 30
percent of the referenced product cost Many
biological products are used to treat very
expensive life-threatening diseases diseases
that all too often are responsible for debt
crisis issues and medical bankruptcies And
any decrease in cost for these expensive
treatments through the approval of
corresponding biosimilars may have a
significant impact on patient access
A significant number of cancer
treatments are injectable biological products
as are many current treatments for autoimmune
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diseases such as rheumatoid arthritis
multiple sclerosis and Crohns disease These
health conditions represent the majority of
patients assisted by PAF in 2011 Patients
with cancer were 69 percent of the population
and those with chronic and debilitating
conditions were 17 percent demonstrating the
impact of these chronic debilitating or life-
threatening diseases and the very expensive
treatments on the American consumer
As part of the patient-focused
educational campaign NPAF also believes that
FDA should consider preparing lay summaries of
the three current biosimilar guidances and any
future guidances The lay summaries could be
appended to the end of the technical guidances
in a way that medication guides for patients
are appended to the prescriber oriented
package inserts for prescription drugs These
efforts could help increase physician health
plan and consumer confidence in FDAs
approval process for biosimilars and
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consequently the acceptance of biosimilar
products by those critical stakeholders
As suggested above NPAF believes
a public-private partnership with the nonshy
profit community could result in lay summaries
that positively impact the patient community
by allowing them to make well-informed
decisions
Finally NPAF believes that these
consumer educational materials and campaigns
should be disseminated in other languages
besides English The selection of which
languages to translate various materials
should include the most recent census data
reflecting the nations multicultural
composition and limited English proficiency
as well as Centers for Disease Control and
prevention data on disease prevalence by race
andor ethnicity
Thank you again for the
opportunity to present these comments on
behalf of NPAF
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PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel
PANEL MEMBER KOZLOWSKI So we
heard about education earlier and I think it
is really an important topic and you have
outlined some very specific suggestions So I
think if there were ways of even adding more
specificity to them it would be very useful
to us I mean I am particularly interested
in what the best structure of a public-private
partnership for this would be who it would
include and how it would be set up to make a
level playing field to use the term we heard
before And also the role of newer you know
you mentioned innovative approaches social
networks Are there other tools that will
help this work even better
PRESIDING OFFICER SHERMAN Other
I had a very similar thought Any
suggestions you have of any specific
organizations that would want to assist the
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Agency or partner with the Agency in this
effort would be appreciated
Thank you So that constitutes
our patient panel So I will just ask the
panelists we have heard some repeating
themes if there is anyone you would like to
recall and ask a particular question
Oh we have one more Thank you
Thank you Denise for keeping me on track
All right we are -- that actually
does conclude for the moment our patient
panel We are missing a panelist
So I will go back Are there any
other patient-oriented questions from the
panel Okay
Then we will keep our break on
time and we will go -- Oh Im sorry Al Cors
from RetireSafe is here
MR CORS Thank you
PRESIDING OFFICER SHERMAN Youre
welcome
MR CORS Thank you very much
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Dr Sherman and thank you and your colleagues
for this hearing this morning And I am
certainly very honored to participate My
name is Al Cors and I serve as the Vice
President of Public Affairs for RetireSafe a
non-profit non-partisan organization that
educates and advocates on behalf of 400000
older Americans across the country
Our President Thair Phillips had
hoped to be here however he is in Denver
today participating in the Colorado
Generentological Societys 23rd Annual Salute
to Seniors So he is holding forth with a few
thousand seniors in the Denver Convention
Center right now So I am pleased to be here
to represent him and RetireSafe in this
important hearing this morning
I would like to first cite three
recent news events that just popped out at me
as I was preparing comments An April 21
2012 Wall Street Journal article In hundreds
of documented cases that undermine a broad
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swath of research cancer samples that were
supposed to be one type of tumor have turned
out to be another through either careless
laboratory handling mislabeling or other
mistakes That was one story
In that same edition of The Wall
Street Journal on April 21st is another story
about fake Avastin possible in 13 states It
cites reports an FDA warning to doctors and
medical practices in 13 states regarding the
fact that they may have purchased a fake
version of the cancer drug Avastin an
injectable biologic All told at least 76
physicians and medical practices have received
letters from FDA warning about using
counterfeited Avastin of one form or another
The story notes By purchasing
cheaper foreign drugs doctors can increase
their profits say investigators probing the
purchases If doctors buy cheaper-priced
controlled drugs from other countries but
bill managed care companies and government
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health programs for the full FDA-approved -shy
full price of FDA-approved drugs the
difference goes to their bottom line the
investigators say
And then finally three days later
on April 24th both The Wall Street Journal
and the Daily Mail had stories regarding an
Avastin Lucentis age-related macular
degeneration controversy Evidently the drug
company in the United Kingdom the drug
company Novartis has taken legal action to
stop a national health service effort to
encourage the use of the approved cancer drug
Avastin to treat wet age-related macular
degeneration or wet AMD rather than a more
expensive drug Lucentis a drug specifically
approved and licensed for use in the treatment
of AMD
The Daily Mail story noted that
the Royal College of Ophthalmologists supports
the continued use of Lucentis and also noted
that fears over side effects had led the US
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Department of Veterans Affairs to stop using
off-label Avastin for the treatment of AMD
Now I cite these three news items
I think they are important because they
highlight just how critical the FDA biosimilar
guidances for all Americans and especially for
seniors
Please remember that there are
roughly 10000 new retirees every day and that
older Americans will soon comprise 20 percent
of our population They will no doubt be
the largest users of biologics and
biosimilars We want them to be safe
In the first instance above
scientists made major mistakes in the lab
endangering both research and patients In
the second instance we know that fake
biologics of uncertain provenance are
enriching some greedy individuals while
putting perhaps thousands of cancer patients
at risk
In the third and final instance
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we know that governments on both sides of the
Atlantic Ocean have tried to favor the use of
one unapproved and unlicensed injectable
biologic for the treatment of AMD over the use
of an approved and licensed injectable
biologic designed to treat AMD just to save
money
In the last case we know that
infections and side effects have been reported
probably because of the substitution Our
point is there can be no shortcuts Both
original biologics and biosimilars must be
rigorously tested including full clinical
trials Biologics are complex organisms and
as we have seen even scientists can make
mistakes
Every drug destined for the market
must be fully proven to be safe with no
exceptions The biosimilar system must
absolutely guard against the use of cheaper
imported drugs that may bring the plague of
counterfeit foreign drugs here The complete
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surveillance system for biosimilar manufacture
marketing and distribution must be in place
before a single patient is put at risk
Finally there could be no forced
government or third-party substitution because
one biologic drug is simply cheaper than
another The choice between two biologic
drugs should be a patient-physician decision
made after both drugs are fully approved to
treat the respective illness Biosimilar
drugs are not innovator drugs and must have a
large time and cost advantage over the
developers of new innovative treatments and
cures These drugs should certainly come to
market sooner and cost less but biosimilar
drugs are also not generics and they must all
be required to prove their safety and
effectiveness just as the reference drug to
which their similar did earlier
There should be no flexibility
intentionally introducing differences to the
molecule or the finished product allowed in
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the manufacture of biosimilars That would
clearly open the door to unintended or
unanticipated risk Biosimilar drugs should
be labeled distinctively and a strong track
and trade system for them should be fully in
place before they come to market That is
what patients want is guidance for this
important new class of drugs
Thank you for your consideration
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions for the
panel
I have one overarching question
for you or for anyone So you have all
emphasized the importance of maintaining our
standards of safety and efficacy or safety
purity and potency Is there anything in
what we have communicated so far that raises
in your mind a question that in fact we are
indicating otherwise in the guidance documents
we have provided
MR CORS No there is not And
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we have on several occasions submitted
comments essentially supporting what you are
doing and saying and urging the strongest
possible safeguards We are here today to do
that again to highlight the fact that there
are many concerns whether it be counterfeit
drugs whether it be mistakes in the lab all
of these concerns that we are all looking to
safeguard against every day and certainly you
more than anyone else So we appreciate what
you are doing And again we just want to
encourage the strongest possible safeguard
because -shy
And I just turned 65 earlier this
year so I can speak personally for seniors
across America We are a very vulnerable
population and we count on you to safeguard
our medications And this is going to be a
critical area in an era of cost controls
people looking to save the dollar wherever
they can This is going to be very important
So what you do with these guidelines will
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impact every one of those seniors across
America Thank you very much
PRESIDING OFFICER SHERMAN Other
questions Okay thank you very much
It is 1000 so we will take a 15shy
minute break And if everyone could be back
here at 1015 Thank you
(Whereupon the foregoing hearing went off the
record at 957 am and resumed at
1014 am)
PRESIDING OFFICER SHERMAN Okay
welcome back Our first speaker in this panel
is Dr Dolinar from the Alliance for Safe
Biologic Medicines Welcome
DR DOLINAR Dr Sherman and
panel members good morning Thank you for
giving me this opportunity to speak with you
today My name is Dr Richard Dolinar I am
a practicing physician I am an
endocrinologist I specialize primarily in
diabetes I am also chairman of the Alliance
for Safe Biologic Medicines
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The Alliance is a non-profit
organization composed of patients physicians
clinical researchers scientists and
innovative medical biotechnology companies
We have a slide here I can you show you some
of the -- Im pushing this and it is not
moving Oh there we go There we go
We are a diverse organization a
non-profit organization Our objective is to
ensure that patient safety is in the forefront
of the biosimilars policy To achieve this
goal the Alliance has been active in many
ways since the FDAs initial public hearing in
November 2010 We have put on webinars we
have also written op-eds And in fact just a
few weeks ago on the Hill we hosted a forum
on biosimilars and biologics that was well
attended
A list of our activities can be
found on our website safebiologicsorg I
would encourage all of you to review the
website I think you will find it very
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helpful
All of these activities are meant
to drive home our primary message that
patient safety must be the non-negotiable
priority in developing a framework for the
review and approval of biosimilar medicines
As you know biosimilars are quite
complex quite large molecules In contrast
to the small molecule standard drugs of the
past that are made chemically as you know
biologics are made with living cells We grow
them That is why I call it farming It is
actually farming at a molecular level We
call it molecular farming And as we know no
two biologics made from two different cell
lines or by different processes are identical
I just want to point out that small changes
or small differences in a molecule can have
major differences in how it impacts the body
If I can go to the next slide here
-- there we go
Notice how similar these molecules
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are These are actually three hormones and
you can see they are very similar Very minor
changes between them But look at the
difference when they are in the body You
know the one on the left testosterone that
makes boys Progesterone estradiol on the
right that makes girls A major difference
even with small changes in these molecules
So we recognize what an immense
task that you are undertaking to formalize a
regulatory pathway for biosimilars The
Alliance appreciates your ongoing efforts and
we appreciate that you have consulted with
stockholders -- stakeholders We strongly
support the work you are doing because you
know ultimately it is the patient who is
going to benefit And that is what we are all
about What is right for the patient is right
for everybody So we truly appreciate what
you are doing We strongly support the work
that you have done
We do have some suggestions for
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you as you continue in your work Clinical
studies have been mentioned repeatedly by
previous speakers So I will just go briefly
through this As you know immunogenicity is
an issue regarding not only biosimilars but
all biologic drugs And unfortunately our
ability to predict immunogenicity is limited
by our scientific knowledge We are learning
more each day Science is progressing each day
and we think analytic studies are very
important to analyze these molecules in an
attempt to determine immunogenicity but along
with that we think that clinical testing
plays a very important role
As a practicing physician I can
tell you this is the kind of information I
need to feel comfortable with a drug What
clinical tests were done What were the
results And I can tell you physicians if
they are not comfortable if they are not
confident in a drug they are not going to use
it Clinical testing will help provide that
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confidence and allow docs to use the drugs
with confidence
The next point I would like to
make is about foreign source reference
products The global biosimilars market is
expanding markedly and we believe steps must
be taken to monitor the global supply chain
and the manufacturing process
We believe that the FDA must
receive critical supporting information before
it can accept biosimilar clinical data that
would be used to seek approval in the US
This supporting information must be able to
demonstrate the following we believe We
believe the same company should manufacture
the reference drug both in the United States
and outside the United States We believe
that the non-US reference drug and US
reference drug should be analytically
indistinguishable from each other
We also believe that it should be
demonstrated that the product is filled and
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finished in fully representative strengths
formulations and containers An earlier
speaker from the Kidney Foundation pointed out
how a difference in the container made they
believe a difference in the effect of that
drug
And we believe that proof of
pharmacokinetic bioequivalence between the
biosimilar the US reference product and the
non-US reference product should be shown
And please note we are not suggesting that
foreign clinical trial data generated to
support the approval of a new biosimilar by
the FDA be limited We are basically saying
that it can be used as long as it conforms to
current standards That is all we ask there
Regarding track and trace and
naming provisions currently the post-approval
surveillance of biosimilar products is
impossible under the current system if
biosimilars use the same nonproprietary name
We think it is absolutely critical that
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different nonproprietary names be used for the
biologic and also for the biosimilar drugs
This we believe is one very helpful way to
help with track and tracing and in the end
will ensure that we are able to identify what
drugs the patient is taking when they were
taking them et cetera
The issue came up earlier about
packaging labeling and prescribing
information We believe that the drugs the
biologics and the biosimilars should be in
packages that are unique easily identifiable
The patient should know what drug they are
receiving from the doctor or from the
pharmacy We believe the package should list
the manufacturer the lot number directions
on how to use how to prescribe and unique
packaging would help identify that and it
could be easily identified
Interchangeability has come up
with the previous speakers I want to make a
few points regarding that At the present
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time little is known about switching a
patient from one drug to another drug from a
biologic to a biosimilar or perhaps from a
