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Biosimilars -- Why We Are Here Biologic products continue to grow world wide and are >$150 billion as a market -- ~50% in The U.S.
Global Biologics Spending and Growth, 2001-2012
180 160 140
SPENDING (US$BN)
Global biologic sales Global biologic growth Global small molecule growth
25%
20%
GROWTH (CONST US$)
120 100 80 60 40 20 0
2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 MAT Mar 2012
15%
10%
5%
0%
The global traditional small molecule Patent Cliff peaks in 2012 and starts to decline biologics are the next logical target
Credit Suisse forecasts that the largest 10 drugs worldwide in 2016 will be largely biologics
Early Biotech Products Are Reaching Mid Age And By The Time Biosimilars Arrive.
Drug
Aranesp Enbrel Epogen Remicade Neulasta Rituxan Herceptin Lantus Avastin Humira Avonex Neupogen
Current Age
10 13 22 13 9 14 13 11 7 9 15 20
Source: http://www.accessdata.fda.gov/scripts/cder/drugsatfda/index.cfm
Interchangeability?
Interchangeable or Interchangeability means:
the biological product is biosimilar to the reference product; it can be expected to produce the same clinical result as the reference product in any given patient; and for a product that is administered more than once to an individual, the risk in terms of safety or diminished efficacy of alternating or switching between use of the product and its reference product is not greater than the risk of using the reference product without such alternation or switch.
Note: The interchangeable product may be substituted for the reference product without the intervention of the health care provider who prescribed the reference product (subject to State laws).
General Requirements
A 351(k) application must include information demonstrating that the biological product:
Is biosimilar to a reference product; Utilizes the same mechanism(s) of action for the proposed condition(s) of use --but only to the extent the mechanism(s) are known for the reference product; Condition(s) of use proposed in labeling have been previously approved for the reference product; Has the same route of administration, dosage form, and strength as the reference product; and Is manufactured, processed, packed, or held in a facility that meets standards designed to assure that the biological product continues to be safe, pure, and potent
General Requirements
The PHS Act requires that a 351(k) application include, among other things, information demonstrating biosimilarity based upon data derived from : Analytical studies demonstrating that the biological product is highly similar to the reference product notwithstanding minor differences in clinically inactive components; Animal studies (including the assessment of toxicity); and A clinical study or studies (including the assessment of immunogenicity and pharmacokinetics (PK) or pharmacodynamics (PD)) that are sufficient to demonstrate safety, purity, and potency in 1 or more appropriate conditions of use for which the reference product is licensed and for which licensure is sought for the biosimilar product FDA has the right to determine, at its discretion, that an element listed above is unnecessary in a 351(k) filing
Exclusivity
BPCIA has exclusivity provisions, and provisions for resolution of patent disputes that differ from ANDA process.
Exclusivity for reference product: No 351(k) product can be approved until 12 years from first licensure of reference product No 351(k) application can be filed until 4 years from first licensure
A new 6 months exclusivity for pediatric studies Section 351 (m) for new or already licensed products, and 1 Year exclusivity provision for the first interchangeable biosimilar approved under 351 (k)
Patent Disputes
Process for patent dispute resolution
Unlike the public patent listing process for generic drugs, the BPCIA provides for a detailed private disclosure process in which
Applicant provides copy of application and shares manufacturing information with innovator Innovator identifies its patents, including process and process patents The parties negotiate and reduce to patents in dispute for litigation, innovator can sue towards end of this process Applicant gives 180 days notice before first commercial marketing, and innovator can seek preliminary injunction
Source: Per Kathleen Uhl, deputy director of CDER office of medical policy as quoted in Pink Sheet Daily September 12, 2012 article 14120912007
Biosimilars So How Did We Get Here In The EU? EU Approach Based Upon Science
European Commission Directive June 2003
Directs EMA to create a regulatory pathway for biosimilars by establishing new Annex on an application for MA with specific dossier requirements for similar biological medicinal products
EMA & CHMP Guideline: Similar Biological Medicinal Product October 2005
Outlines requirements for Marketing Authorization Applications (MAA) based on the demonstration of the similar nature of the two biological medicines
EMA Guideline on similar biological medicinal products, section 2.1: Application of Similar Biological Medicinal Products approach
Due to the complexity of biological/biotechnology derived products the generic approach is scientifically not appropriate for these products
http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2009/09/WC500003517.pdf
EU
RP now (Sept 2012) permitted outside of EU based upon case by case approach and comparative data may be necessary
Japan
RP must be approved in Japan
Canada
RP should be authorized for sale and marketed in Canada
WHO
