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THe BIOWaIVer MONOGraPHS - FIP

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FDCs, as well as products containing only a single drug substance in the Biowaiver<br />

Monographs. With more drug substances in a product, one is confronted with new<br />

challenges. To name a few examples: what if one drug is BCS Class I while the other<br />

is BCS Class II? Are there physical incompatibilities between the FDC partners? What<br />

should the comparators be – other FDCs or can one use the equivalent single drug<br />

products? These and other challenges will surely be the topic of intense discussion<br />

within the Focus Group as we move forward.<br />

Should we consider highest dosage strength or highest single dose to<br />

calculate D:S?<br />

In the Biopharmaceutical Classification System (BCS), an Active Pharmaceutical<br />

Ingredient (API) is classified according to its GI permeability and solubility. Solubility<br />

is expressed in Dose/Solubility (D/S), defined as the volume (ml) sufficient to dissolve<br />

the Dose. “Highly soluble” APIs are those with D/S at or below 250ml over the entire pH<br />

range defined in the guidance. The present FDA (2000) and WHO (2006) Guidances, as<br />

well as the former EMEA (2001) guidances, define Dose as the highest oral immediate<br />

release (IR) dosage strength, i.e. the tablet or capsule with the highest content of<br />

API. However, the recent EMA (2010) guideline defines Dose not as the highest oral IR<br />

dosage strength, but as the highest single oral IR dose administered, referring to the<br />

Summary of Product Characteristics (SmPC). This has resulted in a BCS Class change<br />

for several APIs, such as acetazolamide, metoclopramide and verapamil 11 . In the case<br />

of acetazolamide, the BCS based biowaiver had not been recommended due to its<br />

borderline narrow therapeutic index status and inconclusive solubility/permeability<br />

classifications, so the change in BCS Class did not affect the negative biowaiver<br />

recommendation. However, with the change in BCS Class for metoclopramide and<br />

verapamil, a biowaiver based approval would no longer be applicable in the EU, so<br />

the bioequivalence decision would have to be based on results of a comparative<br />

pharmacokinetic study. It is interesting that the same EMA guidance generally calls for<br />

the highest dosage strength to be used for a pharmacokinetic proof of bioequivalence,<br />

thus revealing a degree of inconsistency between the dose to be considered for in vitro<br />

and in vitro proofs of bioequivalence in this jurisdiction.<br />

Discussion of the merits and disadvantages of the two ways of calculating the<br />

dose:solubility ratio is ongoing. On the one hand, it is the drug product, not the dosing<br />

instructions, which is being tested for bioequivalence and in in vivo BE testing it is usual<br />

to use the highest dosage strength for the study. On the other hand, particularly in<br />

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