biosimilar to a different biosimilar or back
to the reference biologic We are still
beginning to understand that So in light of
that we strongly encourage clinical trials
once again We also would like to raise the
issue of drift As you know over time due to
manufacturing process or changes in storage or
whatever these biologics can tend to drift
from where they were initially And this will
need to be monitored Two drugs that were
initially thought to be similar with time
might drift apart and be different So
sometime a mechanism needs to be in place to
monitor for that
The lady earlier asked the
question about what can the FDA do regarding
biosimilars and biologics and I would like to
address that Like the earlier physician the
first speaker the neurologist in parts of
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the country pharmacists can change the drug
without notifying the doctor And we too in
our office have one person who just works
with the pharmacist all day working on prior
authorizations et cetera
We would suggest and we believe
that the doctor should be involved in the drug
substitution process He should be involved
in that decision And although this process
is available in some states we recommend that
this not be applied to the biologics and the
brand name biologic drugs
In conclusion we support what you
are doing As I said the work you are doing
will ultimately benefit the patient If there
is any way to help you we are happy to do it
Thank you
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel
PANEL MEMBER MARCHAND Thanks for
your comments I appreciate them I wanted
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to just explore this with regards to the
comment you made about before biosimilars are
sold there should be a robust surveillance
system So beyond what currently exist can
you talk a bit about what you might envision
beyond the current structure for biosimilars
that would be unique
DR DOLINAR As I pointed out I
think one of the main issues we think that the
biosimilar and the biologic should have
different nonproprietary names We think that
that is a critical issue and important so that
they can be differentiated so the doctor can
know exactly what medication the patient is on
and therapy So that would be main point
Ultimately it is all about
patient safety It is all about keeping good
notes What was the patient treated with
when See as a treating physician I cant
tell you how important it is to keep a good
chart good notes and to be very specific
PANEL MEMBER KOZLOWSKI I just
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want to follow up on the question of naming
and tracking and tracing
And so I think you stated that it
was impossible to be able to track and trace
without unique names And I sort of wonder
what is the data you have to support that
DR DOLINAR It is my clinical
experience working in hospitals and treating
patients et cetera
My concern is if the biosimilar
and the biologic have the same nonproprietary
name that is what is going to be written in
the chart We wont know which drug was
actually given to the patient I am trying to
keep things as clear as possible so that
people dont make mistakes
PRESIDING OFFICER SHERMAN Other
questions
I have one One concern we have
heard is that if you will the same product
the biosimilar and the reference product have
unique names there is a danger of inadvertent
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if you will dual prescribing Do you have any
comments on that
DR DOLINAR As a physician that
is your responsibility You are trained I
think that type of a problem for somebody who
is trained in working in that area I would
think it would be unlikely You know people
make errors I think anything is possible of
course My concern is that if they have the
same name we dont know which drug they are
getting and if there is a problem we cant
identify it
And I think that that is a major
consideration whereas your consideration I
think is possible but I think less so
PRESIDING OFFICER SHERMAN Thank
you very much for your comments
DR DOLINAR Thank you
PRESIDING OFFICER SHERMAN Our
next speaker is Shein-Chung Chow from Duke
University
DR CHOW Thank you My name is
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Shein-Chung Chow I am from Duke University
School of Medicine Before I get started
first I would like to congratulate the FDA for
the wonderful job that they have done in such
a short period of time And also I would like
to thank the panel for providing me the
opportunity to comment on the guidance
especially the one for the scientific
consideration
So in the next ten minutes or so I
will focus on the two key concepts for
assessment of biosimilarity proposed in the
guidance by the FDA Those two key concepts
include the stepwise approach and also
totality of the evidence Then I think that I
would like to provide my input regarding the
interchangeability intents of the definition
interpretation and the concept of the
alternating and the switching Then I think
that if I may I will probably propose some
possible use for study designs for tracing the
interchangeability by using the alternating
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and the switching indices
In the guidance the FDA proposed
the use of the stepwise approach This stepshy
by-step approach is understandable However
at each step it is not clear the way the one
size fits all criterion or the way that the
one size fits all criterion will be used and
how to determine how similar is considered
highly similar Those are not mentioned in
the draft guidance
And in addition to that I think
in my opinion I think in order to implement a
stepwise approach for assessment of
biosimilarity the fault in the scientific
issues should be addressed The first one is
how many steps is required How many steps
are there How many studies should be
required And the second is the order of the
steps that matter And the third should each
of the steps carry the same rate And finally
I think how to control the overall error rate
And now that the key concept
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proposed by the FDA the so-called totality of
the evidence The concept of totality of the
evidence involves two concepts One is the
so-called local biosimilarity For example
in some specific domain you know a specific
domain or similar specific domains versus the
global biosimilarity across all domains And
it should be noted that the degree of the
biosimilarity may vary from domain to domain
and each domain may carry different weights
So I think that the face on this
concept I think we feel that FDA seem to
suggest a scoring system for measuring the
totality of the evidence Along this line
the ideas of the so-called Biosimilarity Index
proposed by Chow and others 2011 may be
useful These proposed Biosimilarity Index
will achieve the totality of the evidence
under different study designs andor the
biosimilarity criteria
In order to I mean before I
introduce the Totality Biosimilarity Index I
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think first I would like to propose the so-
called local Biosimilarity Index The so-
called Biosimilarity Index it is very
straightforward by following the steps
Step one I think that we can
assess the average biosimilarity based on a
given criterion For example the company
used the 80 100 and 125 based on long-
transformed data for the assessment of body
clearance
Step two we can then calculate a
reproducibility probability based on the
observed ratio and availability
Then step three we would claim
that the local biosimilarity if the 95 percent
confidence interval lower bound of the
reproducibility probability is larger than the
pre-specified number p0
Now you may ask I think how are we
going to determine the p0 The p0 actually
can be obtained based on some comparison of
the reference product to the reference
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product In other words we can calculate the
reproducibility probability when comparing the
reference to itself This probability is
expected to be very high because we compare
the reference to itself So the probability
should be high
Then in this case I think the p0
can be selected as 80 percent of the pRR the
reproducibility probability for comparison
between the reference and itself
For example if the pRR is 90
percent and we may choose the p0 as 80 percent
of the 90 percent which is 72 percent and the
p0 actually can reflect a degree of
biosimilarity that either I think they are
required by the regulatory agency or the
sponsor would like to achieve
Now totality biosimilarity across
the different domains I mean also follows a
similar idea We first obtained a pi pi is
the reproducibility probability or a local
Biosimilarity Index for the ith domain I
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mean I goes from 1 to K and the K domains is
supposed And then we can define the Totality
Biosimilarity Index which is the weighted pi
So the Totality Biosimilarity Index could be
P In this case under step three we are
going to claim the biosimilarity if at a 95
percent confidence lower bound of the p is
greater than the pre-specified value of p0
Now I would like to provide some
of my input regarding the interchangeability
According to the BPCI Act the biologic
product is considered to be interchangeable
with the reference product if they satisfy the
following condition First the biologic
product is similar to the reference product
and then second it can be expected to
reproduce the same clinical results in any
given patient And then I think the Part B I
think the risk of alternating andor the
switching I mean between the use of the
biologic product and the reference is not
greater than the risk of using the reference
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product without such alternating andor
switching
Now based on this definition the
first we noticed that there is a clear
distinction between the biosimilarity and the
interchangeability And then the key concern
the major concern of this is that it is
possible to show the same clinical result in
any given patient I think that is would be
our major concern according to the definition
as described in the BPCI I think that in
practice is difficult if not impossible to
demonstrate the same clinical result in any
given patient However it could be possible
to demonstrate the same clinical result in any
given patient with a certain assurance
Now I would like to now talk a
little bit about the concept of the switching
and alternating Switching is referred to the
switch from one biologic product to another
So in our case I think it could be a switch
from the reference to test 7 to (T) or to
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switch from the (T) to 7 7 to 7 or (T) to
(T) And alternating is a switch from the one
biologic product to another and then switch to
another for example the original biologic
product So it could be I think start with
the reference product and then switch to the
test product and then switch back to the
reference product Or maybe we start with the
test product and to the reference product and
then back to the test product
Now in order to address this
switching and alternating the drug
interchangeability I think I would like to
propose that four impossible study designs
The first of the design in order to address
the switching that will be the four by two
balanced crossover design Four by two that
means it is a four sequence and a two (T)
rail In other words I think that the first
sequence with the test you will receive the
test product first after some original answer
was shown and then cross over to receive a
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test product
And then the second sequence would
be the (R)7 and then the third would be (T) 7
and the fourth sequence will be (R)(T)
In order to address the
alternating I think the two by three dual
design which is a (T)(R)(T) (R)(T)7 may be
useful And an alternative design could be
the actual reference design which is the
(T)(R)7 (R)(T)7 I mean the design has been
studied extensively in the literature
In order to address the switching
and the alternating altogether perhaps I think
the modified Balaams design like a (T)(T)
(R)7 (T)(R)(T) and (R)(T)7 may be useful
Of course there is some
alternative designs such as the extended and
modified Balaams design TDD RR TRT RTR
And another the alternative design could be
the TDD RR RTR RTD Im sorry RTD RTR So
this design currently has been studied by a
group of researchers to compare the relative
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advantage and the disadvantage for a
situation the potential switching and
alternating
So now I will like to conclude my
presentation by listing two remarks The
first the proposed Biosimilarity Index and the
Totality Biosimilarity Index across different
domains is useful in providing the totality of
the evidence for assessment of biosimilarity
describing the FDA guidance And a similar
concept can be used to address the issue of
the interchangeability by developing the
switching index alternating the index andor
the switching and alternating index under the
proposed possible useful study designs
Thank you very much for your
consideration
PRESIDING OFFICER SHERMAN Thank
you for your comments we have time for one
or two questions
PANEL MEMBER KOZLOWSKI So do you
envision this score including all aspects of
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the evaluation each of the analytical tests
with what their margins are whatever clinical
studies are performed animal studies all
integrated using the same score
DR CHOW Yes that is the idea
But the only thing that I think is different
I mean the studies for example if we want to
evaluate the quality attribute in the
manufacturing process of things like that I
think that we may have a different set of the
criteria for the biosimilarity So I think
the proposed scoring system the so-called
Totality Biosimilarity Index actually we take
that into consideration because I think the
calculation of the Biosimilarity Index or the
so-called reproducible probability is robust
to the design and also the selected the
biosimilarity criteria
PANEL MEMBER KOZLOWSKI But would
you weigh those different factors for each
product each analytical attribute
DR CHOW That is a very good
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question I think that is probably subject to
the discussions between the regulatory agency
and also the sponsor because the sponsor they
probably have a better idea in terms of what
kind of weight that you should carry forth
specific domain
PRESIDING OFFICER SHERMAN Thank
you for your comments We hope you submit
them in detail to the docket
Our next speaker is Marcie Bough
from the American Pharmacists Association
DR BOUGH Good morning My name
is Marcie Bough Im a pharmacist with the
American Pharmacist Association APhA where I
serve as the Senior Director of Government
Affairs APhA is the first established and
largest professional association for
pharmacists and we represent members in -shy
over 62000 members practicing in all practice
settings including community pharmacies
hospitals long-term care facilities
community health centers managed care
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organizations hospice settings and the
uniformed services Thank you again for the
opportunity to provide comments today
APhA supports the development of
scientifically based safe and effective
processes to approve biological products
demonstrated to be biosimilar to or
interchangeable with FDA-licensed biologic
reference products We appreciate FDAs
efforts to develop the initial implementation
draft guidances to date and we look forward to
providing additional input in the future We
also appreciate that you are seeking public
input and support the stepwise approach as
development continues
Pharmacists are often considered
the most successful healthcare provider for
some patients or the medication use experts on
healthcare teams and play an important role in
helping patients manage their medications and
achieve optimal medication therapy outcomes
which will be including biosimilars in the
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future
Standard components of
pharmacists practice include recommending
generic alternatives for patients requesting a
generic or facing cost-related access
barriers complying with dispensing as
written or DAW orders on a prescriptions
complying with formulary management orders on
a prescription complying with formulary
management requirements set by a plan and
complying with other plan or state-based
generic utilization programs
Often we are in communication with
the prescriber and make adjustments to clarify
dosing and directions or make adjustments due
to formulary coverage issues Such processes
and actions for a prescription order
fulfillment and dispensing to a patient
translate to biosimilars
Pharmacists long-standing trust in
the FDA process for generic drug approval and
now for biosimilars focusing on safety
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effectiveness and evidence-based medicine is
a core component of pharmacists daily practice
in helping patients As FDA considers the
next steps in finalizing current draft
guidances and importantly considering future
draft guidances on biosimilars we recommend
that FDA consider the following key focus
areas
1) Processing prescriptions in
interchangeability As the abbreviated
license or pathway for biosimilars matures we
recommend additional guidance to the extent
possible on the logistics for handling
biosimilar prescriptions in the pharmacy For
example will pharmacists processing
prescription orders in any pharmacy need a
unique individual prescription by name for a
biosimilar andor for a biosimilar determined
to be interchangeable with that reference
product Do we need an individual
prescription for the biologic for the
biosimilar and the interchangeable And does
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that constitute a unique individual
prescription order for each processing of that
prescription
Recognizing that at this stage in
guidance and implementation it may be too
early for such switch in logistical aspects
for prescribing and dispensing of the
biologics but it is what we think about and we
will need more information as to how
physicians and other prescribers and
pharmacists are to manage prescription orders
for these products
In addition we support references
in the guidances to development of an FDA-
compiled interchangeable reference list
something similar to the current Orange Book
for generics to assist healthcare providers in
managing prescription orders
