Overview of Guidance Documents and
Decision process: Biopharmaceutics Section
Mehul Mehta, Ph.D.
Director
Division of Pharmceutical Evaluation I
OCPB, CDER, FDA
ACKNOWLEDGEMENTS
• Dr. Uppoor
• Dr. Marroum
Outline
• Overview of biopharmaceutical
aspects of dissolution related
guidances
• Examples of dissolution
specification setting of IR and MR
products
• Opportunities
Guidances covered
• BCS Guidance (Waiver of In Vivo Bioavailability and
Bioequivalence Studies for Immediate-Release Solid Oral
Dosage Forms Based on a Biopharmaceutics
Classification System”); August 2000
• IR Dissolution Guidance (Dissolution Testing of
Immediate Release Solid Oral Dosage Forms); August
1997
• IVIVC Guidance (Extended Release Oral Dosage
Forms: Development, Evaluation, and Application of In
Vitro/In Vivo Correlations); September 1997
• General BA/BE Guidance (Bioavailability and
Bioequivalence Studies for Orally Administered Drug
Products - General Considerations); 2003
Guidances covered
• SUPAC-IR Guidance (SUPAC-IR: Immediate
Release Solid Oral Dosage Forms Scale-Up and
Post Approval Changes: Chemistry, Manufacturing,
and Controls, In Vitro Dissolution and In Vivo
Bioequivalence Documentation); 1995
• SUPAC-MR Guidance (SUPAC-MR: Modified
Release Solid Oral Dosage Forms Scale-Up and
Post-approval Changes: Chemistry, Manufacturing,
and Controls; In Vitro Dissolution Testing and In
Vivo Bioequivalence Documentation); 1997
BCS Guidance Summary
 BCS takes into account three major factors that govern
the rate and extent of drug absorption from IR solid oral
dosage forms: solubility, intestinal permeability, and
dissolution.
 4 BCS classes are: 1 = HS, HP; 2 = LS, HP; 3 = HS, LP;
4 = LS, LP
 Different formulations of rapidly dissolving BCS class 1
product can be given biowaiver if they show rapid and
similar dissolution profiles over the physiological pH
range.
 BCS defines rapid dissolution, i.e., 85% in 30 minutes. If
dissolution is this rapid across the pH range, absorption
not dissolution rate limited.
IR Dissolution Guidance Summary
Topics Covered:
• Approaches to setting dissolution specifications
for an NCE
• Approaches for setting dissolution specifications
for generic products
• Mapping or Response Surface methodology
• Model independent approach to compare
dissolution profiles using a similarity factor, f2
• The dissolution specifications
are established in consultation
with biopharmaceutics and CMC
review staff.
General BA/BE Guidance Summary
Dissolution Method Development Report:
• For an NDA:
– The pH solubility profile of the drug substance
– Dissolution profiles generated at different agitation
speeds. Dissolution profiles generated on all
strengths in at least three dissolution media.
– Select the agitation speed and medium that provide
adequate discriminating ability, taking into account all
the available in vitro and in vivo data.
• For ANDAs:
– Appropriate USP method, or; the FDA
method if publicly available, or; the
dissolution method development report
described above.
– For MR products, dissolution profiles using
the appropriate USP method (if available),
or; the FDA method for RLD if available. In
addition, profiles using at least three other
dissolution media and water recommended.
IVIVC Guidance Summary
 A point-to-point relationship between in vitro
dissolution and the in vivo input rate of the drug
from the dosage form.
 Usually estimated by a two stage procedure
(e.g., deconvolution followed by comparison of
the fraction absorbed to the fraction dissolved).
 Generally linear, but non-linear are also
acceptable.
