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Biosimilars Series: Regulatory and development issues hurdles exist but are surmountable

Published by: Datamonitor

Published: Sep. 13, 2007 - 135 Pages


Table of Contents


CHAPTER 1 EXECUTIVE SUMMARY
Scope of the report
Key findings
Key definitions
CHAPTER 2 INTRODUCTION TO THE BIOSIMILARS MARKET
Drivers and resistors of the biosimilars market growth
Drivers of growth in the biosimilars market
Biologics are the fastest growing segment of the pharmaceuticals market
Patent expiry on first-generation biologics
Increasing pressures of cost-containment
Advances in analytical techniques
Resistors of growth in the biosimilars market
Opposition from the innovator companies
Lack of biosimilars regulatory approval pathway in the US is stalling the entry of biosimilars into the US market
Cost and complexity of development
Lack of time on market hinders physician uptake
CHAPTER 3 BIOSIMILARS REGULATORY ISSUES
Europe is leading the way in biosimilars legislation and approval
Guideline on quality issues for biosimilars is based on analysis of comparability after process change
Guidelines on pre-clinical and clinical issues are vague
Results of clinical trials could be extrapolated to other indications in some cases
Product-class specific annexes provide more details
Route of administration used in clinical trials is critical
Five biosimilars have been approved in the EU
Omnitrope's approval forced a change of law to allow approval of biosimilars
BioPartners's Valtropin received approval but Alpheon failed on quality issues
Three biosimilar Epoetins have been approved in Europe
Further guidance is expected
Other regulatory issues in Europe remain
The Bolar provision - a safe harbor for development of biosimilars
Use of trade secret data
Innovators insist that biosimilars should have unique INNs
Others will follow where EU leads
Opposing interests hinder progress in the US
The FDA has delayed issuing guidance for approval of biosimilars
The FDA has already approved follow-on protein products
Avonex marks approval of a first biosimilar
Follow-on hyaluronidase approval
Glucagon and Fortical (salmon calcitonin nasal spray) follow-on protein products
Sandoz's Omnitrope
The FDA's decision to use the abbreviated approval pathway for Omnitrope was met with criticism
Recent activity in the US Senate and Congress suggests legislation on biosimilars approval might be issued in the near future
The Access to Life-Saving Medicine Act is pro-biosimilar and was not accepted by the pro-innovator faction
The Patent Protection and Innovative Biologic Medicines Act of 2007 is pro-innovator
The Biologics Price Competition and Innovation Act of 2007 proposes a middle-of-the road solution
Impact of future legislation on the FDA's biosimilars approval pathway
What happens before legislation is passed?
Abbreviated or full submission routes?
Strategies for innovators to minimize the effect of biosimilar competition
Naming of biosimilars remains an issue in the US
Automatic substitution with biosimilars or not - an unresolved issue
Automatic substitution in the US is unlikely
Substitution policies are defined by individual member states in the EU
Will reimbursement incentives drive biosimilar substitution?
CHAPTER 4 BIOSIMILARS DEVELOPMENT ISSUES
Biosimilars producers have to develop their own manufacturing process
Development of a manufacturing process for biosimilars involves many steps
Process knowledge is key
Choice of cell line is important
Patent protection of biologics is complex
Demonstration of comparability and similarity employs the same techniques
Product knowledge is critical for designing analytical testing strategy
Advice from regulators is invaluable
Lack of experience and data makes defining acceptance margins difficult
Analytical testing of biosimilars
Limitations of analytical testing
Primary sequence analysis
Misfolding can have a serious impact on clinical performance
Different processes result in different heterogeneity profiles - critical factor to explore
Post-translational modifications are a major cause of heterogeneity
Differences in glycosylation patterns need to be investigated
Presence of aggregates can have negative effects on a protein's clinical profile
Differences in hydrophobicity and charge need to be investigated
Stability testing of biosimilars
Comparability after process change
Choice of reference product is important
Some originator products exhibit great inter-batch variability
Pre-clinical testing of biosimilars
Biological activity assays are used in pre-clinical testing of biosimilars
Animal studies have limited value
Pre-clinical safety studies
Immunogenicity testing is critical for approval
Factors influencing the potential of a protein product to elicit an immune response
Immunogenicity considerations are especially important for therapeutic antibodies.
Pre-clinical immunogenicity testing
In vitro methods used in clinical immunogenicity testing
Aggregates have the capacity to trigger immune response
Differences in glycosylation can lead to enhanced immunogenicity
PRCA associated with Eprex led to increased focus on immunogenicity
Final formulation and packaging
Formulation can impact the clinical profile
Differences in packaging can have an effect on safety
Second-generation biosimilars have different formulation and packaging
Clinical trials are necessary for approval of biosimilars
Clinical trials are the longest and most expensive part of the comparability demonstration
Comparative PK studies of biosimilars
Comparative PD studies of biosimilars
Comparative efficacy studies of biosimilars
Clinical safety studies of biosimilars
Clinical immunogenicity testing of biosimilars
Risk management plans are important
Pharmacovigilance plans are necessary for approval of biosimilars
Scientific advice from regulatory bodies
Comparable or interchangeable?
Can a biosimilar be better than the originator's product?
The EMEA has been flexible in its approval of biosimilars to date
Omnitrope was approved by the EMEA despite changes in the purification procedure of the final product
Approval of Valtropin demonstrates the importance of using the correct reference product
BioPartners's Alpheon was rejected on grounds of quality issues
Three biosimilars of Eprex were approved by the EMEA
Finding information about previous approvals is not straightforward
Development strategies for biosimilar manufacturers
A detailed development plan can help avoid pitfalls
Third party advice
Strategic collaborations are used to gain access to complementary competencies
Acquisitions are used to acquire biosimilar pipelines or production facilities
CHAPTER 5 FUTURE DEVELOPMENTS
The EMEA will issue further guidelines
Which biosimilars will be approved next?
The future of biosimilars in the US depends on whether a consensus can be reached in Congress
If the Senate bill is accepted the US will be a more lucrative market
What about other markets?
Biosimilars of monoclonal antibodies
Monoclonal antibodies will not be open to biosimilar competition for several years
Manufacturing and comparability of biosimilar mAbs
New technologies allowing controlled glycosylation are emerging
Regulatory approval of mAbs
The big players are most likely to enter this market
BIBLIOGRAPHY
Publications and online articles
Websites
Conference literature
Datamonitor resources
Suggested reading
GLOSSARY
List of Tables
Table 1: Patent expiries of selected key biologics
Table 2: Safety and efficacy study duration and extrapolation to other indications for different classes of biosimilars
Table 3: Statutory pathways for the approval of small molecule drug generics in the US
Table 4: Three bills regarding biosimilars were introduced in 2007
List of Figures
Figure 1: Drivers and resistors of the biosimilars market growth
Figure 2: The EMEA has published several guideline documents on biosimilars
Figure 3: The Access to Life-Saving Medicines Act is pro-biosimilar
Figure 4: The Patent Protection and Innovative Biologic Medicines Act is pro-innovator
Figure 5: The Biologic Price Competition and Innovation Act balances the interests of the public, biosimilar manufacturers and innovators
Figure 6: Manufacturing of biosimilars involves many steps
Figure 7: Relevance of different tests and studies used to characterize biosimilar products
Figure 8: EMEA's recommendations for the detection and characterization of antibodies in patients' sera