2) Labeling and naming of
biosimilars As outlined in the draft
guidance we support that a biosimilar product
label should clearly indicate approval of the
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biosimilar to a reference product as well as
labeling to indicate approval or lack thereof
of interchangeability with reference products
Such information will be critical for
pharmacists to have and will help guide
pharmacists in appropriate product selection
at the point of dispensing
In addition we support reference
in the draft guidances about similar
interchangeables used the same strength or
measurement as the reference product labeling
Furthermore we consider that the
variety of potential mechanisms for naming of
biosimilars we caution these with suffixes
If it is to be considered suffixes present
challenges for pharmacy operating systems and
in processing for fulfilling orders Suffixes
may not be included in the original electronic
or written prescription They may fall off
the electronic dropdown menu order form for
product selection and they may not fit into
the data field in the database However the
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naming is finalized we will need to provide
clear information to providers on the correct
use at the point of prescribing and
dispensing
Similarly information will be
needed on naming and tracking for the use in
adverse event reporting and post-market
surveillance activities to ensure standard
procedures are used that are applicable to
inpatient and outpatient settings and
consistent with current adverse event
reporting procedures
For example we believe it is
important for the adverse event tracking to
work in compliance with the existing formats
with MedWatch processes and the evolving
Sentinel Initiative
For another point on labeling if
a biosimilar is approved to be slightly
different in delivery design we recommend
that such variation be clearly indicated in
the label as providers and patients will need
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to know if it is a different form than the
reference product because additional or
different patient education may need to be
provided on use of the product or instruction
3) Education and outreach APhA
recognizes the need for education and training
for healthcare providers on the implementation
of biosimilars Education and outreach will
need to focus on but is not limited to
awareness identification of biosimilars and
interchangeability terminology processes
and logistics to prescribe and dispense
biologics and importantly those that are
determined to be interchangeable differences
from our current generic process and
necessary resources that are available to
healthcare providers and patients
Education for pharmacies should
also address the biosimilar information will
or will not be integrated into the pharmacy
operating system meaning product menu
selection safety edits interaction warnings
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et cetera that are currently in place and
uploaded into our pharmacy operating databases
and used for fulfilling those prescription
orders Such information will be important to
understand how prescribers will see the
information as they use electronic prescribing
order entry processes as well
There will be a learning curve
before during and after products complete
the biosimilar pathway to market We
understand that Again we do believe that
there will need to be education as we have
heard earlier today and awareness campaigns
for the entire healthcare system on how to
handle these products and the logistics for
prescribing and dispensing
APhA is willing to work with FDA
and the other stakeholders to help develop and
provide education to pharmacists through
vehicles such as continuing education
programs faculty and practice tool kits and
online communication tools and other outreach
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opportunities
4) State preparation for
biosimilars We recommend that FDA consider
future guidance to assist states as they
consider potential and if needed revisions
to their state substitution laws and
regulations to reflect biosimilars and
interchangeability or for what they may
require for their state programs Such
guidance could potentially help the states
forgo creating different interchangeability
standards for biosimilars
5) Totality of evidence We
support FDAs efforts to use the totality of
evidence support approach as it considers
biosimilars and applications that focus on
considerations of the complexity of the
proteins and manufacture process use of data
driven from non-US studies or licensed
products close market surveillance
monitoring and considerations in early
communications with those manufacturers
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potentially seeking to proceed through the
biosimilar pathway
In closing we need to ensure that
healthcare providers have education on how
biosimilars are being implemented what is
classified as and how to identify biologics
and biosimilars and what is the
interchangeable use and access to
interchangeable reference list and what needs
to happen to prescribe and dispense these
products
Pharmacists in the community
across the country will play an important role
in patients accessing biosimilars We look
forward to working with FDA and the other
stakeholders as additional information becomes
available and the future guidance is
developed
Thank you
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel Heidi
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PANEL MEMBER MARCHAND Thank you
Ms Bough -- Dr Bough we appreciate it very
much
I wonder if you could talk a
little bit about models that you have seen
with FDA interacting with regard to the
training So you have talked about some
specific things and I am particularly
interested in sort of the timing of
introducing that training
DR BOUGH Great question We
have often thought -- Well as we have gathered
feedback from our members and we have talked
internally people are not lacking of interest
but they are lacking of awareness of when
these are really hitting the market and what
are we going to have to do when when we start
seeing applications that have completed the
biosimilar pathways So in advance of the
products hitting the market we would want to
make sure that we have information out in the
hands of pharmacists and the other healthcare
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providers that know what it is they are
supposed to do when they receive that
prescription so that even if they are
processing a prescription for the first time
of one of those products they at least know
what to do when they are on the receiving end
of that or what reference material to go to in
search of that type of information
One example that we have done
through print and electronic kind of education
and awareness campaigns is inserting into our
publications or posting on the website simple
guides
One example that we have that
relates to the generic side is called the
Pharmacists Guide to Using the Orange Book for
Product Substitution and Decisions It is
branded under what we have as The One Minute
Counselor That is on the front side for the
pharmacist On the back side it is The
Patients Guide to Drug Product Substitutions
So with regard to the interchangeability of
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all of this that type of information just
some logistical information could be helpful
even if we dont know which product might hit
that landing spot in the future But it is
that type of awareness campaign that others
have mentioned today that we really want to
make sure we have already in place before we
start filling these prescription orders
But I think it is also important
as products become available on the market
that go through this pathway the material
about the new product just as with any new
product to clearly indicate that here may be
something different with filling these
prescriptions This is a biosimilar This is
interchangeable with X reference product
That type of information should clearly be
indicated not only in the labeling but the
information and awareness about that product
marketing materials as with normal new
prescription products
PANEL MEMBER KOZLOWSKI So thank
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you Dr Bough I thought you raised a number
of very important points I wanted to ask
that one particular thing you mentioned was
names and databases
So there are a variety of reasons
that there can be errors in leaving suffixes
or any changes you might have in a name Some
of them are database limitations Some of
them are human limitations in terms of data
entry So we would be curious if you could
supply in more detail to us more thoughts
about where those problems exist
And then on a related topic we
have heard reference to NDC codes And
certainly many outpatient pharmacies track
everything by NDC codes We would kind of be
interested in the APhA perspective on when
that is captured and when it is not and in
what context
DR BOUGH Okay We can
certainly provide some additional information
in our written comments And there is one
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variation on how NDCs are used whether it is
inpatient or outpatient So we wouldnt want
to create anything that is different from kind
of tracking that we can do now but make sure
it is integrated and not kind of siloed just
because these might potentially biosimilar
products
There is lots of improvements from
a technology perspective on better or
decreasing the option for potential for error
with order entries and transfer the
information from electronic platforms are
written but we will be happy to work with some
of our other pharmacy colleagues to provide
some additional information So thank you
PRESIDING OFFICER SHERMAN Ms
Esposito
PANEL MEMBER ESPOSITO Thank you
I will make it quick because I know we are
out of time
Following up on Dr Kozlowskis
comment I was going to ask a question related
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to naming Since it sounds like you will be
submitting additional information to the
docket if you have specific recommendations
for naming conventions that APhA thinks would
work for all of the different -- satisfying
all of the different factors we have
discussed including pharmacovigilance that
would be helpful
And also I dont think we have
your statement in the record so I would
encourage you to put your full statement in
the record so that we have it for reference
DR BOUGH Will do Thank you
PRESIDING OFFICER SHERMAN Thanks
for your comments
Our next speaker is Everett
Neville Express Scripts
MR NEVILLE Good morning and
thank you for the opportunity to present
today
My name is Everett Neville I am
the Chief Trade Relations Officer at Express
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Scripts I am a pharmacists by training I
spent the first ten years of my career in
hospital pharmacy and the last 14 years I have
been on the payer side
Express Scripts is a pharmacy
benefit manager We administer the pharmacy
benefits of approximately one hundred million
Americans So I guess I am here representing
the much maligned payer perspective today
Additionally we own specialty
pharmacies that are responsible for dispensing
about 30 percent of all retail biologics that
go through a pharmacy So we bring that
perspective or I bring that perspective as
well
When Congress passed the BPCI
certainly the purpose of that was to allow
pathway for biologics and inherent in that
were interchangeable biologics The rationale
for enacting this Act clearly had to do with
the cost of biologics In fact they submitted
to the CBO this Act and it was scored at about
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25 billion dollars over ten years
From the payer perspective we
have a real problem today with biologic costs
As you can see the overall trend for drug
costs is trending in the single digits
typically around three percent Biologics are
well into the double digits 17 percent last
year as much as 20 percent in some of the
recent years and we predict that will
continue for the foreseeable future This is
not just on new products by the way The
overall increase in existing biological
products was over ten percent last year for
products already on the market many of which
have been on the market for as much as a
decade
We dont look at cost though
strictly as -- this is not about how much
money the greedy payers can make Cost is
about affordable healthcare and affordable
healthcare is about access The best
medications in the world if they cannot be
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taken cannot be afforded by patients do not
benefit those patients So we believe this is
an extremely important healthcare issue
I want to spend a few moments on
interchangeability I am certainly not a
scientist but as a previous speaker addressed
earlier today the science of highly
analytically similar drugs is a science It
is well-known and can be attributed that way
We believe that with the use of that science
that the use or need for clinical trials can
be limited Where it is necessary it
certainly should be done but they should be
limited as a science directs We would like
to see guidelines that allow for flexibility
by the FDA depending on the molecule As you
know biologics are not universally complex
Some of them are much more complex than
others Some of them are much more larger
molecules than others
The level and the degree of
clinical studies should vary based on what the
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science dictates We dont want to see
clinical trials essentially as a barrier to
interchangeability
I would like to commend the panel
on the draft We found much that we liked
there Certainly and I am going to hit a few
points certainly we would have preferred to
see less than a 12-year marketing exclusivity
in the Act but we believe that is workable for
all sides It protects the innovators as well
as the cost side of the equation
We commend you on your indication
that you would allow the use of non-US data
as we believe that the quality of research
particularly in Europe is sound Also with
the use of foreign-source comparator products
We believe that is important in order to make
the clinical trials that will be required
cost-effective and not prohibitive
We also commend your allowance or
the indication that there may be some
allowance for the extrapolation of indications
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as these indications expand on the innovator
products
And lastly in what has certainly
been a focus today I wanted to discuss the
naming convention And Im sorry that is a
typo That should be IND We believe it is
absolutely imperative that the same
nonproprietary generic name be used If you
do not allow that you effectively have no
interchangeability in our healthcare system
So that would from our perspective make that
impossible to do
Today drugs essentially reach the
public in three ways in the American
healthcare system And with biologics
approximately half of them come through a
pharmacy Pharmacy dispensing requires and
uses an NDC which is more specific It even
tells you the package size The vast majority
of pharmacies by the state law actually even
track lot numbers I know in our pharmacies
we track it down to the lot number not just
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the NDC
The second pathway are through
hospitals Most hospitals also track those
drugs through NDCs and they certainly track it
from a purchasing point of view They dont
purchase multiple manufacturers in a time
They typically strike contracts and purchase
one manufacturers product as a time until
that is used and a new contract comes into
play Having worked in hospitals it is not
hard when you have an adverse event to track
it back to which product is used
That leaves the third alternative
which is that dispensed in a physicians
office or a buy and bill model I would posit
that if physicians dont know what they used
that is not going to be solved by giving it a
different name in convention That we may
want to have more robust tracking required at
the physicians offices but that would be the
change I would recommend not changing the
names Changing the names creates very
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difficult processes with changing in
interchangeability as was referenced by the
APhA pharmacists what prescription do you
use
Additionally there is a real risk
that a patient who is on one product gets a
prescription when they go into a teaching
hospital and is sent back to the community
feel that a separate pharmacy that that
pharmacist fills that product the patient
doesnt realize they are the taking the same
product twice because they have two different
names and that continues for some period of
time I think that is a real healthcare
risk not something to be minimized
Thank you
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel Ms Maloney
PANEL MEMBER MALONEY Thank you
for your comments I had a question on the
naming and I think I heard you say you support
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the same name for interchangeable products but
Im not sure I heard you speak to the name
with regard to biosimilar products
MR NEVILLE For biosimilars I
would support the same naming convention for
the same reasons that the risk of prescribing
essentially the same medication twice the
difficulty in tracking and lining up adverse
drugs checking engines that also look for
those as well as just confusion within the
marketplace
But I think that if it does not
occur then interchangeability cant happen
So I would support it on both and I think it
is absolutely essential for an interchangeable
drug
The other problem you would have
if you dont use it on both if a product comes
out and it is not interchangeable because you
are requiring a different level of studies and
those are completed one or two years later
does the product change its name
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PANEL MEMBER MALONEY Just a
follow-up question Do you have concerns that
when the product is not interchangeable if the
same name is used that there might
substitutions
MR NEVILLE I do not because
that exists today I mean the filo of a 4C of
a 3C where there are products that are not
interchangeable They are not AB-rated and
they cant be interchanged today
So that exists today where you
have products with the same name that are not
interchangeable That has not proven to be a
problem within the system
PRESIDING OFFICER SHERMAN Ms
Esposito
PANEL MEMBER ESPOSITO Thank you
I have a follow-up question on the patient
