Home FDA Review of Inavolisib Tablets: Established Conditions and Formulation Change Bridging

FDA Review of Inavolisib Tablets: Established Conditions and Formulation Change Bridging

Jul 04, 2025 19:34 CST Updated 19:34
Genentech

Pharmaceutical R&D Manufacturer


Product Information

NAVOLISIB Tablet

NDASerial Number

219249

Specification

3 mgAnd9 mg

Route of Administration

Oral

Applicant

GENENTECH, Inc.

Treatment Classification

Tumor

RLD

New Molecular Entity

Proposed Indications

Phosphatidylinositol-4,5-Diphosphate3-Kinase (PIK

Catalytic Subunit α Isoform Protein (p110α; byPIKCASelective inhibitor of gene coding, used for the treatment of breast cancer

Product Appearance

Film-coated Tablets:

• 3 Milligram: Red round convex tablets, one side engraved with"INA 3"Legend.

• 9 Milligrams: Pink oval tablets, one side engraved with"INA 9"Legend.


ICH Q12 Development Established Conditions:

The applicant submits a Product Lifecycle Management (PLCM) document detailing the proposed plans regarding Established Conditions (ECs), Non-Established Conditions (non-ECs), and the Post-Approval Change Management Protocol (PACMP). The applicant confirmed via an Information Request response (June 25, 2024): "Changes to the Established Conditions listed in the PLCM document will be implemented in accordance with regulations and guidelines, as described in Section 2 of the PLCM, 'Identification of Established Conditions': 'Relevant changes will be reported to regulatory authorities based on applicable regulatory requirements, the type of EC change, and the degree of impact on product quality.'"

According to the FDA's opinion, this application does not require a PQS assessment, as all established conditions listed in the PLCM will be implemented in accordance with regulations and guidelines. OPQ’s evaluation of EC focuses on whether the applicant has scientifically justified the proposed EC and excluded content that the FDA might typically consider as EC. The applicant agreed (on August 22, 2024) to update the established conditions in Table R-5 of Module 3.2 of the Product Lifecycle Management (PLCM).

PACMP includes the proposal to change the number of tablets per bottle from 30 to 28 to align with the 28-day dosing cycle. The bottle packaging will remain unchanged. The applicant plans to submit a CBE-0 filing for the 28-tablet bottle configuration. The applicant's proposal is reasonable, with a low risk of change. The comparative protocol for adjusting the tablet count, related labeling, and supporting data package for the change is acceptable.

Interpretation:The applicant submitted a product lifecycle management document according to Q12 during the NDA application, defining the EC, which is the number of tablets per bottle, and its revision can be submitted as CDE-0. The development and management document of this EC have been agreed upon by the FDA. The ICH Q12 guideline is used to guide product lifecycle management and the setting of EC conditions. Applicants may refer to this guideline, set EC conditions based on product development and possible post-marketing changes, and submit corresponding research data and plans to reach an agreement with regulatory authorities. This could lead to a downgrade in the level of post-marketing changes and improve the timeline for change implementation.

Formulation Bridging

The proposed commercial formulation for Inavolisib tablets at 3 mg and 9 mg has evolved from multiple clinical formulations, with the applicant making minor adjustments to accommodate different dosage strengths (b)(4), as shown in Figure 1. A film coating (b)(4) was introduced, and the color of the proposed commercial formulation was optimized for sufficient market acceptance.

Module 3.2.P.2 provides a qualitative and quantitative comparison of all clinical formulations with the primary stability study formulations. Table 4 shows the formulation comparison for Phase I clinical, Phase III clinical, primary stability studies, and the proposed commercial formulation. The dissolution testing of critical clinical batches (formulations F08/09 and F14/15) was conducted using the proposed paddle method at the specified rotation speed. During the formulation bridging study, representative critical batches were also tested using the proposed quality control method at 50 rpm.

