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Dear Group,
Greetings for all,
If we conduct BE studies (both fasting and fed) using a batch no:
XXXX of reference products. Only fed study is meeting the BE
criteria. To repeat (fasting) biostudy, If we don't have sufficient
number of same batch number of reference products, what could be the
possible solution?
Experts' opinion on the above critical situation would be appreciated.
Thanks & Regards,
Chanukya.
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The following message was posted to: PharmPK
Dear Chanukya,
As per my opinion should be repeat study done on the same batch. But
in this scenario would you reveal in front of FDA that first fasting
study failed and and without reformulating the test product second
study passes. If second study passes FDA may suspect.
In case of unavailability of innovator same batch you may write to
FDA and get recommendation for the same. But I would like to open
debate on my point.
Regards
Anuj Saini
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You may not use the different brand lot in between fasting and fed
studies. But definitely you can repeat the study with more no. of
voulnteers if it was concluded it was not a formulation issue but
failed due to high intra subject variation.
Pankaj Gupta
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The following message was posted to: PharmPK
Dear Chanukye,
As per your query, if your study is at the exhibit level then change
in the Batch of reference will not matter much as you might not be
submitting the data to any body, you can have the data for support
purpose. But if you are at the level of filling an ANDA or any other
filling, then in my opinion you might have taken the reference which is
already marketed and approved by the regulatory body, so the
analytical data of two different batches can be submitted to the
regulatory body as these should be identical.
Regards
Sukhbir
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