safety issue that you perceive associated with
the potential for double prescriptions
I guess the first question is
whether you have any data that would suggest
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that that is a real risk and if so to what
extent Is there quantitative data to suggest
that this is a risk
MR NEVILLE I dont believe we
would have that because it doesnt exist
today So we dont have a situation where
drugs have the same two different names for
the same drug that I am aware of at the
nonproprietary level
So again my comment is that is
the way the system works today Why would we
change it
PANEL MEMBER ESPOSITO And are
you aware of any literature or social science
studies that looked at this issue even though
we dont have those on the market today
MR NEVILLE I am not
PANEL MEMBER KOZLOWSKI So you
mentioned a variety of ways in which products
can be tracked through NDC codes et cetera
So there are adverse event reports but there
is a whole variety of other sources of data
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and Sentinel is an example and I think it was
mentioned earlier of using a variety of
databases claims databases medical records
that are electronic if they are available and
integrating them
And so I think the issue of
identifying products goes beyond necessarily
what gets submitted through MedWatch So I
was wondering if you could comment on whether
or not the strategies you mentioned would work
in that broader environment of surveillance
MR NEVILLE And I will tell you
I am not an expert on pharmacovigilance
Certainly I work within those systems But it
would be my understanding when those other
Sentinel and other indications show that there
is a potential problem there needs to be
considerable more investigation of potential
studies and evaluation after that And even
today were that to occur you wouldnt know if
that was a for example a problem related to
the packaging that contained one type of
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rubber in the top of the syringe or another
At some point in order to make that workable
and to issue a recall or to change warnings on
a package insert you still have today when we
have multiple products and package sizes in a
market have to get additional research and
have to get additional data But I am not an
expert in that area so I am not familiar with
any specific issues related to them
PRESIDING OFFICER SHERMAN Other
questions
I have one The only published
data we are aware of is Platt and colleagues
where they looked at the ability to trace this
type of product in a Sentinel type of
environment without a unique name And their
conclusion was that it was not possible And
we heard from previous speakers that the
ability to be able to identify which product
is causing a problem is very crucial So
perhaps your organization could look at the
published literature and other data you have
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and then put a response to dockets either
supporting your recommendation that the name
be the same or discussing how we have as an
agency might track and trace the problem
without that
MR NEVILLE I would be happy to
do that
PRESIDING OFFICER SHERMAN Great
Thank you
Our next speaker is Kristin Bass
from the Pharmaceutical Care Management
Association
MS BASS Good morning everybody
I am Kristin Bass I am the or PCMA
Senior Vice President for Policy and Federal
Affairs for the Pharmaceutical Care Management
Association or PCMA We represent the
pharmacy benefit managers again the much
maligned payers and are very pleased to be
here today
Our companies our member
companies cover the benefits for about 210
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million Americans who have coverage through
private payers through Medicare through
TRICARE essentially across the panoply of
health benefits Our members also operate
specialty pharmacies that focus on managing
high cost complex biological medications as
well as mail-service pharmacies that dispense
prescriptions to millions of Americans
We appreciate the opportunity
again as I said And we appreciate your
leadership in working through the pathway
PCMA strongly supported the pathway as it was
developed through the statute and is very
pleased that this is proceeding We believe
that with the pathway competition can enter
the market And we think that competition
will be crucially important to getting
medications that are life-saving and life-
altering to patients at a more affordable
cost
And we think that will benefit not
just the patients but obviously our whole
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healthcare system because if we constrain
costs in one area we have more money to spend
in other areas
While we really appreciate your
guidance documents wet think that they
represent an overly cautious approach that
doesnt build on the experiences and
guidelines of other highly regulated markets
that have approved biosimilars For instance
the experiences in Europe should be built on
to a greater extent than currently is
reflected in your guidance documents
We are concerned that the overall
effect of the draft documents will delay
development and approval of safe and effective
biosimilars mostly around the issue of
interchangeability We are disappointed that
the draft documents dont go further in
offering requirements for interchangeability
We urge the FDA to accelerate development of
guidance in this critical area We note that
the guidance basically said that you are
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continuing to consider the type of information
sufficient to enable FDA to determine whether
a biological product is interchangeable with
a reference product and we saw a presentation
a little earlier suggesting ways to do it We
believe that the work that you have done
already on biosimilars as manufacturers have
changed their products in areas in which you
approved a change a manufacturing change and
designated that product as interchangeable
helps to pave the way for your development of
interchangeability with biosimilars
And we also think that you have
worked on interchangeability with respect to
distinct biologics in the case for instance
of the Omnitrope being the therapeutic
substitution for Genotropin in the growth
hormone market So we urge you to consider
all of the advice that you have been given and
put out some more specific guidance on this so
that you can accept applications and make a
determination more quickly than later
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We think that if you dont do that
there is going to be an unnecessary delay in
bringing lower cost equally safe and
effective crucial medications to patients We
think that access and affordability for
biologics cant be realized without
competition as I noted earlier And we think
that the abbreviated pathway will offer an
opportunity for competition
With the cost of biologic and
specialty medications increasing by double
digits each year as Everett pointed out
greater availability of lower cost actions
will be an enormous benefit to patients and
the entire healthcare system
By analogy an analysis for IMS
Institute for Healthcare Informatics shows
that the use of generic prescription drugs in
place of brand name counterparts and this is
on the small molecule side saved the US
healthcare system more than 931 billion
dollars in the decade between 2001 and 2010
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In 2010 alone generic use generated more than
150 billion dollars in savings
If the FDA approves even a few
biosimilars as interchangeable just one year
earlier than your currently overly cautious
approach would likely allow the savings for
patients employers and the system as a whole
will be millions of dollars We urge you to
create an environment of regulatory
predictability for biosimilars that encourages
sponsors to invest in their development and to
submit applications We look forward to
continuing to work with FDA and other
stakeholders to implement the rules for
biosimilar products in a way that doesnt
restrict patient access to medications
Thank you and we appreciate the
opportunity to be here at this meeting
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel
PANEL MEMBER ESPOSITO Thank you
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for your comments I have a question You
mentioned or touched on in your opening
statement that you would encourage the FDA to
leverage the EU biosimilars experience Can
you elaborate on what you meant by that and
areas that you think work well that we should
be considering
MS BASS I would refer to Dr
Vink who is going to testify later on behalf
of Mylan and he will be able to answer that
question I dont claim to be a scientist but
we can get you some answers for the record
PRESIDING OFFICER SHERMAN Ms
Maloney
PANEL MEMBER MALONEY Thanks
again for your comments I was trying to
understand if there was a biosimilar and not
an interchangeable product what activities or
actions might your organization take with
regard to that such an approval
MS BASS Can you ask the first
part If there was a biosimilar and not -shy
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PANEL MEMBER MALONEY That was
not interchangeable Would that effect what
products you made available on your formulary
MS BASS So we are the trade
association for the PBMs Typically the way
therapeutic substitution currently works in
our member companies there is a difference as
you know between therapeutic substitutions and
generic substitutions Our understanding
would be that if there were
interchangeability it would act as generic
substitution currently acts If there were
not interchangeability then I think that our
PampT committees would be in a situation in
which they would think about therapeutic
substitution and would have to think about
formulary placement and tiering and those
sorts of things under that rubric And I am
sure Everett can elaborate on that if you
would like or if you would like him to
PRESIDING OFFICER SHERMAN Other
questions
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PANEL MEMBER KOZLOWSKI So to
follow up on that you mentioned that
Omnitrope is part of the therapeutic
substitution program now So that is
something that has been initiated by what
group and is it being studied in some way
MS BASS So if there is a
substitution there my assumption is that it
is some combination of patients and physicians
probably working with their health plans on
what is most effective for the patients in the
context of what is also cost effective for the
plan
Are there studies on that I
dont know the answer to that
PANEL MEMBER KOZLOWSKI I think
that it is very useful as it has been
mentioned that sometimes products are switched
and may have occurred in Europe in sort of
data around those switches actually very
useful information And so if there are
programs to move from one product to the
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other it would seem being able to at least
capture some surveillance data around that
would be useful
MS BASS Agreed Agreed We
mentioned that instance as an instance in
which we believe that you have the scientific
capability of judging biosimilarity and
interchangeability and we are just using that
as an example to encourage you to not be
overly cautious but to actually move forward
PRESIDING OFFICER SHERMAN I have
a question You emphasized interchangeability
quite a bit We have the guidances that we
have put out to date the three documents that
are under your consideration address
biosimilarity You did not talk about or I
think you seemed to imply that without
additional guidance on interchangeability the
pathway the biosimilarity was somehow either
not as clear or less attractive Am I reading
your comments correctly
MS BASS Our understanding from
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our member companies and again the way that we
put together our comments on this is to talk
to our member companies talk to the generic
manufacturers to get their perspective And
what we have been hearing from folks is that
given that lack of predictability they arent
sure that they will use the abbreviated
pathway
And so from our perspective what
was the point of establishing getting the
statute done and trying to establish a pathway
if folks dont think that it is going to be
useful to them to use
So we just threw that out there
PRESIDING OFFICER SHERMAN Okay
thank you Thank you for your comments
Our next speaker is Neal Parker
from Abbott Laboratories
MR PARKER Good morning
everyone My name is Neal Parker I am an
attorney with Abbott a global broad-based
healthcare company headquartered in Abbott
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Park Illinois And on behalf of Abbott I
would like to thank FDA for the opportunity to
present today
Abbott as a healthcare leader is
keenly interested that patient access to
innovative therapies long-term is maintained
If companies like Abbott dont keep on
discovering new therapies eventually there
wont be any new biologic treatments for
biosimilar companies to reference
FDA must therefore we believe
implement the BPCIA in a manner that both
increases access to biotherapies for a greater
number of patients but also preserves
incentives for companies like Abbott to
continue to discover study and get approved
new innovative biologic products
So today my remarks are going to
focus on two specific areas use of non-US
comparator products in biosimilar applications
and also protection of reference product
sponsor trade secrets during FDAs review of
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biosimilar applications
Now on the first issue FDA
discusses in I believe all three of the
guidance documents the drafts the potential
use of data comparing a proposed biosimilar
product to a non-US-licensed product in
order to demonstrate that the proposed
biosimilar is highly similar to the USshy
licensed product that has been identified as
the reference
We at Abbott are concerned that
the proposed approach in the draft guidances
may not comport with the Agencys statutory
authority Our position is that data from
studies involving a foreign comparator product
cannot be considered pivotal if the foreign
comparator is different than the US
reference product If the comparator product
is anything less than the same as the US
reference if it is just similar to the US
reference or if it is highly similar to the
US reference or if it is biosimilar to the
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US reference then the utility of such data
has to be limited
The task of the biosimilar
applicant after all is to identify and
address residual uncertainties about
differences between its proposed biosimilar
and the US reference product But comparing
a proposed biosimilar to a foreign non-
licensed non-US reference product and then
trying to compare that non-licensed non-US
comparator product to the US reference by
adding a third and a different product into
the mix seems to us to just increase rather
than alleviate those residual uncertainties
Now under the statute and that is
what I have put up on this slide the
reference product has to be the single
biological product licensed under a US BLA
against which a proposed biosimilar is
evaluated If the proposed biosimilar
compares itself or to use the words of the
statute is evaluated against a non-USshy
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licensed product and the resulting data
provides a basis for approval licensing of the
proposed biosimilar application then the non-
US-licensed product has either become the
reference product or else it has become a
second reference product and the statute
expressly forbids this
The second topic that Abbott would
like to raise is the need to adequately
protect reference product trade secrets during
FDAs review of biosimilar applications
Now just a note here There are
specific concerns related to the protection of
BLA data submitted to FDA prior to enactment
of the BPCIA and Abbott has raised these
issues separately in another form with the
Agency
Here today at this hearing I want
to emphasize that my remarks are limited and
focused on innovator data which is submitted
to FDA after the date of enactment of BPCIA
Now with respect to such data
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nothing in the statute authorizes access to
the innovator BLA or direct use of the actual
trade secrets in the innovators application
by either the biosimilar applicant or the
Agency But we at Abbott are concerned that
the Agencys guidance omits any discussion or
reference to this important topic
Specifically we think safeguards are needed
to ensure that the Agency doesnt
unintentionally inadvertently but
nevertheless impermissibly use or disclose to
a biosimilar applicant an innovators trade
secrets
The major safeguard that we think
is needed is to prevent FDA reviewers who
worked on specific US-licensed innovator BLA
products from reviewing biosimilar
applications that reference those same
specific innovator BLAs We actually think
the law compels FDA to take this step
Our concern is rooted in the idea
and the concept of bias Now both law and
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science recognize bias as something that needs
to be controlled So for example in clinical
investigations for example double-blinding
investigators to patients receiving placebo
versus study drug is done because it is
recognized that it is impossible to prevent
subconscious knowledge from impacting
behavior Likewise FDA has expressly
acknowledged that comparable concepts of bias
affect FDA reviewers
Here for example on this slide the
first quote on this slide is from a senior FDA
official testifying before Congress on the
biosimilars law I am going to read this
quote just because it is so directly on point
This was acting Commissioner Crawford I
believe said this Reviewers are sometimes
unavoidably conscious of information in a
prior application even without physically
consulting the application simply because they
recall the information from having worked on
the earlier review Now in the law likewise
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Page 165
they have a way of handling these situations
So for example lets say that you have an
employee of one company that has access to
trade secrets about a product and that
employee takes another job at another company
competitor who makes a similar product courts
will find in circumstances like this they will
find what is called inevitable disclosure In
other words they will find that the
likelihood that the employee in a situation
like this will inevitably use the trade
secrets from former employer is so apparent
