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Subcommittee Report:Orally Inhaled and Nasal Drug

Products (OINDP)

Wallace P. Adams, Ph.D.

OPS/CDER/FDA

Advisory Committee for Pharmaceutical ScienceRockville, MD

15 November 2000

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Draft OINDP Guidance

BA and BE Studies for Nasal Aerosols and Nasal Sprays for Local Action

(June 1999; Under Revision)

Under DevelopmentBA and BE Studies for Orally Inhaled MDIs, DPIs and Inhalation Solutions

for Local Action

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Main BA/BE Guidance Issues• Approach to developing a single test for

comparative particle size distribution (profile analysis) based on the cascade impactor

• Approaches to BE in the presence of relative insensitivity of rhinitis and asthma studies to dose-response

• Consideration of in vitro, and PK study of systemic exposure, to assure equivalent local drug delivery

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In VitroBA/BE Questions

To the OINDP Subcommittee(26 April 2000 Meeting)

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Profile Analysis

A1. Should all stages, including the inlet (throat) of the cascade impactor (CI) be considered in a comparison of test and reference products?

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Cascade Impactor Deposition Profile Comparison

C.L Leach, Respir Med 1998;92(Suppl A):3-8

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Profile Analysis

A1. Yes. The data are used comparatively to support BE. The relationship of drug deposition on specific stages to safety and efficacy is not known, therefore, all stages and inlet should be considered.

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Profile Analysis

A2. Should a statistical approach rather than a qualitative comparison be used for profile comparisons? If yes, does the chi-square comparative profile approach seem appropriate?

• A statistical approach is preferred because it allows quantitation

• The chi-square approach is still in progress - it is premature to comment at this time

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In Vitro Tests for DPIs: Comparability

B1. Prior to doing in vivo studies to establish equivalence of a test DPI product, a firm would need to design its product to have the best likelihood of being found equivalent in these in vivo studies.

a. What design features of the device and formulation and what parameters should be considered in determining pharmaceutical equivalence?

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In Vitro Tests for DPIs: Comparability

• Operating characteristics of equivalent devices should be as similar as possible

• Match airflow resistance and flow-rate dependence of drug delivery

• Devices must be functionally similar

• It would be helpful to know what flow rates patients actually generate with the test and reference devices

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In Vitro Tests for DPIs: Comparability

B1b. What comparative in vitro tests should be conducted to help support BE?

• Peak flow rate at particular pressure drops

• Rate of rise in flow in cascade impactor

• Variability of the devices at multiple flow rates

• Goalposts for the in vitro tests should be clinically relevant

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In VivoBA/BE Questions

To the OINDP Subcommittee(26 April 2000 Meeting)

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Clinical Studies for Local Delivery of Nasal Aerosols and Sprays

A1. Three study designs have been proposed in the draft guidance for drugs intended to have local action: traditional treatment study; day(s) in the park study, and environmental exposure unit study. These study designs are based on seasonal allergic rhinitis (SAR).

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Nasal Corticosteroid Dose-Response(e.g., Mometasone Furoate Nasal Spray)

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Mean reduction from baseline in TNSS following once daily dosing for 14 days.EA Bronsky et al, Ann Allergy Asthma Immunol 1997;79:51-6

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Clinical Studies for Local Delivery of Nasal Aerosols and Sprays

Is it feasible to demonstrate a dose-response for locally acting nasal drugs? If not, what other approaches can be relied upon to establish equivalent local delivery?

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Clinical Studies for Local Delivery of Nasal Aerosols and Sprays

A1.

• Yes, but requires hundreds of subjects• Crossover approach is a problem for seasonal allergy due to shortness of the allergy season• If a clinical study is nondiscriminating to dose, rather than relying only on in vitro studies, a scintigraphy study could be considered. However for a multi-phase product (i.e., suspension), it is difficult to make a labeled product that duplicates the marketed product

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Clinical Studies for Local Delivery of Nasal Aerosols and Sprays

A1.

• In vitro tests may be so discriminating, but irrelevant, that they would keep an equivalent product from the market

• A key requirement of a BE test is the ability to show differences. Setting an appropriate goalpost can deal with a very discriminating test

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Clinical Studies for Local Delivery of Nasal Aerosols and Sprays

A1.