RP should be approved in licensing country
Comparative data involving non US licensed comparator produt may address, in part requirements under PHS 351(k); bridging data required
Same RP should be used throughout comparability program If licensing country lacks RP, an RP may be used that is widely marketed in a jurisdiction with well established regulatory framework and experience with biologics evaluation and post market surveillance
EU
Possible depending on clinical experience, literature, MoA of proposed indications, safety issues in sub populations Concept paper proposes revising these criteria
Japan
Possible if a similar pharmacological result can be expected in the new indication Not possible if the MoA differs for each indication or is not clear
Canada
Possible depending on MoA, pathophysiological mechanisms of disease, safety profile in relevant indications and/or populations, and clinical experience with reference product
WHO
Possible if, e.g. sensitive clinical test model was used; MoA and/or receptors are the same (or a strong scientific rational and additional is provided); and no special safety issues are expected in the new indication
EU
Comparative clinical trials usually necessary for recombinant proteins; in some cases, clinical PK/PD studies may be sufficient All biosimilar applications granted to date contained substantial clinical data
Japan
Clinical studies generally required, unless nonclinical PK, PD or PK/PD studies are sufficient Type and content of clinical studies assessed on a case by case basis
Canada
Comparative PK and PD should be conducted Comparative efficacy and safety trails are critical
WHO
Clinical trials are usually required Confirmatory human PK/PD data may be used in lieu of efficacy trials, provided that there is sufficient scientific justification
EU
Determined by Member States Biosimilars are not a generic Decision to treat a patient with an RP or biosimilar should be made following an opinion of a healthcare professional
Japan
Important to assure traceability of adverse events during surveillance period Switching between a biosimilar and the RP should in principle be avoided throughout the treatment period
Canada
Biosimilars are not generics. Authorization is not a declaration of pharmaceutical or therapeutic equivalenence with the reference product
WHO
Biosimilars are not generics Determined by national authorities
EU
To support pharmacovigilance, the specific product given to the patient should be clearly identified All biosimilars authorized to date have borne either a brand name or a distinctive feature in the nonproprietary name
Japan
Canada
WHO
Biosimilars should be clearly identifiable by unique brand name, the WHOs policy on INNs should be followed
Lot number is essential for traceability
The non proprietary Not addressed names and brand names of biosimilars should be readily distinguishable from the names of reference products and other biosimilars
A very detailed naming policy with examples for biosimilar naming
Approvals, Failures and Launches of Biosimilars Second Enoxaparin Approved in September 2011 (US)
10/2010: Neutroval 12/2007: Insulin Marvel 1/2010: JCR EPO Alfa
8/2007: EPO Alfa Hexal 06/2006: Alpheon 8/2007: Abseamed 8/2007: Binocrit 04/2006: Omnitrope 04/2006: Valtropin 05/2006: Omnitrope
12/2007: Retacrit 12/2007: Silapo
9/2008: Biograstim 4/2011: Epostim 9/2008: TevaGrastim 05/2009: Omnitrope 6/2010: Nivestim 9/2010: Nivestim
2006
2007
2008
2009
2010
Growth hormone G-CSF Insulin
2011
IFN-alfa LMWH EPO-alfa EPO-zeta
Sources: Datamonitor Consulting; EMA (click here); Australian TGA (click here); Japan MHLW (click here); Health Canada (click here); FDA (click here); company reported data (obtained f rom company websites during April 2011); EU approvals unless otherwise stated
Commercial Impact Of Biosimilars Has Been Modest EU Biosimilar Market Share Value by Country 2009 (IMS)
Germany tends to have favorable biosimilar use -- why is Germany uptake of biosimilars better than average?
Germany was first country of EPO generic launch Biosimilar EPOs are manufactured/marketed by German firms Germany generic penetration of small molecules is very high
Germany branded pricing is high relative to other EU countries Tender driven market Biosimilar prescribing targets of 10%+ are being set by the sick funds for the physicians
The $64,000 Question ..What Does Biosimilar EPO In Germany Sell For?
Emerging Markets Have Had Biosimilars (copy biologics) For Years -- EPO Biosimilar Share Is High in Pharmerging Markets
Biosimilar Epoetins: Gaps in Quality and Potential Safety EU Journal of Hospital Pharmacy Science v 11 2005
Biosimilar (or copy) versions of epoetins have been available in developing countries for many years and are widely used for economic reasons. Despite limited data on the efficacy and safety of biosimilar epoetins, they are prescribed under the assumption that they have similar safety and efficacy profiles as the original product. The aim of this study was Systematically evaluate the quality of biosimilar epoetins Report the potential implications of the results
Biosimilar Epoetins: Gaps in Quality and Potential Safety Eu Journal of Hospital Pharmacy Science v 11 2005 -- Methods
Biosimilar epoetin samples were procured from pharmacies in Brazil, Colombia, India, Indonesia, Iran, Jordan, Korea, Lebanon, Philippines, Thailand, Venezuela, Vietnam, and Yemen. Samples were tested against the European quality specifications for epoetin alfa. The epoetin alfa reference standard was used as control.