that the courts will issue an injunction to
prevent that from happening
Now what I personally know to be
true from my 20-year plus career doing this
kind of work both in industry and my years at
FDA and in the government is that FDA
scientists and government employees almost
without exception strive to follow the law
and to protect innovator trade secrets I do
know that to be true But again to be clear
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what Abbott is concerned about is subconscious
bias
So we have some potential
safeguards and we request that FDA consider
adopting these safeguards along the lines on
this slide to ensure that trade secrets in
reference product BLAs are not disclosed or
used during biosimilar product development
meetings or while reviewers are reviewing
applications
I am not going to read these to
save time They are up on the slide They
are also in our written comments But they
are generally guardrails to protect against
the source of trade secret violations that I
think we should all be concerned about
Again I want to thank you for
allowing Abbott to present today and if you
have any questions I am more than happy to
hear them
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
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Page 167
panel
Maryll
PANEL MEMBER TOUFANIAN You had
mentioned in the first component of your
comments the reference to the single
biological product It seems from your
comments that you werent objecting wholesale
to the use of non-US comparator data but not
using it as a pivotal mark It almost seems
like there was a tipping point after which you
think such reliance would be or such data
would be inappropriate Could you elaborate a
little bit more on that
MR PARKER Yes this is a key
question I would be happy to
We think words like supportive or
corroborative I actually dont think those
are very helpful There is a model here
essential to approval In the Hatch-Waxman
context FDA has 30 years of experience
assessing whether data submitted to FDA is
essential to approval for a condition of use
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If it is you get three years There is case
law on this There is the Upjohn case on
Rogaine It involved a switch of a product
And there was a study done I think it was a
switching study And Bob Temple after the
fact wrote a memorandum on this and at issue
in the case was whether that study submitted
by the sponsor was essential to approval And
FDAs position and it is supported by the
preambles it is a but-for test What the
court did and what FDA does when looking at
these kinds of studies is but for this study
this bit of data could we approve the
biosimilar application
Now if the Agency answers that no
we needed this study otherwise the biosimilar
would not be approved then we believe that
the test has failed and that product has
become a reference product It is really a
but-for test
PRESIDING OFFICER SHERMAN Other
questions
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I have one not being a lawyer I
can ask a clinical question So Europe
because they are ahead of us there is a large
randomized controlled trial of a thousand
patients and there is a very rich source of
data human experimentation What do we do
with that information How do we -- Are you
suggesting we put it on the shelf and try and
reproduce it
MR PARKER Well under what
conditions was the data gathered I mean
what product Was this data of a proposed
biosimilar to a European reference product
PRESIDING OFFICER SHERMAN Lets
say we are confident that the product in that
study was biosimilar not identical using -- I
dont know what identical means but not
identical -- but was biosimilar
MR PARKER Wasnt the same
stuff
PRESIDING OFFICER SHERMAN Wasnt
made in the same -- Well Steve would have to
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comment on that but wasnt the same yes
MR PARKER Right Well we dont
believe that that data satisfies the statutory
standard to be allowed to be used as pivotal
for approval of a US biosimilar
PRESIDING OFFICER SHERMAN But it
could contribute to our thinking
MR PARKER It could -- What we
are talking about today it was the prior
question is the but-for test
Scientists and FDA reviewers need
to look at stuff They like data If someone
is going to present a body of data there is
no way we are going to say no you cant look
at it The question is to what extent can it
be used to approve the product And it is a
question a statutory question we believe that
there is a limit here There has got to be
one reference product and the studies to
support approval of a proposed biosimilar if
they are evaluated against the proposed
biosimilar evaluated against another product
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it has got to be evaluated against the US
reference product
PRESIDING OFFICER SHERMAN And I
have two questions on this last slide The
first is do you have does Abbott have
concerns these types of concerns in other
environments other than biosimilars Because
I can tell you as a former reviewer I reviewed
many different it was on the drug side many
different applications from many different
manufacturers
MR PARKER Yes it is a good
question too You know so if you are not in
a follow on statutory context you are just in
the same division and you have got two
innovators the sensitivity to trade secrets I
believe isnt as acute because the subsequent
product still has to come up with a standalone
full package and it has got to stand by
itself And so the familiarity of one
reviewer with another product I dont think is
as acute there And so these questions dont
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arise in that context If you look at other
follow on product context I guess with ANDAs
and the 505(j) application because you have
the sameness standard again I dont think the
familiarity applies
Now in the (b)(2) context I think
there may be some crossover And frankly
FDA there have been instances where FDA has
run into issues regarding reviewer access on a
505(b)(2) to the reference product And it is
an area where there could be more transparency
on the part of the agency and some of these
issues may apply
PRESIDING OFFICER SHERMAN So
since we are out of time I could just ask
again as a former reviewer this has
logistical nightmare qualities to it But to
the extent in your submission to us you can
define significantly and so forth and really
talk about how you would want to see that
implemented would be very helpful to us
MR PARKER And if I can respond
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I understand And what we are asking for as
Abbott is a rule of reason here Obviously
in a hierarchy of the Agency and I am quite
familiar with this someone has to sign off on
ultimately every approval Im not saying you
need different sign-off It is reviewers who
are significantly materially involved in the
review of one product that we think steps
should be taken to ensure that subconscious
bias does not affect those reviewers when they
are confronted with a biosimilar for that same
product
PRESIDING OFFICER SHERMAN Okay
thank you for your comments
PANEL MEMBER KOZLOWSKI One quick
question
MR PARKER Sure
PANEL MEMBER KOZLOWSKI This
would also apply to reviewing multiple
biosimilar products So no reviewer could
review the same biosimilar products
MR PARKER Again you could keep
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spinning this out and what we are asking for
is a rule of reason I think at some point if
the Agency could recognize the issue of trade
secrets and the issue of subconscious bias in
a way that certain safeguards could be set up
reasonable safeguards this is an area of
transparency where I think it would be
worthwhile to at least begin the discussion
towards ensuring that trade secrets wherever
they exist within the Agency are adequately
protected
PRESIDING OFFICER SHERMAN Thank
you for your comments
Our next speaker is Joseph P
Miletich from Amgen
DR MILETICH Good morning
Thank you for the opportunity to comment
today My name is Dr Joe Miletich I am the
Senior Vice President of Research and
Development at Amgen one of the worlds
leading healthcare biotechnology companies
Since 1980 Amgen has been
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discovering developing and delivering
innovative human therapeutics As a leading
provider of high-quality biologic medicines
we plan to use our expertise to produce
biosimilars as well Consequently we
understand both the challenges and the
opportunities biosimilars present
We at Amgen appreciate the FDAs
efforts on the guidelines and we encourage
adoption of a thorough review and approval
process However Amgen believes some changes
and additional clarity are needed to advance
patient safety and to promote confidence in
biosimilars marketed in the United States
We have provided detailed comments
in our submission but with the limited time I
have today I would like to focus on some
important points for the FDA to consider
Biotechnology is an evolving
field While much more is known today than 30
years ago FDA guidance documents should
candidly acknowledge that there are some
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things we still do not know today It is
important that the Agencys policies account
for this FDA is seen as the leading source
of expertise and the steps taken by FDA to
implement the biosimilar program will be
modeled around the world
As we have previously stated
patient safety must be a non-negotiable
priority both for the FDA and for
manufacturers However focus on safety does
not end with drug approval We believe that
it is essential that FDA first adopt policies
that facilitate the attribution of adverse
events and that foster manufacturer
accountability second conduct a
communication campaign about biologics and
biosimilars and third foster supply chain
stability
So first FDA policy should
facilitate attribution of adverse events and
foster manufacturer accountability Tracking
and tracing all biologics not just
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biosimilars throughout the product lifecycle
is important We know from experience that
biologics can be highly sensitive to small
changes that could in turn lead to
unexpected clinical implications The
challenge and importance of accurate tracking
and tracing will increase significantly with
the arrival of biosimilars in the US
marketplace Today there is often only one
and certainly no more than acute products in
the class of biologics However when
multiple manufacturers are marketing different
versions of a medicine identification of
exactly which product a patient received will
be far more difficult We believe prompt
identification and resolution of product
problems will be facilitated by
distinguishable established names Whereas
products sharing the same name would
definitely confound the attribution of adverse
events
Amgen urges the FDA to implement a
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policy of biosimilars sharing a common root
with a reference product but requiring every
biologic to have a unique suffix possibly a
Greek letter or the manufacturers name For
example monoclonal mAb gamma or monoclonal
mAb Amgen Distinguishable product names
facilitate manufacturer accountability and
avoid incorrectly implying that the molecules
are identical
Second in addition to guidances
FDA communication to stakeholders will play an
essential role in the safety and success of
biosimilars The biosimilars approval pathway
is a new initiative in the US with many
scientific and administrative challenges and
nuances These could have important
implications for patients healthcare
providers states payers other federal
agencies and more as we seek to introduce
this new class of medicine into the healthcare
system
It will be essential for FDA to
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clearly communicate to all stakeholders what
biosimilar products are and what they are not
For example there should be no perception
implied or otherwise that an FDA approved
biosimilar is somehow less effective or less
safe than the reference product However
biosimilars are not appropriate for automatic
substitution that is without the explicit
consent of the prescribing physician unless
deemed interchangeable by the FDA
This information is important not
only for patients but for all stakeholders
Doctors making prescribing decisions payers
implementing formularies state and federal
agencies putting policy in place all face
important decisions that will define the
success or failure of the introduction of
biosimilars into the healthcare system
FDA has a track record of
successful healthcare professional outreach
programs that have included public
presentations conference exhibits brochures
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and webinars We urge the FDA to execute such
a program for biosimilars
Among the first priorities for FDA
communication should be the message that
patient safety is a collective effort It is
important that healthcare providers are
prepared for the essential role they play in
the accurate attribution of adverse events in
light of the increased number of similar
products on the market Doctors and
pharmacists are on the front lines and will
often be the first recognize or to be alerted
when a problem is associated with a biologic
Accurate records will facilitate the correct
product identification
Third FDA policy should foster
supply chain stability Making biologic
medicines whether innovative or biosimilar is
neither straightforward nor easy Biologics
have complex manufacturing processes and today
require significant investment to deliver high
quality and reliable supply both critical to
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patient safety
Recent medicine shortages have
been an opportunity for some manufacturers to
suggest that FDA standards are overly
rigorous This is exactly wrong Complex
products require high standards It is by
maintaining appropriately robust GMP and
facility inspection standards that FDA assures
the public reliable supply of high-quality
products
Amgens vision is to produce high-
quality products more efficiently and at lower
cost We will achieve this through precision
and predictability not through lower
standards Pretending biologics manufacturing
is simple will not make it so To borrow a
quote all things are difficult before they
are easy In time the science of
biotechnology will evolve to where meeting the
necessarily robust standards set by the FDA
will be easier and less expensive Indeed in
ten years biotech manufacturing will look
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much different than it does today Between
now and then there is much hard work to do and
we are committed to it
In summary the biosimilar
approval pathway presents opportunities and
challenges Manufacturer accountability FDA
communication and supply chain stability all
play essential roles in advancing the safety
in biologics
Thank you for your time
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions
PANEL MEMBER MALONEY Thanks for
your comments I had a question on the first
point you made about attribution of adverse
events and fostering manufacturer
accountability And my question goes to the
latter the manufacturer accountability Are
you making a different point there Something
in addition -shy
DR MILETICH Im sorry I dont
understand your question
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PANEL MEMBER MALONEY The
question is when you talk about fostering
manufacturer accountability are you saying
something in addition to this notion of
attribution of adverse events
DR MILETICH The comment about
manufacturer accountability is that we believe
without distinguishable established names
that it is not possible to attribute adverse
events to the correct manufacturer And we
believe that any reputable reliable
manufacturer would want to know about the
adverse events that might be connected with a
product so that they could investigate and
correct a potential problem
PRESIDING OFFICER SHERMAN Heidi
PANEL MEMBER MARCHAND Thank you
very much for your comments One of your
points that you are making is that you would
suggest that FDA have a communication with
stakeholders The FDA recently has done a lot
of things such as using social media
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teleconferences webinars Can you talk a
little bit about how you might see that
campaign being effective and timing of it
DR MILETICH Regarding the
timeliness it would be great if it was ahead
of the introduction of biosimilars into the
marketplace of course
In terms of an example the bad ad
campaign was a particularly good example I
think of effectively reaching stakeholders and
making people aware of a problem and what they
should do and act And that is one that could
be emulated
I would also add that in terms of
influence where the FDA may not have actual
statutory authority for example around
substitution education campaigns directed at
those who do could be exceptionally helpful
such as toward state payers and other
influential individuals
PRESIDING OFFICER SHERMAN Other
questions
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PANEL MEMBER ESPOSITO You spoke
a little bit about naming in your support of a
distinguishable name and I think you made
reference of a suffix as an example And we
heard earlier today that there might be a
logistical problem with a suffix either not
being in the original prescription or database
limitations that might drop off a suffix
Have you thought about other naming
conventions that might be distinguishable and
can you speak a little bit to Amgens view on
that
DR MILETICH I think the reality
of our current situation is that it is not
really possible to come up with a perfect
solution I think the idea here is
redundancy The idea is that we want
everybody who could be involved in recognizing
and reporting an adverse event to have as many
chances as possible to be able to correctly
identify the manufacturer So there probably
isnt yet even though it is aspirational that
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we would like to get there There probably
isnt a single system that is going to catch
everything I think redundancy is the key
here
PANEL MEMBER CHRISTL In follow-
up to sort of the labeling naming conventions
that we are talking about you had made a
statement that biosimilars are not appropriate
for automatic substitution unless deemed
interchangeable by FDA and then had gone on to
discuss FDAs role in communication and
outreach in that Does Amgen have a position
in terms of other ways to be articulating that
a product is biosimilar and not