IVIVC Levels: Level “A”
Correlation
0
20
40
60
80
100
0 20 40 60 80 100
% Drug Dissolved
% Drug
Absorbed
IVIVC Levels: Level “A”
Correlation
Dissolution Specifications
• Ideally, all lots within the lower and
upper limit of the specifications are
bioequivalent
• Minimally, these lots should be
bioequivalent to the clinical trials
lots or an appropriate reference
standard chosen by the Agency
Dissolution Specifications
• Variability alone should no longer be a
primary consideration
• Specifications wider than 20 % are
acceptable only when evidence is
submitted that lots with mean dissolution
profiles that are allowed by the upper
and lower limits are bioequivalent
Dissolution Specifications With No
IVIVC
• Minimum of 3 points required
• Last time point should be the time where
80% of claimed labeled amount is
dissolved
• Specifications set to pass at stage 2
level of testing of the USP acceptance
criteria
Dissolution Specifications with
IVIVC
• External validation is not required to use
the IVIVC for setting specifications
• Wider specifications based on what the
correlation predicts
FINAL DISSOLUTION SPECIFICATIONS:
Set such that the predicted Cmax and AUC range NMT 20%
0 5 10 15 20 25 30
0
20
40
60
80
100
120
Time in hours
C
um
ulative
%
dissolved
DISSOLUTION PROFILES
0 5 10 15 20 25 30
0
20
40
60
80
100
120
Time in hours
Plasma
conc.,
ng/ml
Predicted plasma concentrations
IVIVC Applications: Dissolution
Specifications
SUPAC-IR (1995) and MR
Guidances (1997) Summary
(Equipment Addendum (1999); FDAMA
(1997) and “Changes Approved to an NDA or
ANDA” Guidance (2000))
General Aspects: (Change)
Variables Covered
 Components and Composition
Non Release Controlling
Release Controlling
 Site
 Batch Size (Scale-Up/Scale-Down)
 Manufacturing
Equipment
Process
General Aspects: Supporting Data
• Level I (Minor) change
• Level II (Moderate) change
• Level III (Major) change
• Chemistry (A/C test, Stability)
• In Vitro dissolution/release
• In Vivo bioequivalence test / IVIVC
• Annual report
• Change being effected supplement
• Prior approval supplement
Level of
Change
Tests
Filing
SUPAC-IR Excipient Levels
Level Excipients % Change (w/wtotal) Allowed
I - Glidant: Talc; Other +/- 1.0%; +/- 0.1%
- Disintegrant: Starch; Other +/- 3.0%; 1.0%
- Binder +/- 0.5%
- Lubricant: Ca/Mg Strt; Other +/- 0.25%; +/-1.0%
- Filler +/- 5.0%
- Film Coat +/- 1.0%
II - Glidant: Talc; Other +/- 2.0%; +/- 0.2%
- Disintegrant: Starch; Other +/- 6.0%; 2.0%
- Binder +/- 1.0%
- Lubricant: Ca/Mg Strt; Other +/- 0.5%; +/-2.0%
- Filler +/- 10.0%
- Film Coat +/- 2.0%
III - Higher than SUPAC-IR Level 2
Excipient ranges
SUPAC-MR Excipient Levels
• For the release controlling excipients, the SUPAC-
MR guidance defines change in quantity as
percentage (weight / weight) of total release-
controlling excipients. For these:
– A level 1 change means that the total additive
effect of all RCE should not be more than +5%.
– A level 2 change allows a range of +10%
– Changes beyond +10% are considered level 3.
SUPAC- IR and MR SUMMARY
• The guidance defines tests, filing recommendations and
levels of changes in: C and C (RC and NRC); Site; batch
size; equipment and process.
• The following changes need a bio study (or IVIVC): level
3 RC and NRC, level 2 RC for NTR drugs, level 3 site
change, and level 3 process change.
• “Equipment Addendum” identifies equipment by class and
subclass for all major unit operations; change to a
different class generally considered a change in design
and principle.
• “Changes” guidance allows for multiple different level
changes, the most restrictive individual change should be
followed.
Examples
• Data available for a typical IR product in an
NDA:
– Dissolution results under a variety of agitation and
media conditions.
– A method that provides rapid dissolution profile; Mean
and range of dissolution values of 12 units from the
bio lot(s) plus a few to several production lots under
this condition.
– BA results of one or more lots (relative BA trials, BE
trials).
– Lots used in efficacy trials.
– Stability data.
• Factors taken into consideration when
setting specs for IR products:
– In vivo behavior, particularly how rapidly the
drug is absorbed (Tlag, Tmax)
– Dissolution behavior across all the conditions
in vitro
– Adequately discriminating in vitro method
from all the in vitro conditions attempted,
based on qualitative or quantitative in vitro –
in vivo inference
• Factors taken into consideration when setting
specs for IR products:
– Comparison with more rapidly dissolving
formulation, e.g., solution very helpful in
assessing in vivo dissolution; this can guide how
discriminating the in vitro method needs to be;
– look at all available dissolution data; pay
particular attention to the lots that have in vivo
data, e.g., the bio lots and efficacy trial lots;
– discuss with Chemists data from the stability lots;
• Possible Outcomes:
– Sufficient data submitted; specs finalized
– Insufficient data submitted; interim specs set
for a limited time frame; additional data
submitted; specs finalized.