The applicant conducted bridging studies for formulations at various clinical development stages through in vitro dissolution tests under different pH conditions (pH1.1, pH4.5, and pH6.8). The specific results are shown in Figures 12A, B, and C.



From the early prescription development stage to Phase II and the main stability study stage, the tablets showed similar dissolution behavior in the pH range of 1.1 to 6.8, consistent with the characteristics of immediate-release formulations. Additionally, Figures 13A, B, and C show the dissolution profile comparisons between Phase III batches and main stability batches using the commercial testing method (USP Apparatus 2 (paddle method) at 50 rpm) in 0.1N hydrochloric acid medium, pH 4.5 acetate buffer, and pH 6.8 phosphate buffer, respectively (Note: Formulation F15 was not tested under the 50 rpm condition. Since F15 has the same formulation composition as F09, their dissolution profiles are expected to be consistent).


In 0.1 N HCl, all formulations exhibited similar extremely rapid dissolution behavior, dissolving within 30 minutes (4)(6). In pH 4.5 acetate buffer and pH 6.8 phosphate buffer, all formulations showed similar dissolution profiles (f2 > 50).

Conclusion:The applicant has fully bridged the formulation changes during the clinical development phase through in vitro dissolution comparative tests, demonstrating the similarity between the formulations (*(4)% released within (4) minutes*).

General Recommendations of Biopharmaceutics: Based on the completeness of the submitted information and evaluated from a biopharmaceutical perspective, it is recommended to approve the dissolution method for Inavolisib Tablets (3 mg and 9 mg) for NDA 219249: Use USP Dissolution Apparatus 2 (500 mL of 0.1 N HCl for the 3 mg strength, 900 mL of 0.1 N HCl for the 9 mg strength), at a speed of 50 rpm. The acceptance criteria for batch release and stability testing is Q = dissolution within 30 minutes (4)%.

Interpretation:The formulation prescription underwent four iterations from Phase 1 clinical trials to pivotal clinical trials, and then to registration stability studies. Even between the pivotal clinical trials and the registration stability studies, there were changes in the formulation. Dissolution data using the applied dissolution method showed that the dissolution profiles of the four generations of formulations were consistent. Additionally, the dissolution profiles under pH 4.5 and 6.8 conditions were also consistent. The dissolution speed used here was not 50 rpm, differing from the proposed commercial dissolution speed. A comparison of dissolution differences between the pivotal clinical batch and the registration stability study batch was conducted using the proposed commercial dissolution method and pH 4.5 and 6.8 media. The data showed no differences between the two, indicating comparability. Therefore, during clinical development, the changes in formulation were adequately bridged by in vitro dissolution to demonstrate their consistency.


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Dr. Wenliang Zeng  
With nearly 20 years of experience in drug research and development, expertise in new drug R&D and registration submission. In the past five years, successfully submitted nearly ten small molecule new drugs for IND applications in both China and the US, and achieved successful marketing application for two Class 1 anti-tumor new drugs. Previously held positions at a large CRO pharmaceutical R&D company, USP Greater China R&D Center, and a Hong Kong-funded API manufacturing plant, leading MNC quality research projects, USP monograph updates, and guiding pharmaceutical QC laboratories to pass national GMP inspections and WHO audits.
Invited by the China Chamber of Commerce for Import and Export of Medicines and Health Products, I led the planning of the salon titled "Quality Research and Registration Strategies for Small Molecule Innovative Drugs" at the 22nd CPHI China (World Pharmaceutical Raw Materials China Exhibition) and delivered a keynote speech. Additionally, I was invited by a professional pharmaceutical forum to give more than ten keynote speeches, including: "Key Points and Case Analysis of Quality Research for Innovative Drugs," "Common Issues and Case Analysis of Communication in New Drug Applications in China and the U.S.," "FDA and EMA Control Strategies for Nitrosamine Impurities," "Statistical Evaluation of Analytical Method Development, Validation, and Transfer," and "Case Analysis of Cleaning Validation in FDA 483."  

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