interchangeable either through naming or
labeling or other ways that that communication
would occur to separate that a product is
biosimilar and not deemed interchangeable or
when it is approved as an interchangeable
product or is it just through education
DR MILETICH I think that we
would strongly advocate that labeling be very
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clear and that labeling indicate certainly
whether a product is biosimilar or
interchangeable We agree with the FDAs
position that interchangeability is currently
a very high standard I personally think it
is going to be a very difficult thing to prove
interchangeability So I think the label
should be clear The label should also be
clear about the distinguishable name We also
would advocate for very clear labeling
particularly in regard to transparency around
the data that was derived from clinical trials
with a reference product versus the clinical
data that was derived from the use of the
biosimilar if such was done
We have made some recommendations
about consistent labeling for biosimilars and
we would be happy to go into more details with
the FDA on those suggestions
PRESIDING OFFICER SHERMAN
Thanks So to the extent that we have heard
specific suffix is a good example specific
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recommendations for and against the suffix to
the extent that you could submit state it to
the docket if you have not already done so
and the same comment for Dr Bough that would
help us to evaluate
Thank you for your comments
DR MILETICH Thank you we will
do that
PRESIDING OFFICER SHERMAN Our
next speaker is Michelle Rohrer from
Genentech a member of the Roche Group
DR ROHRER Good morning Im
Dr Michelle Rohrer Vice President of US
Regulatory Affairs at Genentech Roche
Overall Genentech supports the
FDAs approach as outlined in the guidances
that is a science-driven risk-based approach
to determine biosimilarity As written the
guidance has balanced the need to assure
safety and efficacy for biosimilars while
allowing for an abbreviated pathway for
follow-on biologics
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Within the guidances themselves
there are issues that could benefit from
additional FDA clarification particularly
with regard to more clearly stating certain
expectations so that in the global setting
these expectations are not misunderstood as
optional when the requirements are truly
expected
In this presentation I will not be
speaking to Genentechs extensive commentary
on the guidances as these can be found in our
submission to the docket My remarks today
will focus instead on the need for unique
naming as has been mentioned previously
certain labeling considerations including
data and promotion guidance for biosimilar and
interchangeable products
Biosimilars are similar to the
innovator product but not identical And
therefore a unique name is critical for clear
identification safe prescription and
dispensing of medicines to patients We see
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four categories of biologic products needing
unique names These are 1) the innovator
molecule 2) related biologic products
approved under a full BLA 3) biosimilars and
4) interchangeable biosimilars
The need for unique names has been
discussed extensively in other forums and
indeed today here with the chief benefit
being the ability to identify the exact
product prescribed for and received by the
patient Having unique names will avoid
unintended substitutions minimize risk of
medication errors allow for essential
elements of pharmacovigilance such as
traceability and follow-up of adverse drug
reactions as well as facilitate prescriber-
patient decision making
In this proposed naming system
biosimilars would be distinguished from the
innovator biologic product by use of a unique
nonproprietary name The nonproprietary name
would include the same distinct additional
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stem as the innovator but would have a unique
suffix for each biosimilar of the innovator
and a unique prefix for biosimilar approved
as interchangeable
Now certainly we have heard issues
with implementing that idea in the system I
dont have an alternate solution today but I
think the point is that we need a unique name
that is simple and that can track that
molecule through the healthcare system
As biosimilars enter the
healthcare system the ability to distinguish
products by the name is critical as I said
for clear identification safe prescription
and dispensing of products to patients as
well as accurate adverse drug reaction
reporting In order to avoid reporting errors
on adverse drug reaction reports we propose
that both the nonproprietary and brand name
would be required on the report
We request that FDA issue guidance
to address this issue of unique naming after
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considering input from stakeholders This
additional FDA guidance would serve to
proactively define the standardized naming
system which will distinguish biologic
products in the marketplace and link adverse
events to the appropriate product Early
action by FDA will also help provide clarity
so as to avoid confusion among providers and
patients as well as to facilitate
harmonization on global nomenclature a very
important topic
Moving on from unique names to my
next topic labeling considerations for
biologics It is Genentechs position that
all biologic product labeling should first
acknowledge that the label information is only
applicable to that specific biologic product
Second clarify the data source
especially as certain data may come from tests
involving only the reference innovator
product
Third state that substitution
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between similar biologics by a pharmacist or
payer should not be allowed without the
consent of a physician And finally labeling
should state that switching patients between
similar biologic products should be avoided
unless the biologic is approved as
interchangeable This point is especially
relevant for biologics that are indicated for
chronic use
To accomplish this clarity in
labeling guiding principles are necessary
which follow existing principles for drug
labeling and are expanded to include specifics
for biosimilar labeling These guiding
principles are necessary to set expectations
so that biosimilar labels are clear non-
misleading and contain essential information
specific to the product These principles
could play an additional role in that they
would serve to transition the healthcare
system out of generic drug label mindset where
the labels are essentially identical to the
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brand label and this will not be the case for
biosimilar labels
Moving from the broad topic of
guiding principles to more specific
requirements should specify that labeling
should clearly state whether a product is
biosimilar or interchangeable Additionally
labeling requirements should clarify that any
differences from the innovator and reference
product should be detailed in each section
The requirements should also require a
labeling statement that all differences might
not be known at this time
Continuing on from the prior
slide biosimilar labels should be required to
be clear about which indications are supported
by clinical trial data and which indications
were granted based on extrapolation from
solely the referenced product data
Biosimilar labels should also state that there
is a risk to switching or substituting The
label should acknowledge that there may be
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differences between biologic product and that
prescribing decisions should be based solely
on information in the labeling
Finally we ask FDA to consider
whether interchangeable biosimilar labels
should address the issue of drift
specifically whether the labeling should warn
that products may not always maintain
biosimilar status
With regard to biosimilar
promotion in advertising we see a need for
FDA guidance For example a question and
answer on promotion and advertising of
biosimilars could be added to the biosimilar
QampA guidance to address how biosimilars should
or should not be promoted relative to the
reference product
In summary the three biosimilar
guidance documents are comprehensive They
provide a science-driven risk-based framework
for the development of biosimilars Genentech
encourages FDA to extend the guidance further
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to define uniform naming requirements and to
work globally to harmonize these unique naming
requirements
To support patient safety we also
encourage FDA to provide further clarity on
labeling of biosimilar products to facilitate
treatment decisions and safe prescription and
dispensing of medicines to patients This
further clarity on labeling will limit
unintended substitution minimize medication
errors and enable robust pharmacovigilance
And then finally further guidance from FDA on
appropriate promotion and advertising of
biosimilar products would help to support
patient safety and appropriate treatment
sources
Thank you very much
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel
PANEL MEMBER KOZLOWSKI So the
previous speaker said that these products
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should not be substituted unless the Agency
deems them interchangeable stated that it
would be a high bar but nonetheless stated
that if the Agency did deem them
interchangeable they should be substituted
Do you agree or disagree Because it wasnt
clear from your presentation
DR ROHRER We think that the
should clearly outline when a biosimilar has
achieved the interchangeable status And if
it has that interchangeable status then it
could be substituted
PANEL MEMBER KOZLOWSKI Right
But would it require a physician Because
again I think we were sort of thinking about
pharmacy substitutions and I thought you had
stated that it would require a physician
Maybe I misheard
DR ROHRER Well we believe that
the best situation is when the physician is
involved in the decision-making around the
product choice In the case of an
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interchangeable the physician would not need
to be involved
PANEL MEMBER KOZLOWSKI Okay
And then another question to clarify You
mentioned started off by saying
interchangeable products when you brought up
the question of drift but your bullet point
says may not maintain biosimilarity So I
just want to clarify Do you consider drift
an issue for biosimilarity as well as
interchangeability
DR ROHRER I think there could
be both As you know when you are
manufacturing a product there are
manufacturing changes and the comparability is
based back to your original reference So
both that biosimilar product would be
comparing back to its original manufacturing
license the changes to it as the reference
product is also changing referencing back to
comparability of its original license
And so at some point the question
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becomes do you need to reestablish
biosimilarity as well as interchangeability as
these products drift
PANEL MEMBER KOZLOWSKI And I
think I wonder whether one views biosimilarity
as making a link to the clinical data that
supported the originator product and then that
product now has acquired that information and
then it maintains that information
independently through its own process which
is a little different than interchangeability
So just to clarify do you have concerns for
both And apparently you do
DR ROHRER Yes
PANEL MEMBER TOUFANIAN Excuse
me You mentioned your discussion of unique
naming that unique names would be required not
only for biosimilars and interchangeable
products but related biological products
Could you provide Genentechs definition or
criteria you would suggest FDA use to identify
those products
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DR ROHRER I think it is
important that products have unique names
And certainly there are the four different
types of products that could be possible today
that I mentioned in the talk You could have
related biologic products approved under a
full BLA I think we have that situation
today with the EPO products Those have
unique names
PANEL MEMBER ESPOSITO Thank you
Dr Rohrer I have a question I appreciate
particularly your thoughtful comments on
labeling And you mentioned the following up
on the drift issue a recommendation that
labeling include the concept of drift and that
the product may drift away from the reference
product over time
The question I have for you is how
do you distinguish that from not having that
kind of labeling for any biological product
that may drift from its original license date
DR ROHRER I dont have a
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specific answer for you I think that this is
one of the issues that we wanted to put into
the melting pot here of ideas for us all to
think about how do we deal with this issue of
drift
PRESIDING OFFICER SHERMAN Dr
Marchand
PANEL MEMBER MARCHAND Thanks for
your comments I wanted to get your sense if
you thought about what would be a labeling for
biosimilars to the extent that the current
rule or regulations for labeling that exist
the PLR and just wanted to get your thoughts
if they have been developed to the point of
thinking about information relative to the
analytic data the reference product clinical
trials or data as well as the originator
DR ROHRER Are you asking if we
have specific ideas on those
PANEL MEMBER MARCHAND Yes As
you are thinking about what might be in
labeling So as we are thinking about how
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labels for biosimilars might look have you
thought through levels of detail as to the
kind of information that might be there like
the analytic data information with regard to
clinical trials for the reference product
originator
DR ROHRER I think we can take
that back and perhaps provide to you more
granular thinking At the moment we are
thinking quite broadly specifically around
the clinical trial data just would be helpful
to understand for example if the reference
product is being leveraged then how is the
comparison portrayed in the clinical data
section That some verbiage that would guide
biosimilar manufacturers as to how that would
look and then also that would inform the
marketplace what to expect And it is not
clear how differences would be described You
can look at adverse event tables today in the
current labeling situation and that is always
a case-by-case basis But for example if you
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look at adverse events how would differences
in adverse events between the reference
product and the biosimilar product be
described And we just think that some more
granularity guiding sponsors would be helpful
PRESIDING OFFICER SHERMAN Any
additional questions Okay thank you for
your thoughtful comments
We now have lunch Ala carte
items are available for purchase outside And
if we could reconvene at one oclock Thank
you
(Whereupon at 1158 am a lunch recess was
taken)
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A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N
(104 pm)
PRESIDING OFFICER SHERMAN
Welcome back I hope everyone had a good
lunch
So I am back trying not to butcher
peoples names Our first speaker of the
afternoon is Sumant Ramachandra
DR RAMACHANDRA Thats perfect
PRESIDING OFFICER SHERMAN Okay
we are off to a good start
DR RAMACHANDRA Thank you So
good afternoon to the FDA panel and to the
guests here for the public hearing Thank you
for the opportunity to speak to the FDA today
My name is Sumant Ramachandra and I am the
Chief Scientific Officer and Head of Research
Development in Regulatory and Medical Affairs
for a Lake Forest Illinois-based company
called Hospira
Hospira is a global leader in
biosimilars and is the only US-based company
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with biosimilars on the market in Europe and
Australia Our biosimilar EPO also known as
Retacrit is the leading product in the EU and
our biosimilar filgrastim known as Nivestim is
the only biosimilar competitor in the
Australian market as well as being available
in Europe
Hospira therefore has solid
experience in the biosimilar space that we
believe will allow us to intelligently pursue
the US market with scientific and clinical
integrity and thoughtfully contribute to the
regulatory guidance process Hospira is
pleased that the FDA has issued guidance
thereby demonstrating its commitment to making
this important class of medicines available to
US patients and we look forward to
continuing to partner with the FDA on the
development and implementations of the
guidance documents
To begin I would like to share
some of our general impressions of the
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guidance documents as published then
highlight some of the aspects we value and
want to see maintained in the final guidances
and then briefly mention specific areas we see
require clarification or modification to
facilitate effective implementation
It was clear that the FDA had
heeded the input of key stakeholders and
Hospira is proud to have been an active
participant in this process thus far both
through our input offered in public comment
forums and in our individual product-specific
consultations with the agency We are pleased
that FDAs published guidance documents are
generally consistent with our development
approach and that it provides a reasonable
framework within which biosimilar companies
can operate This framework describes a
scientifically rigorous approach and bases the
approval of biosimilars on the totality of
evidence put forth in a stepwise approach
The stepwise approach makes sense
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but Hospira would caution that this does not
always mean that everything needs to be done
purely in a sequential manner That is some
activities should be allowed to be conducted
in parallel to ensure efficiency in the
development process To that end Hospira
welcomes the Agencys invitation to seek
consultation early and often to ensure proper
alignment between the FDA reviewer
expectations and industry sponsors The broad
nature of guidances necessitates such
interactions to calibrate all parties on the
right approach that takes advantage of the
flexibilities afforded yet maintains the
discipline to rigorous signs and the
progressive reduction of uncertainty
Hospira is pleased with several
aspects of the guidance documents that support
an efficient and effective approach to
biosimilar development and would like to see
these aspects maintained in the final version
