FDA’s CMO Janet Woodcock testified at the House of Representatives committee hearing, chaired by Representative Waxman, today, in a thorough presentation of the issues and nuances involved. Testimony at House Committee Hearing today.
An excerpt below
“Current technologies, such as peptide mapping, protein sequencing, and mass spectroscopy enable manufacturers to determine, with certainty, the amino acid sequence of a recombinant protein. However, the amino acid sequence is the most rudimentary characteristic of a protein. Conclusive analysis of other aspects of a protein’s structure requires much more sophisticated technologies and is fraught with uncertainties that are proportional to the size and complexity of the protein itself. Such complexities include: folding of the protein’s amino acid chain into highly organized structures, post-translational modification of the protein with a broad range of biochemical additions (e.g., glycosylation, acetylation, phosphorylation, etc.), and association of multiple protein molecules into aggregates. It is the combination of the protein’s amino acid sequence and its structural modifications that give a protein its unique functional characteristics. Therefore, the ability to predict the clinical comparability of two products depends on our understanding of the relationship between the structural characteristics of the protein and its function, as well as on our ability to demonstrate structural similarity between the follow-on protein and the reference product. Although this may be currently possible for some relatively simple protein products, technology is not yet sufficiently advanced to allow this type of comparison for more complex protein products. Functional characterization, using in-vitro tests, is also of great importance in assessing the similarity of two proteins. For proteins with a well-understood mechanism of action and available functional assays, extensive functional comparisons will enhance understanding of comparability. Future scientific advances may facilitate the ability to perform more meaningful functional testing…
We asked BMS Senior Scientist Declan Moran who is working as part of a multidisciplinary research team in Ireland to develop new bioanalytical tools and methods, which existing commercial analytical technologies (besides the ubiquitous “MALDITOF” were becoming more important in helping to evaluate comparability of “followon” and original biogenerics, and he shared the following insights.
“…No single analytical method can be used to definitively assign comparibility. Orthogonal approaches are proving very useful, and “hyphenated MS solutions” offer 85-90% of the answers, although NMR would still be needed to confirm configuration. Recent advances in gene expression technologies will play a crucial role, since most biotherapeutics are hosted in parent cells(CHO being the favorite due to past FDA approvals), so separation of host cellular material from protein of interest is key and the presence of such things at mitochondrial DNA or RNA could be significant.
Array recognition technology is also becoming very effective in addressing issues, whether these are SPR based technologies such as Biacore or Lectin arrays, as patented by Procognia. All serve to build a fingerprint of the therapeutic of interest.
There is no getting away from traditional wet techniques sucha as IEF and SDS -PAGE as these are still best at separating isoforms.
But here is the rub. To truly say a follow on Biologic is the same as the original, the isoform fingerprint will have to be identical. Thus sensitivity now plays a key role. As yet no analytical methods can successfully map a full isoform sequence and therefore the isoform with the best half life and most bio availability may in reality only represent a very small proportion of the pattern in percentage mass terms. However if the FDA adopts a risk mitigation approach and determines the success of a follow on based upon its treatment affect and lack of immunogenicity than all is up for debate as they will be looking at patient response as the measure and not absolute comparibility.
If follow ons are allowed in the manner stated above then the big players will need to look very seriously into their R&D expenditure, as the cost to market will not support a challenge in the initial years of return on investment.
The key analytical methods shaping up in this area are:
MS- TOF,Q-TOF 3Q all with hyphenated capabilities
Array sequencing(SPR Lectin Ab specific)
qPCR
IEF SDS-PAGE
Any platform based around signal enhancement and sensitivity (whether optical or acoustinc); fluorescence is becoming a key indicator…”
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