Generic Drugs: What does equal really...

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Generic Drugs: What does equal really mean?

Dr. Peter J. Lin

Director Primary Care Initiatives

Canadian Heart Research Centre

Conflict Disclosure Information

FINANCIAL DISCLOSURE

Grants/Research Support: None

Speakers Bureau/Honoraria: Astrazeneca, Takeda, Boeringher

Ingelheim, Eli Lilly, Sanofi, Jansen

Merck, Pfizer, Servier , Abbott, Forest

Laboratories, Novartis, Purdue

Consulting Fees: None

Research Funding: None

Other: None

Speaker: Dr. Peter Lin

Title of Talk: Alzheimer’s Update

Blue Cross Blue Shield of

Michigan Billboards

$20 million to test quality of Generics

Antihypertensive Agents Currently Available in Canada

ACE-Is

Benazepril

Captopril

Cilazapril

Enalapril

Fosinopril

Lisinopril

Perindopril

Quinapril

Ramipril

Trandolapril

ACE-I = angiotensin-converting enzyme inhibitor; ARB = angiotensin receptor blocker; CCB = calcium channel blocker

Diuretics

Acetazolamide

Furosemide

Hydrochlorothiazide

Indapamide

Metolazone

Spironolactone

Triamterene

ARBs

Candesartan

Irbesartan

Losartan,

Olmesartan

Telmisartan

Valsartan

Beta-blockers

Acebutolol

Atenolol

Bisoprolol

Labetolol

Metoprolol

Nadolol

Pindolol

Propanolol

Timolol

CCBs

Amlodipine

Diltiazem

Felodipine

Nifedipine

Verapamil

Renin

inhibitors

Aliskiren

Snake-oil Salesman

•How

to

calm

kids

down.

Infants Relief

Chloroform

Cannabis

1962 Impala

FDA – Companies had to prove that a drug

was both safe and effective before it

reached the market place. All new drugs

had to go through a lengthy and expensive

process that included large-scale human

trials.

12

NDA

REVIEWERS

Chemist

Microbiologist

Pharmacologist

Biopharmaceutist

Clinician

Statistician

Compliance

(CMC)

Scientific

Investigations

Preclinical

Phase 1

Phase 2

Phase 3

Phase 4

Office Drug

Safety

Drug Advertising

Advisory

Committee

Searching for Molecules

Drug Development Timeline

15

Graph Source: www.PhRMA.com

Discovery

Safety Efficacy

Production

Sameness

Center for Drug Evaluation & Research

U.S. Food & Drug Administration 17

Hatch-Waxman Amendments to FFD&C Act - 1984

• Allowed generic firms to rely on findings of safety and efficacy of innovator drug after expiration of patents and exclusivities

• (do not have to repeat expensive clinical and pre-clinical trials)

Human bioequivalence studies have been

required for generic drugs since 1984

“Bioequivalence refers to the absence of a significant

difference in the rate at which or the extent to which

the active ingredient in pharmaceutical equivalents

becomes available at the site of drug action when two

drug products are administered under similar

experimental conditions in an appropriately designed

study.”

Welage LS et al. J Am Pharm Assn 2001;41(6):856-857 Abstract

Human bioequivalence studies have been

required for generic drugs since 1984

“Bioequivalence refers to the absence of a significant

difference in the rate at which or the extent to which

the active ingredient in pharmaceutical equivalents

becomes available at the site of drug action when two

drug products are administered under similar

experimental conditions in an appropriately designed

study.”

Welage LS et al. J Am Pharm Assn 2001;41(6):856-857 Abstract

Non-Inferiority Study

Center for Drug Evaluation & Research

U.S. Food & Drug Administration 20

What are the requirements for a generic drug?

• Same active ingredient(s)

• Same route of administration

• Same dosage form

• Same strength

• Same conditions of use

Compared to reference listed drug (RLD) - (brand name product)

Same ??

24

Bioequivalence Example

6 12 18 24 30 36 42 48 0

1

2

3

4

5

6

7

8 Test/Generic

Reference/Brand

25

Bioequivalence Example

6 12 18 24 30 36 42 48 0

1

2

3

4

5

6

7

8 Test/Generic

Reference/Brand

AUC

Bioequivalence

Source: Conduct and Analysis of Bioavailability and Bioequivalence Studies - Part B: Oral Modified Release Formulations.

FDA “The relative mean measured AUC of the

modified-release formulation to the conventional

formulation should be between 80% and 125% in

the fasting state.”

What does Equal Mean?

80% 125%

-20% +25%

45% Window

What does Equal Mean?

80% 125%

-20% +25%

45% Window

How many people do you need to test?

12

FACT: Research shows that generics work just as well as

brand name drugs.

A recent study evaluated the results of 38 published clinical trials

that compared cardiovascular generic drugs to their brand-name

counterparts. There was no evidence that brand-name heart

drugs worked any better than generic heart drugs. [Kesselheim et

al. Clinical equivalence of generic and brand-name drugs used in

cardiovascular disease: a systematic review and meta-analysis.

JAMA. 2008;300(21)2514-2526].