– Insufficient data submitted; specs can’t be
finalized, including interim specs; additional
data required; approval decision finalized.
Dissolution Specifications for IR Drug
A
• Solubility: Highly soluble over the pH range of 1.2 to
6.9
• Permeability: Highly permeable based on in-vitro
and absolute bioavailability studies
• Dissolution: rapidly dissolving over pH range of 1.2
to 6.8
• Dissolution results of the BA lot and the clinical lot
utilized
• 12 month controlled room temperature stability data
and accelerated storage conditions results also
taken into consideration.
• Method: USP I at 100 rpm in 900 ml 0.1 N
HCl
• Spec: Q=80% in 30 minutes
(Apparatus I was chosen by the sponsor to
avoid mounding or coning of the product
at the bottom of the dissolution vessel)
Dissolution Specifications for IR Drug
B
• The drug is a free base with pKas of 5.4
and 7.2
• Highly soluble at pH 1.0 but practically
insoluble at pH 7, with the solubility
dropping sharply between pH 4 and 5
• Tmax range is 3-5 hours
• Half life is around 45 hours
• Fraction absorbed around 0.75
• Initial dissolution method showed
clinical and TBM formulations to
have similar profiles
• But the BE study showed a clear
failure on Cmax, with the TBM
formulation showing about a 17%
lower Cmax.
• The method optimized further to
have adequate discrimination.
• Proposed method and specs:
– USP Apparatus 2, 50 rpm; 1000 ml
Tween 80 (5% v/v) in water; Q=75% in
45 minutes
• Recommendation:
– USP Apparatus 2, 50 rpm; 1000 ml
Tween 80 (5% v/v) in water; Q=80% in
45 minutes
Dissolution Specifications for an MR
Product with IVIVC
IVIVC
• Level A correlation established.
• Correlation was obtained from in
vivo data obtained from 6 different
studies
• Media Consisted of PH 1.5 for the
first 1.5 hours then PH 6.8 buffer for
the remainder of the 24 hours
Dissolution Limits
Opportunities
“The Concept of Pharmaceutical
Quality”, Dr. Janet Woodcock,
Pharmaceutical Review, 7, 10, 2004:
• "For the purposes of clinical use, the
established drug quality attributes are
generally adequate because they
achieve much tighter control of the level
of variability than could be detected in
patients without extensive study.”
“The Concept of Pharmaceutical Quality”, Dr.
Janet Woodcock, Pharmaceutical Review,
7, 10, 2004:
• “In contrast, for regulatory and manufacturing
processes, the lack of detailed understanding of
the real-world importance of quality attributes is
a serious problem, leading to many disputes
that might be resolved easily were relevant
information available on the relationships
between various quality parameters and clinical
performance."
Sources of Variability in Therapy
• Manufacturing
• Drug exposure (PK)
• Drug response (PD)
• Compliance
• Snapshot: 17 drugs selected
randomly from an Internal BCS
database of 194 NDAs and
variability (%CV) in their exposure
parameters – AUC and Cmax –
assessed.
I*
(n=3)
II*
(n=2)
III*
(n=7)
IV*
(n=4)
AUC
%CV
17-
24%
19-
25%
16-
100%
16-
48%
Cmax
%CV
18-
23%
24-
35%
25-
49%
30-
40%
• Assuming that the clinical trial
formulation is optimized, even for
BCS class I products (no high first-
pass metabolism), there is in vivo
exposure variability of about 20%.
Utilize this to come up with rational
specs!
• Opportunities for improvement:
– Select appropriate dissolution method based on
physicochemical, in vitro and in vivo
characteristics of drug and drug product
– Estimate in-vitro variability for LS and LP IR forms
– Estimate of dissolution variability of lot(s) used in
pivotal efficacy trial(s) would facilitate rational
specs
– For MR products, estimate in vitro release
variability and utilize it to improve upon current
IVIVC method which involves mean estimates
only.
• Opportunities for improvement:
– New technology (e.g., PAT) can provide in
vitro in vivo relationships based on
performance of individual dosage form units!
– Elution / release from Complex dosage
formulations, e.g., Drug Eluting Stents,
Liposomes, should be studied using
mechanistic models and new techniques in
imaging and fluid dynamics.
– Future specs would be based on in vitro
mean and variability estimates.
