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Guidance for Industry: Bioequivalence Requirements: Critical Dose Drugs

2006-05-31

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Contact : Bureau of Policy, Science and International Programs Enquiries

Notice

Our file number: 06-112871-930

Health Canada is pleased to announce the release of the finalized Guidance for Industry entitled Bioequivalence Requirements: Critical Dose Drugs. This new category of drugs is intended to replace the categories of narrow therapeutic range drugs and highly toxic drugs defined in Report C of the Expert Advisory Committee on Bioavailability and Bioequivalence (1992). This finalized version has been updated to include additional clarification as a result of comments that have been received (where appropriate) as well as to promote consistency with other Health Canada guidance documents.

The drugs listed in Appendix I are considered to meet the definition of a critical dose drug and are therefore subject to this guidance. The Therapeutic Products Directorate (TPD) will make amendments to Appendix I in two ways. Amendments may be initiated by the TPD where required. Amendments may also be initiated as a result of stakeholder proposals. Stakeholders may propose changes to the list by providing relevant data and supporting justification to the TPD for consideration. This information would not form part of a drug submission and should be provided in advance of filing a submission. If amendments are warranted, appropriate stakeholder notification and consultation will be undertaken.

Comments received during the most recent consultation process, together with responses from the TPD have been collated in a separate document, which is available upon request. Requests for this document should be directed to the e-mail address below.

Questions or comments regarding the content of the guidance, or proposals to modify the list (addition or deletions of drugs) should be directed to:

Bureau of Policy, Science and International Programs,
Therapeutic Products Directorate,
1600 Scott Street,
Holland Cross, Tower 'B',
2nd Floor, A.L. 3102C1,
Ottawa, ON
K1A 0K9.

Telephone: (613) 948-4623
Fax: (613) 941-1812
E-mail: Policy_Bureau_Enquiries@hc-sc.gc.ca

Foreword

Guidance documents are meant to provide assistance to industry and health care professionals on how to comply with the policies and governing statutes and regulations. They also serve to provide review and compliance guidance to staff, thereby ensuring that mandates are implemented in a fair, consistent and effective manner.

Guidance documents are administrative instruments not having force of law and, as such, allow for flexibility in approach. Alternate approaches to the principles and practices described in this document may be acceptable provided they are supported by adequate scientific justification. Alternate approaches should be discussed in advance with the relevant program area to avoid the possible finding that applicable statutory or regulatory requirements have not been met.

As a corollary to the above, it is equally important to note that Health Canada reserves the right to request information or material, or define conditions not specifically described in this guidance, in order to allow the Department to adequately assess the safety, efficacy or quality of a therapeutic product. Health Canada is committed to ensuring that such requests are justifiable and that decisions are clearly documented.

This document should be read in conjunction with the accompanying notice and the relevant sections of other applicable guidances.

Table of Contents

1. Purpose

The purpose of this guidance is to define the Therapeutic Products Directorate (TPD) bioequivalence standards for comparative bioavailability studies involving oral dosage forms of drugs for which bioequivalence is particularly "critical".

2. Definition

"Critical dose drugs" are defined as those drugs where comparatively small differences in dose or concentration lead to dose-and concentration-dependent, serious therapeutic failures and/or serious adverse drug reactions1 which may be persistent, irreversible, slowly reversible, or life threatening, which could result in inpatient hospitalization or prolongation of existing hospitalization, persistent or significant disability or incapacity, or death. Adverse reactions that require significant medical intervention to prevent one of these outcomes are also considered to be serious.

1 The full definition of a serious adverse drug reaction may be found in C.01.001 of the Food and Drug Regulations

3. Background

Since small differences in the amount of a "critical dose drug" available to the body may result in consequences more serious than with "uncomplicated" drugs, the required degree of assurance of the similarity of reference and subsequent-entry products is greater than with "uncomplicated" drugs.

Differing food interactions with reference and subsequent-entry products may have potentially serious consequences. Although specific products may be labelled to be taken with or without food, considering the potential consequences of differing food interactions with products containing such drugs, bioequivalence should be demonstrated under both fasting and fed conditions.

4. Scope

This guidance applies to comparative bioavailability studies involving oral dosage forms of drugs for which bioequivalence is particularly "critical". This includes drugs which commonly exhibit adverse effects which limit the therapeutic use to doses close to those required for the therapeutic effect (e.g., "narrow therapeutic range drugs") or drugs for which the therapeutic use may result in dose- or concentration-dependent adverse effects, which are persistent, irreversible or slowly-reversible, or life-threatening (e.g., "highly toxic drugs").

The drugs listed in Appendix I are considered to meet this definition and are therefore subject to this guidance. The TPD will make additions or deletions from Appendix I in two ways. Amendments may be initiated by the TPD where required. Amendments may also be initiated as a result of stakeholder proposals. Stakeholders may propose changes to the list by providing relevant data and supporting justification to the TPD for consideration. If amendments are warranted, appropriate stakeholder notification and consultation will be undertaken.