of the guidances Specifically Hospira
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values use of a non-US reference product
with appropriate scientific data bridging
ability to reduce the preclinical and clinical
requirements using bioanalytical
characterization extrapolation with
scientific justification and the ability to
incorporate product differentiation that does
not affect clinical safety or efficacy These
aspects of the guidance will enable biosimilar
development in a cost-effective and timely
manner without compromising quality or safety
There are however aspects of the
guidance that Hospira believes needs to be
clarified to facilitate the consistent
interpretation of the guidances and remove
ambiguity that could result in inefficiencies
in the development process To that end we
have submitted specific written suggestions to
the FDA based around the three guidance
documents quality documents the scientific
documents and the question and answer
documents And a summary of these suggestions
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are captured here
From a quality considerations
perspective Hospira has three primary
recommendations First FDA mentions extra
crystallography and multidimensional NMR
methods to assess three-dimensional structure
but other methods for example vibration
circular dichroism hydrogen exchange Raman
spectroscopy and Fourier transform infrared
spectroscopy can also be considered based on
the molecule being studied The emphasis
should be placed on using the correct method
as appropriate for the molecule
Second FDA should clarify how the
variability of reference product loss observed
over time should be used to set biosimilar
specifications When reference products lots
vary widely and we have seen they do in the
market sometimes then the applicant may
choose to define a narrower acceptance range
if scientifically justified
Third Hospira would like the FDA
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to clarify the degree to which impurity levels
need to be similar in order to realize relief
of pharmacological and toxicological
requirements The term similar levels used in
the guidance document is ambiguous and
difficult to interpret practically
From a scientific considerations
perspective Hospira has four primary
recommendations First we suggest that we
conduct toxicity studies in only one gender
if the data suggests no gender effect
Second we suggest rewording to clarify the
requirements of a clinical immunogenicity
assessment Third regarding clinical study
design Hospira suggests that the FDA
recommend a non-inferiority design in cancer
studies with an appropriate surrogate
endpoint provided that the safety profile is
not significantly different between the
biosimilar and the reference product
Finally in regards to
extrapolation biosimilar sponsors should be
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required to provide scientific data to
demonstrate that the mechanism of actions are
similar across extrapolated indications
Hospira applauds the FDA on the
incorporation of the QampA section of the
guidance documents This information is very
helpful to clarify FDAs position on aspects
of the guidance documents and we hope will
evolve over time to incorporate further topics
and clarifications Even with the QampA
section however Hospira would like
clarification on some areas that remain
ambiguous
With interchangeability the
guidance does not define the requirements for
interchangeability Hospira would like to see
the requirements defined ensuring that there
is only one standard that is the highly
similar standard for biosimilars and
interchangeable biologics With pediatric
requirements a waiver is allowed for
interchangeable biosimilars but what about the
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biosimilar that is not pursuing this
designation Hospira believes that pediatric
assessment should not be a requirement for
biosimilar development if the active
ingredient is already known and shown to be
highly similar to the originator
And in the area of immunogenicity
testing the guidance could be interpreted as
required to require a sequential approach to
immunogenicity assessment in accordance with
the stepwise philosophy This approach
however could protract biosimilar
development Hospira recommends the Agency
clarify that this assessment can be done in
parallel or combined with safety and efficacy
studies
In closing I again would like to
thank the FDA for the opportunity to
participate in this process and in this forum
We are generally pleased with the guidances
that have been issued and would appreciate
clarification of some areas of the guidance
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and have articulated these in our written
feedback While the guidance documents
provide a good framework and starting point
they are relatively broad and subject to
interpretation by the Agency and biosimilar
sponsors In some instances we believe that
clarification is necessary to tighten the
language and decrease the chance of divergent
interpretations between the FDA and industry
In other instances the flexibility will
serve to more efficiently advance these
important development programs We look
forward to working with the FDA to achieve the
proper balance while maintaining a commitment
to scientific rigor in the implementation of
these guidances Thank you
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel
PANEL MEMBER KOZLOWSKI So you
commented about including more methods in the
guidance So I think often when guidances
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talk about methods they are examples They
are not necessarily all-inclusive lists And
too much specificity has its own challenges
but we certainly invite you and your comments
if they are not already there to describe
what other things you think might be useful
for us to talk about
You also mentioned sort of
appropriate boundaries and variability of what
you are aiming to do So I think that the
challenge of statistics is a very difficult
one There may be different numbers of lots
and different situations So again we
welcome any input you might have on general
approaches to doing that
I think one comment you made and
this on the scientific consideration document
is reword the approach to the clinical
immunogenicity assessment So I wondered what
exactly you were referring to
DR RAMACHANDRA There is -- the
way the document is written it sounds like
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immunogenicity follows safety studies PK
studies and before potentially efficacy
studies As you know this sequential
approach will just prolong development And
the reality is that immunogenicity you can
actually maybe test for it in your preapproval
trials but it is measured over time
Sometimes the size you need to actually detect
rare events actually is really in the post-
market setting And I think what has to be
done is that you have to really ensure that
the preclinical data is very solid as well as
you have the appropriate measures within your
clinical trials whether they be phase 1 or
pivotal trials to measure for this knowing
that the statistical chance of finding
immunogenicity unless you have done something
very wrong with your product is very low So
that is what we mean by that
PRESIDING OFFICER SHERMAN Other
questions Thank you for your comments
DR RAMACHANDRA Thank you
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PRESIDING OFFICER SHERMAN Our
next speaker is Jay P Siegel from Janssen
RampD
DR SIEGEL Good afternoon I am
Jay Sigel Chief Biotechnology Officer and
head of Global Regulatory Affairs for Janssen
the pharmaceutical companies of Johnson amp
Johnson
I want to thank the FDA and this
panel for holding this hearing and for
creating an inclusive and transparent and
science-driven process for developing a
biosimilars pathway
Janssen has submitted extensive
comments on the document When I say
extensive I should say we find the guidance
to be in general very strong but extensive
comments of areas for additional
consideration guidance or perhaps
redirection of which I would like to highlight
three selected areas in the time available
One regarding the biosimilarity standard one
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regarding interchangeability and one
regarding extrapolation of indications
With regard to the biosimilarity
standard I specifically want to talk about
avoidable differences The guidance
contemplates in a number of places differences
that are not necessary It speaks about
differences between products introduced by
design It speaks about package and
container and formulation and N amp C terminal
differences that one would presume are
intentional and are avoidable
The fundamental drive for
biosimilars pathway is that there are
differences that cannot be avoided or at
least cannot be avoided with reasonable
practicality If that werent the case we
would have generic biologics But given that
we cant avoid differences and we recognize
that those differences carry certain risks of
potential clinical difference we have created
a biosimilars pathway and we require FDA
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requires and other regulatory bodies a high
degree of similarity and has provided draft
guidance now as to how to control and minimize
those risks what testing is necessary But
to allow extensively avoidable reasonably
avoidable differences is to expose patients to
avoidable risk
Not all the implications of
differences can be predicted All sorts of
differences certainly to the product but also
excipients impurities containers can have
unpredictable implications An interesting
example was the removal of albumen since that
is an example in the guidance document of what
was considered a minor difference and
therefore acceptable Removal of albumen from
erythropoietin formulations which was
requested by European regulators but
specifically not allowed by FDA because of
concerns about what it might to do the product
was a proximal cause of the emergence of pure
red cell aplasia in 2002 and 2003 or of an
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increased incidence including some fatal cases
in Europe and around the world but without any
change in the US because of the FDA approach
on this issue And I ask that you contemplate
that in thinking about whether removal of
albumen is really a minor issue and whether
that sort of avoidable change is something
that you risk that you want to -- because that
would not have been excluded by testing short
of testing tens of thousands of patients
So with regard to the draft
guidance we would urge the FDA to indicate
that reasonably avoidable differences in the
active pharmaceutical ingredient must be
avoided and that other reasonably avoidable
differences should be avoided that HSA
removal is not a good example of a minor
difference It should not meet the legal
standard of a minor difference so it
shouldnt be given as an example of the type
of differences that could be justified
And also why are such differences
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made Well one of the concerns would be that
one might make differences in the product that
have an implicit claim of superiority And in
fact some differences may lead to
superiority But there is of course already
a novel product pathway through BLA for
products that are intended to be different or
superior And so there should be clear it
should be made very clear that the
biosimilars pathway is not appropriate for
intentionally improved products and that
claims of superiority would not be permitted
under this pathway
With regard to interchangeability
much has already been said It is important
to note that even after you have a well-
qualified highly similar safe and effective
biosimilar there are additional risks that
could occur in patients who are switched from
the innovator to the biosimilar They could
get additive immunogenicity risk higher than
on either one alone They may not have -shy
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They might require dosing adjustments that are
not well studied and there are other issues as
well And so the legal standard which we
think is an appropriate one speaks to both
demonstrating that the products would have the
same effect in any given patient and that
switching would not expose patients to risks
or outcomes different from taking either
product or We believe that is an appropriate
standard and we agree with the guidance that
it would be difficult as a scientific matter
to establish interchangeability in an original
351(k) application given the statutory
standard We believe it would be difficult in
a follow-on application and we urge the FDA
as it considers this area and it promotes
guidance that it uphold the legal
interchangeable standard with appropriate
scientific rigor And other speakers have
spoken at length to ensure that naming and
packaging minimize -- maximize the ability to
trace events And I would add also to the
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extent possible minimize the likelihood that
switching will occur except where it has been
appropriately tested
The final area that I would like
to mention is the extrapolation of clinical
data from one indication to another In the
stepwise approach that I think is very well
described and we would support very well
described by the Agency the purpose of
clinical testing is to exclude the possibility
or address the remaining concerns or risks
that exist after all the prior testing non-
clinical preclinical laboratory testing has
occurred
And the fundamental concern
regarding extrapolation is the possibility
that there could be differences between the
biosimilar and reference products differences
that havent been excluded non-clinically that
may not manifest in the first indication
studied but might be clinically meaningful in
another indication
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And we would hold forth that the
basic scientific principles that should be
guiding this consideration and in fact a
basic generalizable scientific and regulatory
principle is that when you do clinical testing
to exclude differences it should be done in a
setting that is sensitive to such differences
This is something Bob Temple often likes to
refer to with regard to non-inferiority as
assay sensitivity
But it is an important principles
and it is principle that is indirectly alluded
to in the discussion of this issue when the
Agency wrote in the guidance consideration of
whether the tested condition of use is the
most sensitive one in detecting clinically
meaningful differences But that wording
suggests that there is a most sensitive one
whereas I think the appropriate and what
needs clarification is that it is really a
difference by difference issue
So what are the residual
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differences If they are in immunogenicity
is the group you studied sensitive to
immunogenicity If they are differences that
might lead to liver toxicity is the group you
studied on the right medications or have the
right risk factors If they are differences
that might influence biodistribution
penetration into the brain may be one
indication that is more important than the
other So those need to be looked
scientifically
Mechanism of action that the
previous speaker spoke to is important
Arguably when mechanisms of action are
different when you require new or different
mechanism of action then probably it is the
case that the different mechanism of action
study is not sensitive to differences that
might influence that new mechanism of action
So I would ask or we would ask
that the Agency consider that principle and
provide a broader clarification of the
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criticality of addressing sensitivity to
various risks in its guidance
And with that I will conclude my
remarks and once again thank you for your time
and attention and express our companys
interest in continuing to work in this process
toward a science-driven pathway for
biosimilars in the United States
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel
PANEL MEMBER KOZLOWSKI So on
your comment about avoidable differences so
when an originator changes their delivery
system or formulation they are also taking an
avoidable risk and what are the sizes of
studies they do to confirm that those risks
are mitigated
DR SIEGEL Well that is
something that of course you as a regulatory
body and other regulatory bodies determine
with an innovator And that is appropriate
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and that needs to be looked at and innovators
are innovating
I would suggest that though to
add that sort or risk on top of the risks or
uncertainties of a biosimilar the goal of a
biosimilar is not to improve a product It is
to make something as similar as possible So
there is not a reason to make a product
different
Now there may be reasons It may
be impractical There may be impediments to
making it the same Thats why I am not
trying to raise barriers that are
unachievable I am just suggesting it
shouldnt be conceived as part of the pathway
that oh well we can make a better product
We wont say it is better but people will know
it is better because it has a gentler
formulation it is purer or it is whatever
Those things can be misleading I can give
you other examples of ways that purer products
have run into problems
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PANEL MEMBER KOZLOWSKI And then
another question So when you talk about the
most sensitive indication you point you that
you can have very different things you are
looking at and sensitivity can vary
And so I would ask do you envision
that if one is very very comfortable with the
analytical similarity or a high-level the
fingerprint-like that is discussed in the
guidance that at some point the burden is not
to reduce any uncertainty in any possible
situation but to confirm in a more general
way
DR SIEGEL Well that is part of
the testing I agree You could never totally
exclude all uncertainty and there is some role
for some broad general but there are certain
areas I would argue even with fingerprinting
that immunogenicity is an area where there
will always be residual risk So many things
can influence immunogenicity
And you know there is discussion
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Im pretty sure there is discussion in the FDA
guidance for example that speaks about
cancer patients perhaps as immunosuppressed
being less sensitive for immunogenicity than
arthritis or rheumatology patients or
autoimmune patients But you know autoimmune
patients may be receiving methotrexate or 6shy