• Opportunities for improvement
– Early communication
• e.g., EOP2 meeting between sponsor
and FDA Biopharmaceutics and CMC
staff to discuss the development plan.
• Good homework will always
bring dividends!

2005-4137S1_03_Mehta bioavaialability.ppt

  • 1.
    Overview of GuidanceDocuments and Decision process: Biopharmaceutics Section Mehul Mehta, Ph.D. Director Division of Pharmceutical Evaluation I OCPB, CDER, FDA
  • 2.
  • 3.
    Outline • Overview ofbiopharmaceutical aspects of dissolution related guidances • Examples of dissolution specification setting of IR and MR products • Opportunities
  • 4.
    Guidances covered • BCSGuidance (Waiver of In Vivo Bioavailability and Bioequivalence Studies for Immediate-Release Solid Oral Dosage Forms Based on a Biopharmaceutics Classification System”); August 2000 • IR Dissolution Guidance (Dissolution Testing of Immediate Release Solid Oral Dosage Forms); August 1997 • IVIVC Guidance (Extended Release Oral Dosage Forms: Development, Evaluation, and Application of In Vitro/In Vivo Correlations); September 1997 • General BA/BE Guidance (Bioavailability and Bioequivalence Studies for Orally Administered Drug Products - General Considerations); 2003
  • 5.
    Guidances covered • SUPAC-IRGuidance (SUPAC-IR: Immediate Release Solid Oral Dosage Forms Scale-Up and Post Approval Changes: Chemistry, Manufacturing, and Controls, In Vitro Dissolution and In Vivo Bioequivalence Documentation); 1995 • SUPAC-MR Guidance (SUPAC-MR: Modified Release Solid Oral Dosage Forms Scale-Up and Post-approval Changes: Chemistry, Manufacturing, and Controls; In Vitro Dissolution Testing and In Vivo Bioequivalence Documentation); 1997
  • 6.
  • 7.
     BCS takesinto account three major factors that govern the rate and extent of drug absorption from IR solid oral dosage forms: solubility, intestinal permeability, and dissolution.  4 BCS classes are: 1 = HS, HP; 2 = LS, HP; 3 = HS, LP; 4 = LS, LP  Different formulations of rapidly dissolving BCS class 1 product can be given biowaiver if they show rapid and similar dissolution profiles over the physiological pH range.  BCS defines rapid dissolution, i.e., 85% in 30 minutes. If dissolution is this rapid across the pH range, absorption not dissolution rate limited.
  • 8.
  • 9.
    Topics Covered: • Approachesto setting dissolution specifications for an NCE • Approaches for setting dissolution specifications for generic products • Mapping or Response Surface methodology • Model independent approach to compare dissolution profiles using a similarity factor, f2
  • 10.
    • The dissolutionspecifications are established in consultation with biopharmaceutics and CMC review staff.
  • 11.
  • 12.
    Dissolution Method DevelopmentReport: • For an NDA: – The pH solubility profile of the drug substance – Dissolution profiles generated at different agitation speeds. Dissolution profiles generated on all strengths in at least three dissolution media. – Select the agitation speed and medium that provide adequate discriminating ability, taking into account all the available in vitro and in vivo data.
  • 13.
    • For ANDAs: –Appropriate USP method, or; the FDA method if publicly available, or; the dissolution method development report described above. – For MR products, dissolution profiles using the appropriate USP method (if available), or; the FDA method for RLD if available. In addition, profiles using at least three other dissolution media and water recommended.
  • 14.
  • 15.
     A point-to-pointrelationship between in vitro dissolution and the in vivo input rate of the drug from the dosage form.  Usually estimated by a two stage procedure (e.g., deconvolution followed by comparison of the fraction absorbed to the fraction dissolved).  Generally linear, but non-linear are also acceptable. IVIVC Levels: Level “A” Correlation
  • 16.
    0 20 40 60 80 100 0 20 4060 80 100 % Drug Dissolved % Drug Absorbed IVIVC Levels: Level “A” Correlation
  • 17.
    Dissolution Specifications • Ideally,all lots within the lower and upper limit of the specifications are bioequivalent • Minimally, these lots should be bioequivalent to the clinical trials lots or an appropriate reference standard chosen by the Agency
  • 18.
    Dissolution Specifications • Variabilityalone should no longer be a primary consideration • Specifications wider than 20 % are acceptable only when evidence is submitted that lots with mean dissolution profiles that are allowed by the upper and lower limits are bioequivalent
  • 19.