Generic only 3% off

Looked at 8556 studies – only 47 matched criteria

Generic and Brand-Name Drugs Used in Cardiovascular Disease

30 Studies 837 Patients

28 per study

- 0.03

Fillers ???

Generic version almost doubles the inactive ingredients

Additional ingredients may increase the risk for allergic response and

pharmacists rarely caution patients against potential adversities and no

labeling is required. It is unclear how these ingredients will effect the

outcomes of the drug. Ex. sodium lauryl sulfate is (surfactant soap) that

can be used in a degreaser

Inactive Ingredients

Prinivil (Lisinopril) Merck & Co Inactive Ingredients in 20mg dose

1.Calcium Phosphate 4. Starch

2.Mannitol 5. Iron Oxide

3.Magnesium Sterate

Lisinoril by Mylan Inc. Generic Inactive ingredients in 20 mg dose

1.Collidal Sillicon Oxide 5. Providone

2.Croscarmellose sodium 6. pregelatinized starch

3.Diabasic calcium phosphate 7.Sodium lauryl sulfate

4.Mannitol 8.D&C Yellow #10 Aluminum lake HT

Generic version almost doubles the inactive ingredients

Additional ingredients may increase the risk for allergic response and

pharmacists rarely caution patients against potential adversities and no

labeling is required. It is unclear how these ingredients will effect the

outcomes of the drug. Ex. sodium lauryl sulfate is (surfactant soap) that

can be used in a degreaser

Inactive Ingredients

Prinivil (Lisinopril) Merck & Co Inactive Ingredients in 20mg dose

1.Calcium Phosphate 4. Starch

2.Mannitol 5. Iron Oxide

3.Magnesium Sterate

Lisinoril by Mylan Inc. Generic Inactive ingredients in 20 mg dose

1.Collidal Sillicon Oxide 5. Providone

2.Croscarmellose sodium 6. pregelatinized starch

3.Diabasic calcium phosphate 7.Sodium lauryl sulfate

4.Mannitol 8.D&C Yellow #10 Aluminum lake HT

Shelf Life

Ramipril vs 22 Generics

Ramipril vs 22 Generics

STABILITY: Metabolite Ramipril-diketopiperazine (DKP)

Clopidogrel 75mg

Clopidogrel 60mg good enough?

What about

eye drops?

ADD

Time (h)

Meth

ylp

hen

idate

(n

g/

mL)

Pharmacokinetic Profiles for MOH and OROS MPH

1OROS MPH (methylphenidate HCI) ER Tablets Citizen Petition. McNeil Consumer & Specialty Pharmaceuticals. 2004

UK Switch to Simvastatin

Phillips, Br J Cardiol 2007;14:280-5

Osteoporos Int (2012) 23:213–221

Osteoporos Int (2012) 23:213–221

Still on Therpary

Epilepsy – switch to Levetiracetam

November 1, 2008 all patients switched to generic

Retrospective Chart review 260 patients

105 patients Switched back (42.9%)

% Patients with Increased in seizure frequency: 19.6% vs 1.6% p<0.0001

Polytherapy: 3.225 (1.512-6.880) p<0.05

Epilepsia. 2011 Apr;52(4):810-5. doi: 10.1111/j.1528-1167.2011.03025.x. Epub 2011 Mar 22.

Hemorrhagic Events

Ann Pharmacother 2011;45:701-12

0 1 2

N=37,756 Brand only = 4468 1 Generic=20, 292 Switchers = 12,996

Thrombotic Events

Ann Pharmacother 2011;45:701-12

N=37,756 Brand only = 4468 1 Generic=20, 292 Switchers = 12,996

Center for Drug Evaluation & Research

U.S. Food & Drug Administration 57

Clinical/PD Dose-Response

Cli

nic

al/

PD

Res

pon

se

Log Dose

Government

“Because this company continued to violate current good

manufacturing practice regulations and falsify information on

drug applications, the FDA took these actions in an effort to

protect consumers,” said Dara Corrigan, FDA associate

commissioner for regulatory affairs.

Ranbaxy

May 15, 2013

http://features.blogs.fortune.cnn.com/2013/05/15/ranbaxy-fraud-lipitor/

1.Substitute Cheaper, Lower Quality

2.Substitute brand name drugs in lieu of their own

generics in bioequivalance tests to produce better

results

Patent Challenge

180 days exclusivity

(USA)

The lots of atorvastatin, packaged in bottles of 90

and 500 tablets, are being recalled due to

possible contamination with very small glass

particles similar to the size of a grain of sand

(less than 1 mm in size).

Alysena is produced in Spain by Laboratorios

Leon Farma and distributed in Canada by

Apotex. There have been growing concerns over

the quality and safety of drugs produced

overseas and many health advocates question

whether Health Canada is doing enough to

ensure overseas plants are following good

manufacturing practices.

Background

An inspection of a Pharmaceutical Factory in China was

conducted by the European Directorate for the Quality of

Medicines and Healthcare (EDQM) recently. During this

inspection, a concern was identified about possible

contamination of clindamycin with quetiapine. This

contamination may have resulted from trace amounts of

quetiapine on common equipment.

What should we do Today?

Think:

• Adherence?

• Drug working?

• Disease getting worse?

THE CANADIAN SIDE

Thanks for Staying Awake