5. Requirements

Studies are to be conducted in accordance with the TPD Guidelines, "Conduct and Analysis of Bioavailability and Bioequivalence Studies, Parts A and B" (Guidelines A and B), with the exception that the following standards will be used:

  1. The 90% confidence interval of the relative mean AUC of the test to reference formulation should be within 90.0 to 112.0%; the relevant AUC or AUCs as described in Guidelines A and B are to be determined.

  2. The 90% confidence interval of the relative mean measured Cmax of the test to reference formulation should be between 80.0 and 125.0%.

  3. These requirements are to be met in both the fasted and fed states.

  4. These standards should be met on log transformed parameters calculated from the measured data and from data corrected for measured drug content (percent potency of label claim).

  5. Steady-state studies are not required for "critical dose drugs" unless warranted by exceptional circumstances. If a steady-state study is required, the 90% confidence interval of the relative mean measured Cmin of the test to reference formulation should also be between 80.0 and 125.0%.

Note:Due to the nature of these drugs, it may be necessary to conduct studies in patients rather than in healthy subjects. The variability of the disease states in patients in whom the studies are performed will be an important consideration in deciding the size of cohort which will have to be investigated in order to meet the standards. It is highly recommended that the study group be as homogeneous as possible with respect to predictable sources of variation in drug disposition.

Where a drug is being administered chronically, it may be possible to study bioavailability only during a dose interval at steady-state. The test drug product would be required to replace the reference drug product over a period of at least five half-lives, where feasible, before sampling. Standardization of the study conditions is essential, particularly with respect to the time of day of drug administration and posture of the subject.

Ethical considerations may also dictate that these studies be conducted in parallel groups rather than by a crossover design.

6. Responsibilities & Procedures

Questions or comments concerning this guidance should be addressed to the Bureau of Policy, Science and International Programs, Therapeutic Products Directorate [Phone: (613) 948-4623, Fax: (613) 941-1812].

7. Effective Date

This guidance is effective immediately. Submissions in review on the effective date will be considered on a case-by-case basis.

Appendix I : List of Critical Dose Drugs

Drug Summary of supporting information
Cyclosporine
  • The reported therapeutic range for 12-hour trough (C0) levels from whole blood which appear to minimize side effects and rejection episodes is between 100 to 400 ng/mL as measured by the RIA method based on the specific monoclonal antibody (Compendium of Pharmaceuticals and Specialties (CPS 2003)

  • Therapeutic trough plasma concentrations are 50 to 300 ng/mL (RIA). (Poisondex)

  • Nephrotoxicity has been associated with trough plasma (RIA) levels greater than 250 ng/mL, and hepatotoxicity with levels greater than 1000 ng/mL. (Poisondex)

There appears to be overlap between therapeutic concentrations and those associated with serious adverse effects.

Digoxin
  • Digoxin and other digitalis glycosides may cause potentially fatal arrhythmias (CPS 2003)

  • Serum digoxin levels ranging from 0.8 to 2.0 ng/mL are generally seen in adequately digitalized patients. Levels greater than 2.0 ng/mL are often associated with toxicity. (CPS 2003)

  • Digoxin and the other cardiac glycosides commonly produce adverse effects because the margin between the therapeutic and toxic doses is small; plasma concentrations of digoxin in excess of 2 ng/mL are considered to be an indication that the patient is at special risk although there is considerable inter-individual variation. There have been many fatalities, particularly due to cardiac toxicity. (Martindale: The Extra Pharmacopoeia)

  • The probabilities of occurrence of digoxin-induced arrhythmias at 1.7 ng/mL, 2.5 ng/mL and 3.3 ng/mL are 10%, 50% and 90% respectively (Goodman and Gilman's Pharmacological Basis of Therapeutics)

Flecainide
  • Therapeutic plasma concentrations of flecainide range from 0.2 to 1.0 mcg/mL (CPS 2003)

  • Flecainide can cause new or worsened arrhythmias, potentially including tachycardia that is resistant to conversion to sinus rhythm with potentially fatal consequences.

  • Frequency of occurrence of ventricular arrhythmias appears to be related to dose and to the underlying cardiac disease.

  • In most patients flecainide slows cardiac conduction sufficiently to produce dose-related increases in the duration of the PR, QRS and QT intervals on the ECG. There have been a few cases of torsades de point-type arrhythmia associated with flecainide-induced QT prolongation and bradycardia.

  • For some patients, treatment with flecainide must be started in a hospital.