    Dissolution Specifications WithNo IVIVC • Minimum of 3 points required • Last time point should be the time where 80% of claimed labeled amount is dissolved • Specifications set to pass at stage 2 level of testing of the USP acceptance criteria
  • 20.
    Dissolution Specifications with IVIVC •External validation is not required to use the IVIVC for setting specifications • Wider specifications based on what the correlation predicts
  • 21.
    FINAL DISSOLUTION SPECIFICATIONS: Setsuch that the predicted Cmax and AUC range NMT 20% 0 5 10 15 20 25 30 0 20 40 60 80 100 120 Time in hours C um ulative % dissolved DISSOLUTION PROFILES 0 5 10 15 20 25 30 0 20 40 60 80 100 120 Time in hours Plasma conc., ng/ml Predicted plasma concentrations IVIVC Applications: Dissolution Specifications
  • 22.
    SUPAC-IR (1995) andMR Guidances (1997) Summary (Equipment Addendum (1999); FDAMA (1997) and “Changes Approved to an NDA or ANDA” Guidance (2000))
  • 23.
    General Aspects: (Change) VariablesCovered  Components and Composition Non Release Controlling Release Controlling  Site  Batch Size (Scale-Up/Scale-Down)  Manufacturing Equipment Process
  • 24.
    General Aspects: SupportingData • Level I (Minor) change • Level II (Moderate) change • Level III (Major) change • Chemistry (A/C test, Stability) • In Vitro dissolution/release • In Vivo bioequivalence test / IVIVC • Annual report • Change being effected supplement • Prior approval supplement Level of Change Tests Filing
  • 25.
    SUPAC-IR Excipient Levels LevelExcipients % Change (w/wtotal) Allowed I - Glidant: Talc; Other +/- 1.0%; +/- 0.1% - Disintegrant: Starch; Other +/- 3.0%; 1.0% - Binder +/- 0.5% - Lubricant: Ca/Mg Strt; Other +/- 0.25%; +/-1.0% - Filler +/- 5.0% - Film Coat +/- 1.0% II - Glidant: Talc; Other +/- 2.0%; +/- 0.2% - Disintegrant: Starch; Other +/- 6.0%; 2.0% - Binder +/- 1.0% - Lubricant: Ca/Mg Strt; Other +/- 0.5%; +/-2.0% - Filler +/- 10.0% - Film Coat +/- 2.0% III - Higher than SUPAC-IR Level 2 Excipient ranges
  • 26.
    SUPAC-MR Excipient Levels •For the release controlling excipients, the SUPAC- MR guidance defines change in quantity as percentage (weight / weight) of total release- controlling excipients. For these: – A level 1 change means that the total additive effect of all RCE should not be more than +5%. – A level 2 change allows a range of +10% – Changes beyond +10% are considered level 3.
  • 27.
    SUPAC- IR andMR SUMMARY • The guidance defines tests, filing recommendations and levels of changes in: C and C (RC and NRC); Site; batch size; equipment and process. • The following changes need a bio study (or IVIVC): level 3 RC and NRC, level 2 RC for NTR drugs, level 3 site change, and level 3 process change. • “Equipment Addendum” identifies equipment by class and subclass for all major unit operations; change to a different class generally considered a change in design and principle. • “Changes” guidance allows for multiple different level changes, the most restrictive individual change should be followed.
  • 28.
  • 29.
    • Data availablefor a typical IR product in an NDA: – Dissolution results under a variety of agitation and media conditions. – A method that provides rapid dissolution profile; Mean and range of dissolution values of 12 units from the bio lot(s) plus a few to several production lots under this condition. – BA results of one or more lots (relative BA trials, BE trials). – Lots used in efficacy trials. – Stability data.
  • 30.
    • Factors takeninto consideration when setting specs for IR products: – In vivo behavior, particularly how rapidly the drug is absorbed (Tlag, Tmax) – Dissolution behavior across all the conditions in vitro – Adequately discriminating in vitro method from all the in vitro conditions attempted, based on qualitative or quantitative in vitro – in vivo inference
  • 31.
    • Factors takeninto consideration when setting specs for IR products: – Comparison with more rapidly dissolving formulation, e.g., solution very helpful in assessing in vivo dissolution; this can guide how discriminating the in vitro method needs to be; – look at all available dissolution data; pay particular attention to the lots that have in vivo data, e.g., the bio lots and efficacy trial lots; – discuss with Chemists data from the stability lots;
  • 32.
