Guidance for Industry- Synthetic Peptides
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ANDAs for Certain Highly Purified Synthetic Peptide Drug Products That Refer to Listed Drugs of rDNA Origin Guidance for Industry U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) May 2021 Generics ANDAs for Certain Highly Purified Synthetic Peptide Drug Products That Refer to Listed Drugs of rDNA Origin Guidance for Industry Additional copies are available from: Office of Communications, Division of Drug Information Center for Drug Evaluation and Research Food and Drug Administration 10001 New Hampshire Ave., Hillandale Bldg., 4th Floor Silver Spring, MD 20993-0002 Phone: 855-543-3784 or 301-796-3400; Fax: 301-431-6353 Email: [email protected] http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) May 2021 Generics Contains Nonbinding Recommendations TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. 1 II. BACKGROUND ............................................................................................................... 3 III. SCIENTIFIC CONSIDERATIONS FOR ANDAS FOR PROPOSED GENERIC SYNTHETIC PEPTIDES ................................................................................................ 5 A. Active Ingredient Sameness .......................................................................................................... 5 B. Impurities ....................................................................................................................................... 6 IV. SUBMISSION OF ANDAS FOR PROPOSED GENERIC SYNTHETIC PEPTIDES ......................................................................................................................... 9 V. REQUESTING ASSISTANCE FROM FDA ..................................................................... 10 APPENDIX 1 – RECOMMENDED EVALUATION OF PEPTIDE-RELATED IMPURITIES TO DETERMINE WHETHER SUBMISSION OF AN ANDA FOR A SYNTHETIC PEPTIDE THAT REFERENCES A PEPTIDE OF rDNA ORIGIN IS APPROPRIATE .......................................................................................................................... 12 Contains Nonbinding Recommendations ANDAs for Certain Highly Purified Synthetic Peptide Drug Products That Refer to Listed Drugs of rDNA Origin 1 Guidance for Industry This guidance represents the current thinking of the Food and Drug Administration (FDA or Agency) on this topic. It does not establish any rights for any person and is not binding on FDA or the public. You can use an alternative approach if it satisfies the requirements of the applicable statutes and regulations. To discuss an alternative approach, contact the FDA staff responsible for this guidance as listed on the title page. I. INTRODUCTION This guidance is intended to assist potential applicants in determining when an application for a synthetic peptide drug product (synthetic peptide) that refers to a previously approved peptide drug product of recombinant deoxyribonucleic acid (rDNA) origin (peptide of rDNA origin) should be submitted as an abbreviated new drug application (ANDA) under section 505(j) of the Federal Food, Drug, and Cosmetic Act (FD&C Act) rather than as a new drug application (NDA) under section 505(b) of the FD&C Act.2 Specifically, this guidance provides recommendations for evaluating whether an ANDA submission is appropriate for a synthetic peptide that references any of the following five previously approved peptide drug products of rDNA origin: glucagon, liraglutide, nesiritide, teriparatide, and teduglutide.3 Given the current state of technology for peptide synthesis and characterization, FDA believes it is now possible for an ANDA applicant to demonstrate that the active ingredient in a proposed 1 This guidance has been prepared by the Office of Generic Drugs (OGD) in the Center for Drug Evaluation and Research (CDER) at the Food and Drug Administration. 2 This guidance does not address ANDAs for peptides of rDNA origin. Based on the types of data permitted to be submitted in an ANDA (see section 505(j)(2)(A) of the FD&C Act) and current scientific considerations, FDA does not expect that an ANDA could include sufficient evidence (e.g., clinical investigations to assess potential immunogenicity) for approval of a proposed peptide of rDNA origin at this time. An applicant seeking approval of a proposed peptide of rDNA origin may file a 505(b)(2) application or a “stand-alone” NDA submitted under section 505(b)(1) of the FD&C Act. 3 This guidance does not address all studies and information that should be submitted in support of an ANDA for a synthetic peptide. Applicants should check on the availability of other guidances, including product-specific guidances, for such recommendations. Guidances relating to generic drugs can be found at https://www.fda.gov/drugs/guidance-compliance-regulatory-information/guidances-drugs. Product-specific guidances for generic drug development can be found athttps://www.fda.gov/drugs/guidances-drugs/product- specific-guidances-generic-drug-development. Also, a potential applicant may request information on a specific element of generic drug development via controlled correspondence or, for complex products such as peptides, may submit a request for a Pre-ANDA meeting. 1 Contains Nonbinding Recommendations generic synthetic peptide drug product (proposed generic synthetic peptide) is the “same” as the active ingredient in a previously approved peptide of rDNA origin. For a synthetic peptide that is intended to be a “duplicate”4 of a previously approved peptide of rDNA origin, a determination of whether an application for the synthetic peptide should be submitted as an ANDA depends largely on its impurity profile as compared to the impurity profile for the peptide of rDNA origin. Differences in impurities, particularly peptide-related impurities, may affect the safety or effectiveness of a peptide drug product as compared to the RLD. Submission of an ANDA for a proposed generic synthetic peptide for which the reference listed drug (RLD) is a peptide of rDNA origin generally would be appropriate if, among other things, the applicant can: 1) show that, for each peptide-related impurity that is found in both the proposed generic synthetic peptide and the RLD, the level of such impurity in the proposed generic synthetic peptide is the same as or lower than that found in the RLD; 2) show that the proposed generic synthetic peptide does not contain any new specified peptide-related impurity that is more than 0.5 percent of the drug substance;5 3) characterize each new specified peptide- related impurity; and 4) justify for each new specified peptide-related impurity that is no more than 0.5 percent of the drug substance why the presence of such impurity would not be expected to affect the safety or effectiveness of the proposed generic synthetic peptide as compared to that of the RLD.6 This information will enable FDA to evaluate the purity of the proposed generic synthetic peptide and to confirm that it and the RLD of rDNA origin can be expected to have the same safety profile (including with respect to the risk of immunogenicity due to peptide-related impurities) when administered to patients under the conditions specified in the labeling. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public regarding existing requirements under the law. FDA guidance documents, including this guidance, should be viewed only as recommendations, unless specific regulatory or statutory requirements are cited. The use of the word should in Agency guidance means that something is suggested or recommended, but not required. 4 The term “duplicate” generally refers to a drug product that has the same active ingredient(s), dosage form, strength, route of administration, and conditions of use as a listed drug. See the proposed rule entitled “Abbreviated New Drug Application Regulations” (54 FR 28872 at 28877, July 10, 1989). 5 A new specified peptide-related impurity refers to an impurity that is present in the proposed generic synthetic peptide, but not in the RLD. 6 For definitions of specified and unspecified impurities, see guidances for industry ANDAs: Impurities in Drug Substances and ANDAs: Impurities in Drug Products, and the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH) guidances Impurities in New Drug Substances (ICH Q3A(R2)) and Impurities in New Drug Products (ICH Q3B(R2)). The guidances referenced in this document are available athttps://www.fda.gov/drugs/guidance-compliance-regulatory-information/guidances-drugs . We update guidances periodically. To make sure you have the most recent version of a guidance, check the FDA Drugs guidance Web page athttps://www.fda.gov/drugs/guidance-compliance-regulatory-information/guidances-drugs. 2 Contains Nonbinding Recommendations II. BACKGROUND FDA considers any alpha amino acid polymer composed of 40 or fewer amino acids to be a peptide, not a protein. Glucagon, liraglutide, nesiritide, teriparatide, and teduglutide are peptides. A peptide is regulated as a drug under the FD&C Act unless the peptide otherwise meets the statutory definition