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© Bird & Bird LLP 2010 Thanks to our Sponsors!! Bird & Bird LLP Engel & Novitt, LLP Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
© Bird & Bird LLP 2010 GoToWebinar Attendee Interface 1. Viewer Window 2. Control Panel
Biosimilars Europe AIPLA Webinar-8 December, 2010 Liz Fuller, Partner Liz.Fuller@twobirds.com
© Bird & Bird LLP 2010 Overview ● Chemicals vs. Biologics-bioequivalence and comparability ● Authorisations to date ● Biosimilars in Europe-Legal basis for authorisation ● What's New-Draft Guidelines out for Biosimilars of Monoclonal Antibodies ● Summary
© Bird & Bird LLP 2010 Generics: Chemicals vs Biologics ● Chemical products are created by mixing together well-defined chemicals under controlled circumstances. The resultant product can be analysed in a laboratory to determine that it is identical to that of an originator/innovator. Therefore easy to compare to reference product for bioequivalence. ● Biological products are alive (e.g., vaccines, mAbs, recombinant proteins). They are created by engineering living cells to produce the desired protein or antibody. As the living cells are unique, the products so produced can never be absolutely identical to that of an originator/innovator. ● “Biological medicinal products can be defined therefore largely by reference to their method of manufacture.”
© Bird & Bird LLP 2010 Biosimilars to date ● EU approvals Omnitrop-Sandoz (reference Genotropin) Binocrit, Abseamed, Epoietin Alfa Hexal-Sandoz (reference Eprex) Silapro-Stada (reference Eprex) Retacrit-Hospira (reference Eprex) Valtropin-BioPartners (reference Genotropin) Filgrastim-Sandoz/Hexal (reference Neupogen) ● EU rejections Alpheon-interferon α-2a and interferon β-BioPartners Insulin Human Marvel-Marvel LifeSciences-withdrawn ● US-Omnitrop-Sandoz (reference Genotropin)
© Bird & Bird LLP 2010 So why are Biosimilars important? ● Biosimilars have strongest growth in the pharma sector, and are not priced as are other “generics” ● They are an extremely expensive category of products used to treat very serious indications ● Many other products under development by: BioPartners, Merck BioVentures, Sandoz, Bioceuticals, Biogenerix, Ambrx, et al. Other major pharma companies have indicated they will enter this market. ● Regulatory environment and legal status in flux in EU, on a case-by-case basis In US, legal pathways created in Biologics Act in March 2010-Guidances forthcoming
© Bird & Bird LLP 2010 Biopharmaceuticals: Biogenerics, Biosimilars and Follow-on Biologics ● Biological pharmaceuticals manufactured by biotechnology methods, i.e., involving the use of living organisms (cells, bacteria, yeast) ● Biopharmaceuticals are defined by their manufacturing processes. If they originate in different cell lines, they are distinct, i.e., not bioequivalent. As such, there is technically no such thing as a biogeneric, though the term is often used. ● It is however, possible to demonstrate comparability to the originator’s product, the term “biosimilar” is used in Europe, while the terms biosimilar and “follow-on biologic” are used by the FDA.
© Bird & Bird LLP 2010 Relevance of this lack of “identicality” ● Immunogenicity-significant danger to patients ● Very difficult to develop products from a different cell line-only very large sophisticated companies can manufacture and support biotech development. ● Very minor changes in the manufacturing process can result in profound differences in safety and efficacy of the product (e.g., Eprex) ● Extensive post-marketing surveillance is required, and effects “substitutability” by physicians and pharmacists (US), problem with INN ● Perhaps particularly relevant in case of mAbs-due to multi- determined (and sometimes poorly understood) efficacy
© Bird & Bird LLP 2010 Eprex and PRCA ● J & J (Ortho Biotech/Janssen-Cilag) altered its manufacturing process (and presentation) of erythropoietin marketed in the EU, Eprex. ● On the market for 10 years, and in 2002, PRCA (pure red cell aplasia) was identified in patients with CRF and/or CRI that had received Eprex SC. MA in that indication suspended in EU for nearly 4 years. ● There were over 65 variations in the EU to the original Eprex registration. ● Significance is that problems of the RMP effect profoundly effect subsequent developments and regulatory strategies (specific exception made for Binocrit from the EPO development guideline in this case- Eprex was not used as a comparator in SC studies in renal anaemia patients and therefore no second randomised, parallel group clinical trial could be conducted). ● Regulatory Authorities far more strict on safety issues and also in imposing post-marketing obligations.