    • Possible Outcomes: –Sufficient data submitted; specs finalized – Insufficient data submitted; interim specs set for a limited time frame; additional data submitted; specs finalized. – Insufficient data submitted; specs can’t be finalized, including interim specs; additional data required; approval decision finalized.
  • 33.
  • 34.
    • Solubility: Highlysoluble over the pH range of 1.2 to 6.9 • Permeability: Highly permeable based on in-vitro and absolute bioavailability studies • Dissolution: rapidly dissolving over pH range of 1.2 to 6.8 • Dissolution results of the BA lot and the clinical lot utilized • 12 month controlled room temperature stability data and accelerated storage conditions results also taken into consideration.
  • 35.
    • Method: USPI at 100 rpm in 900 ml 0.1 N HCl • Spec: Q=80% in 30 minutes (Apparatus I was chosen by the sponsor to avoid mounding or coning of the product at the bottom of the dissolution vessel)
  • 36.
  • 37.
    • The drugis a free base with pKas of 5.4 and 7.2 • Highly soluble at pH 1.0 but practically insoluble at pH 7, with the solubility dropping sharply between pH 4 and 5 • Tmax range is 3-5 hours • Half life is around 45 hours • Fraction absorbed around 0.75
  • 39.
    • Initial dissolutionmethod showed clinical and TBM formulations to have similar profiles
  • 41.
    • But theBE study showed a clear failure on Cmax, with the TBM formulation showing about a 17% lower Cmax. • The method optimized further to have adequate discrimination.
  • 45.
    • Proposed methodand specs: – USP Apparatus 2, 50 rpm; 1000 ml Tween 80 (5% v/v) in water; Q=75% in 45 minutes • Recommendation: – USP Apparatus 2, 50 rpm; 1000 ml Tween 80 (5% v/v) in water; Q=80% in 45 minutes
  • 46.
    Dissolution Specifications foran MR Product with IVIVC
  • 47.
    IVIVC • Level Acorrelation established. • Correlation was obtained from in vivo data obtained from 6 different studies • Media Consisted of PH 1.5 for the first 1.5 hours then PH 6.8 buffer for the remainder of the 24 hours
  • 48.
  • 49.
  • 50.
    “The Concept ofPharmaceutical Quality”, Dr. Janet Woodcock, Pharmaceutical Review, 7, 10, 2004: • "For the purposes of clinical use, the established drug quality attributes are generally adequate because they achieve much tighter control of the level of variability than could be detected in patients without extensive study.”
  • 51.
    “The Concept ofPharmaceutical Quality”, Dr. Janet Woodcock, Pharmaceutical Review, 7, 10, 2004: • “In contrast, for regulatory and manufacturing processes, the lack of detailed understanding of the real-world importance of quality attributes is a serious problem, leading to many disputes that might be resolved easily were relevant information available on the relationships between various quality parameters and clinical performance."
  • 52.
    Sources of Variabilityin Therapy • Manufacturing • Drug exposure (PK) • Drug response (PD) • Compliance
  • 53.
    • Snapshot: 17drugs selected randomly from an Internal BCS database of 194 NDAs and variability (%CV) in their exposure parameters – AUC and Cmax – assessed.
  • 54.
  • 55.
    • Assuming thatthe clinical trial formulation is optimized, even for BCS class I products (no high first- pass metabolism), there is in vivo exposure variability of about 20%. Utilize this to come up with rational specs!
  • 56.
    • Opportunities forimprovement: – Select appropriate dissolution method based on physicochemical, in vitro and in vivo characteristics of drug and drug product – Estimate in-vitro variability for LS and LP IR forms – Estimate of dissolution variability of lot(s) used in pivotal efficacy trial(s) would facilitate rational specs – For MR products, estimate in vitro release variability and utilize it to improve upon current IVIVC method which involves mean estimates only.
  • 57.
    • Opportunities forimprovement: – New technology (e.g., PAT) can provide in vitro in vivo relationships based on performance of individual dosage form units! – Elution / release from Complex dosage formulations, e.g., Drug Eluting Stents, Liposomes, should be studied using mechanistic models and new techniques in imaging and fluid dynamics. – Future specs would be based on in vitro mean and variability estimates.
  • 58.
    • Opportunities forimprovement – Early communication • e.g., EOP2 meeting between sponsor and FDA Biopharmaceutics and CMC staff to discuss the development plan.
  • 59.
    • Good homeworkwill always bring dividends!