mercaptopurine or steroids or other drugs that
suppress immunogenicity And so they are
usually I think -- Yes there is general
confirmation but there usually are specific
and important questions that remain Does the
product get to get the right place at the
right -- you know will it -- Are there
toxicities Are there potential differences
It just has to be looked at product by
product
What are the possible differences
that cant be excluded by testing I would
argue there always are some with regard to
immunogenicity Usually there are others
And then how do you adequately test it
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clinically
So frankly general Im not sure
If you really could exclude all differences
I think you could make a strong case for not
doing clinical testing So when you say you
need clinical testing you are saying there
are differences that need to be assessed But
then the question is how do you adequately
assess them
PANEL MEMBER MALONEY Thanks for
your comments I had one question On one of
your slides you say you urge FDA to ensure
that naming and packaging maximize the ability
to trace events to specific products
So can you expand on what you are
referring to when you are talking about
packaging to maximize tracing
DR SIEGEL I dont have the
expertise in this area I say that the
concern comes from the fact that I know that
often when one gets safety reports they are
originated from the patient And the patient
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doesnt necessarily know or report and it
isnt always readily accessible you know
what is the chemical name what is the lot
number or whatever
So the concept there although I
dont have a great deal of expertise is just
to do this in a way that people know what they
are getting and that the reports maximize the
likelihood that it is traceable
PANEL MEMBER TOUFANIAN Just to
follow up on Dianes point You referenced in
your discussion of interchangeability a
specific concern with tracing problems And I
wasnt sure if you are using that in the same
context as you were below And if you could
explain that and if it is in fact tracking
with respect to pharmacovigilance tracking if
you could explain that a little bit more or if
it is in a different context
DR SIEGEL I dont recall
specifically -- oh yes So I have that in a
bullet there yes Well I think that when
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patients -- So we have had company experience
for example trying to track down cases of PRCA
in Thailand where sometimes it is very
difficult there are a number of biosimilars
to erythropoietins are available Sometimes
we dont have clear record about what
information which products the patient got
Sometimes we know they have gotten a number a
products I think although the Agency can
only go so far in limiting this the switching
will per se make tracing to which product
may have given rise to a problem difficult if
you discover that the patient has been on more
than one product And so except where it has
been well-validated or studied that sort of
switching should be discouraged or avoided
PRESIDING OFFICER SHERMAN Okay
we are out of time so I cant ask my question
But I hope in your comments to the docket you
will help us grapple what you mean by
reasonably avoidable because one can probably
spend some time on that Thank you for your
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comments
DR SIEGEL Youre welcome
PRESIDING OFFICER SHERMAN Our
next speaker is James Roach from Momenta
Pharmaceuticals
DR ROACH Good afternoon Im
Jim Roach the Senior Vice President of
Development and Chief Medical Officer at
Momenta Pharmaceuticals
Momenta is an innovative
biotechnology company that is focused on the
development of analytical tools and methods to
advance the science of thorough product
characterization and knowledge Our
technology has enabled the development of
generic versions of complex drugs such as
enoxaparin approved almost two years ago now
and glatiramer acetate currently under review
by FDA
We have extended our technology
and scientific approach to develop biosimilar
and potentially interchangeable products and
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are very interested in utilizing the 351(k)
pathway
We fully support the emphasis that
the draft guidance documents place on quality
by design and the recognition of the
fundamental importance of thoroughly
characterizing products structurally and
functionally in a stepwise manner
We believe that by following this
rigorous approach it is will be possible to
realize the potential efficiencies in
development that the abbreviated pathway may
allow
Momenta supports and agrees with
the foundation laid by the Agency in the
guidance documents with respect to retaining
scientific discretion to review each
application on a case by case basis without
mandating a priori requirements considering a
risk-based totality of the evidence approach
and lastly proceeding with development in a
stepwise fashion allowing for the science to
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dictate additional requirements if any
following review of structural and functional
characterization data
We request that the final guidance
documents continue to reflect these concepts
and approaches and retain flexibility to
assure that each company is able to find the
best means available to them to demonstrate
biosimilarity as well as the possibility of
interchangeability
And we do have some specific
comments With respect to the determination
of interchangeability in the original
application I will be flipping through the
questions quickly We really believe that the
experience with enoxaparin is very relevant to
consider here We certainly understand that
it will be difficult as a scientific matter
for an applicant to establish
interchangeability in an original 351(k)
application and the bar should be high
But again this experience is
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relevant And we noted with interest the
Agencys recent publication in the New England
Journal last August entitled Developing the
Nations Biosimilar Program authored by
several folks from FDA including some of our
panel members And in this article the
Agency commented on how the scientific
principles applied in reviewing generic
enoxaparin could be applied to the review of
biosimilar products And I wont read this
whole quote but to hit the highlights such a
totality of the evidence approach can also be
applied to assessing biosimilars And there
may be strategies that allow a fingerprint-
like identification to very similar patterns
in two different products Although
additional animal and clinical studies will
generally be needed the scope and extent of
such studies may be reduced further if more
extensive fingerprint-like characterization is
used
I bring this up and think this
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context is important because many in the
scientific regulatory and innovator
communities believed it would not only be
difficult rather it would be impossible to
replicate this complex drug and many now state
that it is impossible to replicate biologics
We do not underestimate the complexity of
this task but do believe that achieving this
goal is possible and ask simply that the
Agency remain open to the possibility of
granting interchangeable status based on the
data presented in the original application
We note that high-quality high-
resolution structural and functional data may
actually be a much more robust and sensitive
means to be able to detect differences between
products should they exist than data
obtained in clinical trials
With respect to the question on
whether the use of comparative animal or
clinical data with a non-US-licensed product
can be utilized to support a demonstration of
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biosimiliarity we certainly support allowance
of non-US-licensed product data to support
biosimilarity with appropriate bridging data
and believe that this is in fact critical if
the goal is to implement a global development
program that is feasible to conduct
We also believe that the same
scientific principles applied whether
comparing non-US reference product to US
reference product or comparing either of these
to a proposed biosimilar And I will make
further comments on the PKPD aspect of that
question shortly
With respect to the question on
the applicability of ICH Q5E it is a
demonstration of biosimilarity we agree that
some of the scientific principles in ICH Q5E
are certainly applicable to the demonstration
of biosimilarity Much more data utilizing a
lens which provides a much higher degree of
resolution than has been historically utilized
in the industry may be required to establish
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biosimilarity as well as interchangeability
and in particular if this same structural and
functional characterization set is serving as
the primary justification or reducing or even
potentially eliminating clinical trial
requirements
Moving on to the question
regarding human PK andor PD study
requirement I note that the answer to this
question states for example but we are unclear
based on the wording and the use of the word
must and at least in this answer as to
whether the Agencys intent was to actually
mandate a requirement for a clinical PK andor
PD study to support the demonstration of
biosimilarity and request that the Agency
provide further clarification
If the intent was in fact to
mandate this requirement we believe that this
is inconsistent with the clear discretion
afforded the agency in determining
requirements for approval based on review of
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the data and request that the Agency continue
to consider the totality of the evidence and
stepwise approach outlined in the guidances
From our perspective as a
scientific matter we actually believe it is
premature to mandate any particular
requirement or approach without first
evaluating the data presented The science of
comparative assessment of complex products
both structurally an functionally continues to
evolve
Others will be and have commented
on the clinical study section And it is
clear that the Agency has given significant
consideration to the design of the different
types and stages of clinical studies that may
be required to address residual uncertainties
that may remain following the completion of
preceding trials The progression of clinical
studies that is outlined in the guidance
document certainly is logical However as
the Agency begins to implement the 351(k)
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pathway we believe it will also be important
to continue to emphasize a concept articulated
elsewhere in this guidance namely that the
purpose of the biosimilar development program
is to support a demonstration of biosimilarity
between a proposed product and a referenced
product including an assessment of the
effects of any observed differences between
the products but very importantly it is not
to independently establish the safety and
effectiveness of the proposed product And we
believe it is important to not lose sight of
this as this is implemented
For the pathway to actually be
utilized and to ensure that the benefits to
patients in the healthcare system are fully
realized it is imperative that the Agency
truly takes a risk-based totality of the
evidence approach and considers the
feasibility of study design and conduct when
providing guidance
Clinical trials should be designed
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and conducted to provide supportive evidence
to the existing structural and functional data
set rather than to be conducted to
independently establish safety and efficacy
We only have one key point
regarding future guidance development We
believe that less is more in this regard The
state of the science with respect to the
enhancement of product understanding continues
to evolve and is progressing rapidly We
encourage the Agency to continue to set and
implement policy that is flexible enough to
allow the Agency to consider scientific
advancements on an ongoing and real-time
basis
In conclusion patient access to
biologics continues to be limited by high
costs and growing demand Many emphasize the
potential risks to patients if we rush too
quickly to bring biosimilars to the market
However equal emphasis should be placed on
the potential benefits to patients by
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implementing the pathway in a way that ensures
the introduction of safe and effective
biosimilars including interchangeable
biologics into the marketplace in a timely
manner
And I will close by quoting
another statement from the August 2011 New
England Journal article Evaluating
biosimilarity with a risk-based approach is
scientifically appropriate and familiar to
FDA whose decisions are commonly based on
reducing residual uncertainty to an acceptable
level in any given clinical setting
There is a very big difference
between defining and implementing policies
that will reduce uncertainty to an acceptable
level versus policies implemented with the
goal of reducing uncertainty to zero which is
an impossible task
Striking the right balance for
regulatory perspective will certainly not be
easy and nor will it be easy to develop
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biosimilar and potentially interchangeable
products that merit a significant reduction
for elimination in clinical trial requirements
but I believe the biotechnology industry has
historically thrived on challenges such as
this and I think we both share the
responsibility to ensure that the 351(k)
pathway is successfully implemented
Thank you very much for your time
and attention
PRESIDING OFFICER SHERMAN Thank
you for your comments Questions from the
panel
PANEL MEMBER KOZLOWSKI So in
your question about the interpretation of
whether a PK study is required So you know
you are stating a view that with the right
characterization you think even a
pharmacokinetic clinical study would not be
necessary
DR ROACH You know I am
sitting I guess from a conceptual level that
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I am not sure that should be mandated It
certainly wouldnt be the end of the world if
at the end of the completion of a very
rigorous structural and functional
characterization data set there was a
suggestion or a requirement to conduct a PK
study but it struck me conceptually that if
the intent was to proceed in a stepwise
fashion and we have truly demonstrated through
our very rigorous analytical and structural
characterization -- sorry structural and
functional characterization package that the
two drugs are truly indistinguishable from
each other at a level of satisfaction that
first we have to convince ourselves of and
then you then arguably there should be no
further requirement
PANEL MEMBER KOZLOWSKI And one
other question You mentioned that obviously
one cant reduce the residual uncertainty to
zero So earlier we had comments in the
morning session about our definition of
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clinically meaningful differences and it was
challenged from the other side that it is too
close to zero or too far from zero
And I guess what I am asking is do
you have a specific comment on that
definition based on this view
DR ROACH You know I wish I did
because that is really to me where the rubber
hits the road if you will in trying to
define using scientific judgment where one
draws that line But what I will say is that
it is clear that through your decades of
experience in reviewing biologics and
reviewing even comparability packages that
companies are putting forth to you when they
make their own manufacturing changes you are
making these kinds of assessments every day
And I think the same kind of judgment that you
are apply in those situations also apply as
you are reviewing a biosimilar program
PRESIDING OFFICER SHERMAN Other
questions
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I have just a follow-up one on
Steves You pointed out correctly there are
a couple of places that we speculated that it
would be likely that we would want to see
human data PK and obviously
interchangeability Can you envision a
biosimilar development program where there
would be licensure with a product never having
been introduced into a human
DR ROACH Can I envision that
We envision a lot of things at Momenta So I
would say yes I think we can envision that
We appreciate that there may well be some
question about residual uncertainty still at
the end where you may want to see some human
PK data
PRESIDING OFFICER SHERMAN Thank
you for your comments
All right our next speaker is
Patrick Vink from Mylan
MR VINK Good afternoon My
name is Patrick Vink I am the Senior Vice
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President of the Global Institutional and
Biologic Business at Mylan
I first want to thank the FDA for
organizing this meeting today I think it is
a great venue for everybody to listen to what
all stakeholders have to say I also want to
thank the panel for their continued attendance
and interest in all of the presentations
during this whole day
Mylan is the worlds first largest
generic company and we are the largest
generics company with headquarters in the US
Today already one out of 11 prescriptions
dispensed in the US either brand or generic
comes from us and we have a commitment from
over 15 years to help patients get access to
high-quality affordable generics And we take
that commitment that we have for 15 years now
also to the market of biogenerics
As I say as part of that
commitment we are going to take a leading
role in development of this new class of drugs
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for the US marketplace We are actively
pursuing a number of development programs and
we look forward to the ongoing interactions
with the Agency on those product-specific
discussions
We want to express our full
support to the effort of FDA to put in place
this guidance or potentially as mandated by
the implementation of the BPCIA We applaud
this first step that has been made and a
number of elements that are in that we very
much support And as was already mentioned
during today the stepwise approach the
recognition of the totality of evidence and
especially the key role the Agency sees in the
fact that state of the art analytical tools
that are currently available and as are
currently still evolving play a key role in
establishing that high similarity level that
we need to have products approved
We also see moving forward that a
dedicated office of biogenerics would help the
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