© Bird & Bird LLP 2010 Pharmaceutical Regulation in Europe ● Most chemical products-National Regulatory Authorities either individually or through DCP or MRP ● Biotech products (e.g., recombinants, mAbs, transgenic products), orphan medicinal products and products for the treatment of certain types of disease (e.g., autoimmune, cancer and diabetes)-mandatory that they obtain regulatory approval at the EMEA (European Medicines Agency-London)
© Bird & Bird LLP 2010 Biosimilar MA Route-EU Legal Basis ● Amendments to Annex I of Directive 2001/83 (2003/63/EC) ● CPMP Guidance Notes (2003) ● Amendments to text of Directive 2001/83 (2004/27/EC) ● Various CHMP Guidelines in 2005-2007 ● Various Product-specific CHMP Guidelines (G-CSF, Somatropin, human soluble insulin, Erythropoietins, alpha interferon and LMW heparins (draft))
© Bird & Bird LLP 2010 Amendment to Directive 2001/83 (2003/27/EC) Article 10.4 “Where a biological medicinal product which is similar to a reference biological product does not meet the conditions in the definition of generic medicinal products, owing to, in particular, differences relating to raw materials or differences in manufacturing processes of the biological medicinal product and the reference biological medicinal product, the results of appropriate pre-clinical tests or clinical trials relating to these conditions must be provided. The type and quantity of supplementary data to be provided must comply with the relevant criteria stated in Annex I and the related detailed guidelines. The results of other tests and trials from the reference medicinal product’s dossier shall not be provided.” In force as from 30 October 2005.
© Bird & Bird LLP 2010 Draft Guideline on biosimilar medicines containing monoclonal antibodies ● Released for Consultation 26 November 2010 until 31 May 2010 ● Addresses Non-clinical, Clinical and Post-marketing issues (both PV and post-marketing clinical requirements) ● Quality issues are not addressed-rather the reader is referred to existing Guidances EC/CHMP/49348/05 (which is soon to be revised) and CHMP/BWP/15753/07 ● To be read in conjunction with the general guidelines set forth in the "Guideline on similar biological medicinal products containing biotechnology –derived proteins as active substance: non-clinical and clinical issues (EMEA/CPMP/42832/05)
© Bird & Bird LLP 2010 Non-clinical development for biosimilar mAbs ● Scientific Advice strongly recommended ● Risk-based approach to be evaluated on a case-by-case basis in the choice and extent of in vitro and in vivo studies ● Determination as to whether in vivo studies are required will depend on the availability of a relevant animal model-large comparative tox studies in non-human primates are not recommended, though, due to the specificity of mAbs, the relevant species for tox studies is in most cases a a non-human primate. ● If the conduct of the in vitro studies raises no specific safety concerns, it is possible that no in vivo animal studies will be required.
© Bird & Bird LLP 2010 Clinical development of biosimilar mAbs ● Again, close collaboration with EMEA through scientific advice is strongly recommended. ● A comparative PK study in a sufficiently sensitive and homogeneous population forms an integral part of biosimilar mAb development, usually in a parallel-group design due to the long half-life of mAbs and potential interference of immunogenicity. ● PK data can be used to extrapolate data on both safety and efficacy to other indications-generally most sensitive to immunogenicity must be used. ● Dose-concentration-response studies will always be required ● Specific considerations for extrapolation to additional oncological indications. ● Focus of exercise is to demonstrate similar efficacy and safety relative to the reference product, not to patient benefit, per se
© Bird & Bird LLP 2010 Biologic patents to expire-according to BIO Humira (Abbot) 2016Neulasta (Amgen) 2015 Aranesp (Amgen) 2014Enbrel (Amgen) 2012 Myozyme (Genzyme) 2016Fabrazyme (Genzyme) 2015 Herceptin (Roche) 2018Avastin (Roche) 2018 Rituxan (Roche) 2018Lucentis (Roche) 2018 Erbitux (Eli Lilly) 2017Remicade (J & J) 2014 Synagis (AZ) 2018
© Bird & Bird LLP 2010 Questions and answers
Thank you Liz Fuller Partner Liz.Fuller@twobirds.com Bird & Bird is an international legal practice comprising Bird & Bird LLP and its affiliated businesses. www.twobirds.com
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