What Payer Substitution Can Do To A Brand Norway Payer Allowed Substitution For A Short Period
EMA Pharmacovigilance Working Party Cites PRCA in Biosimilar EPO Trial Important That Accurate Medication Histories Are Maintained for Patients Treated With EPOs Why Unique Naming Is Important
U.K. State Regulatory Body Links Proper Identification of Biosimilar Products With Pharmacovigilance Due to same naming (INN) tracking should be done by brand name
Germany EPO Substitution New Proposal In May 2011 Linked Products That Are Identical For Purposes of Substitution. Identical Defined As Same Drug, Same Manufacturing Process i.e. Identical Regulatory Filing
Biosimilars that are identical among each other are substitutable for each other But NOT across biosimilars
Time, cost and credibility required to develop high quality biosimilars is high resulting in most (but not necessarily all) of the high quality competitors to be know at this point
Sea Change in Biosimilar Landscape Branded Companies Now Clearly Entering Biosimilar Space
Branded Pharmaceutical Companies The Obvious
Merck Partners with Hanwha (Korea) for biosimilar Etanercept for a reported $720 Million Novartis already in biosimilar space with Sandoz subsidiary launched with HGH, EPO, GCSF Boehringer Ingelheim Phase I of biosimilar adalimumab and rituximab initiated Amgen Joint venture with Watson Pharmaceuticals to enter biosimilars Pfizer in biosimilar space with Biocon insulin JV in emerging markets. Initiated phase III biosimilar rituximab clinical studies in Jan 2012 Eli Lilly stated in December 2008 that they were considering efforts in this space
-- Merck essentially folds biosimilar unit into operating units of Merck in April 2012
December 2011, initialized Phase I PK/PD study of BI-695501 (biosimilar adalimumab) in 180 patient three arm trial (biosimilar adalimumab vs US Humira vs EU Humira). Expected completion July 2012
http://www.clinicaltrials.gov/ct2/show/NCT01505491
May 2010, Teva initiates phase I PK/PD trial for TL011 (biosimilar rituximab) vs Rituxan in subjects with rheumatoid arthritis. 60 patient trial expected to complete in January 2012
http://clinicaltrials.gov/ct2/show/NCT01123070
June 2011, Teva announced successful completion of Phase III study of XM22 (lipegfilgrastim) vs branded Neulasta (pegfilgrastim)
http://www.tevapharm.com/en-US/Media/News/Pages/2011/1580531.aspx
July 2011, Tevagrastim (biosimilar neupogen) already approved in EU (2008) could enter the US market as early as November 2013 (named Neutroval) after a settlement with Amgen
Tbo-filgrastim approved in the U.S. August 29th 2012 as a 351(a) application, and is therefore technically not a biosimilar since it was not approved under 351(k)
October 3, 2012 halts PIII development work on biosimlar rituximab
December 2011, Amgen and Watson pharmaceuticals announce a joint development program for oncology biosimilars. Watson will invest up to $400 Million into the venture and receive royalty and sales. The new venture will not target Amgen products
http://ir.watson.com/phoenix.zhtml?c=65778&p=irol-newsArticle&ID=1641101&highlight
January 2012, Initiated phase III U.S. trial for biosimilar filgrastim and global Phase III for biosimilar pegfilgrastim
http://www.sandoz.com/media_center/news/2012/press_releases/2012_01_19_biosimilars_phaseIII_trials.shtml
Sandoz/Novartis reportedly has 8-10 molecules in development including mAbs January 2011, Sandoz initiates Phase I PK/PD trial with biosimilar rituximab in 164 patients with expected trial completion date of April 2012
http://clinicaltrials.gov/ct2/show/NCT01274182
December 2011, Sandoz initiates Phase III clinical trial of biosimilar rituximab vs Rituxan in lymphoma. 618 patient trial expected to complete in October 2013
http://clinicaltrials.gov/ct2/show/NCT01419665
Celltrion has reported top level results of the Phase III trial as being successful, and expect approval in mid 2012 with a rolling submission Celltrion has GMP as they reportedly have a contract with BMS to manufacture Orencia (abatacept) Celltrion received approval in S. Korea for biosimilar infliximab in July 2012 and has launched in September 2012 at a 30% discount to branded Remicade (consistent with S. Korean price regulations) Celltrion files biosimlar infliximab with EMA Filing Accepted April 2012
Conclusions
Biosimilars are here, and will continue to develop as a market Global standards (EU, US, Japan, WHO) do not see biosimilars as generics Clinical trial requirements, in general, are different and more complex than with small molecule generics Due to differences in biosimilar vs RP, ability to track/trace and identify products is critical however INNs are not currently unique except by regulatory decree (e.g. Japan) Many areas are still unclear, even with the passage of ACA/BPCI
Questions?
Backup
Why Are Regulatory Bodies So Consistent On Substitution? It Is Not Easy To Make A Bioloigic Even If You Are The Original Inventor
Myozyme Scale Up From 160 liter to 2000 liter Facility Requires New Biologic License Application
Genzyme Initially Submits 2000 liter Application in Early 2007 For Myozyme
FDA Does Not Accept Myozyme Crossover Data Calls For Separate BLA
Lumizyme (2000 liter) Finally Approved By FDA in May 2010 Still Different from Myozyme