Abstract

Introduction

Europe serves as a model for other countries looking to define their own regulatory approval criteria. The US is on the brink of passing legislation to establish a statutory pathway for biosimilars approval but the opposing interests of biosimilar and innovative companies may result in further delays. Development of biosimilars presents many challenges and potential pitfalls.

Scope

Overview of the key drivers and resistors of the biosimilars market growth Analysis of the regulatory requirements for approval of biosimilars in Europe Overview of the progress the US has made in establishing its approval pathway In-depth analysis of the challenges of biosimilars development, including potential technical pitfalls and considerations

Highlights

Europe has shown a degree of flexibility in its approval of 5 biosimilars to date. Although guidance has been issued biosimilar developers are urged to communicate with the EMEA as approval remains on a case-by case basis. Naming of biosimilars remains a contentious and unresolved issue as it carries implications for substitution with biosimilars. The increasing expenditure on biologics is pressuring US lawmakers to formulate a statutory pathway for approval of biosimilars. The Biologics Price Competition and Innovation bill proposes a compromise attempting to satisfy both innovative and biosimilar companies. However its future is uncertain as it faces a slow progress in Congress. Design of the biosimilar manufacturing process is key process knowledge and understanding of potential risks and pitfalls are necessary to minimize the time and cost of development. Selection of analytical methods for assessing biosimilars quality is critical as each method answers a different question about the product.

Reasons to Purchase

Identify the key trends that are driving and resisting the growth of the biosimilars market Understand the regulatory requirements in Europe and how recent attempts to establish a regulatory pathway in the US might affect that market Gain insight into challenges and potential pitfalls in the development of biosimilars including biosimilars of monoclonal antibodies.

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