  • It is recommended that plasma flecainide levels be monitored. Attempts should be made to keep trough plasma levels to below 0.7 to 1.0 mcg/mL The probability of adverse experiences, especially cardiac, may increase with higher trough plasma levels especially when these exceed 0.7 mcg/mL. (CPS 2003)

Lithium

Lithium toxicity is closely related to serum lithium levels and can occur at levels close to the therapeutic range. (CPS 2003)

For manic patients, the dosage should be adjusted to obtain serum concentrations between 0.8 and 1.2 mmol/L (CPS 2003)

Lithium toxicity is closely related to the concentration of lithium in the blood and is usually associated with serum concentrations in excess of 2 mmol/L. (CPS 2003)

In all patients with lithium intoxication, the primary problem is neurologic toxicity that may progress from fine tremor to hyperreflexia, fasiculations, muscular irritability, choreoathesis, clonus, agitation, altered mental status, lethargy, seizures and coma. (CPS 2003)

Symptoms of toxicity, at serum-lithium concentrations above 2 mmol per litre, include hyperreflexia and hyperextension of limbs, syncope, toxic psychosis, seizures, polyuria, renal failure, electrolyte imbalance, dehydration, circulatory failure, coma, and occasionally death. (Martindale: The Extra Pharmacopoeia)

Reports of adverse effects on the heart associated with lithium have included bradycardia due to sinus node dysfunction, which has persisted after stopping lithium, premature ventricular contractions, atrioventricular block, and T-wave depression. (Martindale: The Extra Pharmacopoeia)

Phenytoin
  • Severe cardiotoxic reactions and fatalities have been reported with atrial and ventricular conduction depression and ventricular fibrillation. (CPS 2003)

  • Hematological adverse effects include thrombocytopenia, leukopenia, granulocytopenia, agranulocytosis, and pancytopenia with or without bone marrow suppression. Some reactions have been fatal. (CPS 2003)

  • Dermatological manifestations sometimes accompanied by fever have included scarlatiniform or morbilliform rashes. A morbilliform rash (measles-like) is the most common; other types of dermatitis are seen more rarely. Other more serious forms which may be fatal have included bullous, exfoliative or purpuric dermatitis, lupus erythematosus, Stevens-Johnson syndrome, and toxic epidermal necrolysis. (Physicians Desk Reference (PDR))

  • The most common manifestations encountered with phenytoin therapy are referable to the central nervous system and are usually dose-related. These include nystagmus, ataxia, slurred speech, decreased co-ordination and mental confusion (PDR)

  • Therapeutic phenytoin levels range from 40 to 80 μmol/L. Mild to moderate neurologic toxicity is associated with levels of 80 to 160 μmol/L. At levels above 160 μmol/L, severe neurologic toxicity may occur. (CPS 2003)

  • In epilepsy, dosage should be individualized to achieve maximal benefit, including serum level monitoring (optimal control of seizures without clinical signs of toxicity occurs most often with serum levels between 10 to 20 micrograms/milliliter). (Product Info Kapseals®) Dilantin®), 2002).

Sirolimus
  • Blood levels should be monitored in patients with hepatic impairment; during concurrent administration of inhibitors and inducers of CYP3A4 and P-glycoprotein; and if the cyclosporine dosage is markedly changed or discontinued. (CPS 2003)

  • There is a significant association between trough values less than 5 ng/mL and the severity and occurrence of acute rejection episodes. There is a correlation of the occurrence of hypertriglyceridemia, thrombocytopenia, and leukopenia, but not hypercholesterolemia, with trough concentrations above 15 ng/mL. (Kahan et al. Clin Transplantation 2000;14:97-109)

Tacrolimus
  • May cause neurotoxicity and nephrotoxicity and the likelihood increases with higher blood levels.

  • Monitoring of tacrolimus blood levels in conjunction with other laboratory and clinical parameters is considered an essential aid to patient management. (CPS 2003)

  • In kidney transplant patients a significant correlation was found between tacrolimus levels and the incidence of both toxicity and rejection (Kershner et al. Transplantation 1996;62(7):(920-6)

Theophylline
  • The accepted therapeutic plasma concentration range has traditionally been 55 to 110 μmol/L (10-20 μg/mL) in children and adults. (CPS 2003)

  • Optimum therapeutic serum concentrations are generally considered to range from 10 to 20 micrograms per mL (55 to 110 micromol per litre) (Martindale: The Extra Pharmacopoeia)

  • Atrial and ventricular arrhythmias may occur with serum theophylline concentrations greater than 110 μmol/L, or at therapeutic concentrations in patients with heart disease. Focal or generalized seizures may occur at high serum concentrations, or at therapeutic serum concentrations in predisposed individuals. (CPS 2003)

  • Theophylline has a narrow therapeutic index; therefore, cautious dosage determination is essential. Symptoms of toxicity may even occur when serum concentrations are within the upper end of the therapeutic range (85 to 110 μmol/L), particularly during initiation of therapy (CPS 2003)

Warfarin
  • May cause fatal or nonfatal hemorrhage from any tissue or organ. (CPS 2003)

  • Warfarin is a narrow therapeutic range (index) drug (CPS 2003)

  • Effective concentration reported to be 2.2 ± 0.4 μg/mL. (Goodman and Gilman's The Pharmacological Basis of Therapeutics)

  • Although a relationship between milligram/kilogram ingested and amount of hypocoagulability has not yet been established (Poisondex), the narrow effective concentration range and the seriousness of potential adverse effects, suggest that this drug should be considered a critical dose drug.