• Plasma drug pharmacokinetics could reflect equivalent deposition, dissolution from the nasal suspension formulation, and local concentration. The study may need to involve charcoal block

• No consensus was reached for this question

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Clinical Studies for Local Delivery of Nasal Aerosols and Sprays

A2. Can BE established based on SAR assure BE for other indications such as recurrence of nasal polyps, or other non-SAR conditions?

• More data needed

• No known correlation between SAR and non-SAR

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Clinical Studies for Local Delivery of Orally Inhaled Corticosteroids

(ICS)B1. A number of approaches have been proposed to assess BE of ICS (e.g., clinical trials, bronchoprovocation tests, steroid reduction model, trials with surrogate measures such as exhaled nitric oxide (eNO), etc.)

Are any of these study designs proven to offer better discrimination in terms of dose-response sensitivity?

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Clinical Studies for Local Delivery of ICS

B1.• Perform the BE study at lower doses to avoid plateau of response• Of questionable value

–eNO is not yet acceptable as a surrogate marker

–Beta-agonist reversibility is a potential marker of response

–FEV1 and peak flow changes are small

–Changes with methacholine or histamine challenge cannot be differentiated

• Select the right patients based on entrance criteria

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Clinical Studies for Local Delivery of ICS

B2. What other in vivo approaches (e.g., surrogate markers) might be sufficiently sensitive and validated to establish in vivo BA and BE for inhaled corticosteroids?

• eNO is not accepted yet as a surrogate marker

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PK or PD Studies for Systemic Exposure of Locally Acting Drugs

C. Are there situations where in vitro data plus systemic PK and systemic PD data can be relied on to assure local drug delivery for either nasal or inhaled drugs?

• The participants did not have situations that responded to the question

• For orally inhaled products, the in vitro and PK assessments are important but not sufficient. Clinical studies for local delivery are needed.

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PK or PD Studies for Systemic Exposure of Locally Acting Drugs

C.

• The clinical trial could be a bridging study rather than a full-scale study

• When the nasal dose is increased to increase plasma drug levels for quantitation, the dose should remain within the therapeutic dose range

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Acknowledgments

• Dr. Vincent Lee (Chairperson), Members and Invited Guests of the OINDP Subcommittee

•Nancy Chamberlin (Executive Secretary), OINDP Subcommittee

•Members of FDA’s OINDP Technical Committee

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OINDP Subcommittee Meeting of April 26, 2000

PARTICIPANTS

Vincent H.L. Lee, Ph. D., ChairpersonNancy Chamberlin, Executive Secretary

MEMBERS

Richard C. Ahrens, M.D.James Li, M.D., Ph.D.Stanley J. Szefler, M.D.

CONSUMER REPRESENTATIVE

Gloria L. Anderson, Ph.D.

INVITED GUESTS

Michael Baaske, Ph. D.Charan R. Behl, Ph.D.Richard N. Dalby, Ph. D.Hartmut Derendorf, Ph. D.William Gore, Ph. D.Lester I. Harrison, Ph. D.Walter W. Hauck, Ph. D.Sylvie Laganiere, Ph. D.Thomas R. MacGregor, Ph. D.Nikhil J. Parekh, Ph. D.Sam C. K. Shum, Ph. D.

FDA

Wallace P. Adams, Ph.D.Guirag Poochikian, Ph. D.Eric B. Sheinin, Ph. D.

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Oral Inhalation and Nasal Drug Products (OINDP) Committee*Wallace Adams (Chair)

Working Group Membership

Comparative Badrul Chowdhury Mary FanningClinical Lydia Gilbert-McClain Robert Meyer

Gur Jai Pal Singh (Chair)Wallace Adams Dale Conner

Pharmacodynamic Stella Machado Robert MeyerDonald Schuirmann Sandra SaurezEugene Sullivan Ramana Uppoor

Wallace Adams (Chair)In Vitro Gur Jai Pal Singh Charles Brownell

Bioavailability/ Dale Conner Rabindra PatnaikBioequivalence Moheb Nasr Pradeep Sathe

James Algire Yi Tsong

Guirag Poochikian (Chair)Inhalation Drug Craig Bertha Robert Meyer

Products** Allen Rudman Pharmacologist (TBA)Michael Smela

Comparability of Inactive Ingredients Donald Hare

Comparative Systemic Debra Birenbaum Tien-Mien (Albert) ChenAbsorption (Safety) Dale Conner Robert Meyer

Gur Jai Pal Singh Sandra Saurez

* Part of the CDER BCC and CMC CC** Locally Acting Drug Products Technical Committee

GJPS 11/13/200