`
`CENTER FOR DRUG EVALUATION AND
`RESEARCH
`
`RESEARCH
`
`APPLICA TI0N NUMBER:
`
`
`
`APPLICATION NUMBER:
`22-228
`
`
`MICROBIOLOGY REVIEW(S)
`
`
`
`
`
`
`
`
`
`
`22-228
`
`MICROBIOLOGY REVIEW(S)
`
`
`
`Product Quality Microbiology Review
`
`17 JUNE 2009
`
`
`22-288/N-000
`
`
`NDA:
`
`Drug Product Name
`Proprietary:
`Bepreve™
`Non-proprietary:
`Bepotastine besilate
`
`ophthalmic solution.
`Drug Product Priority Classification: S.
`
`
`Review Number:
`
`Dates of Submission(s) Covered by this Review
`Letter
`Stamp
`Review Request
`12 NOV 2008
`12 NOV 2008
`17 NOV 2008
`03 JUN 2009
`03 JUN 2009
`N/A
`
`1.
`
`Assigned to
`Reviewer
`20 NOV 2008
`N/A
`
`ISTA Pharmaceuticals®, Inc.
`15295 Alton Parkway
`Irvine, CA 92618
`Paul Nowacki
`949-789-3109
`
`John W. Metcalfe, Ph.D.
`
`Recommend approval.
`
`
`Applicant/Sponsor
`Name:
`Address:
`
`Representative:
`Telephone:
`
`
`Name of Reviewer:
`
`Conclusion:
`
`
`
`
`NDA 22-288/N-000
`
`
`
`Product Quality Microbiology Data Sheet
`
`A.
`1.
`TYPE OF SUBMISSION: Original NDA.
`
`2.
`
`Microbiology Review #1
`
`
`SUBMISSION PROVIDES FOR: A new drug product.
`
`MANUFACTURING SITE:
`
`
`
`
`
`
`
`DOSAGE FORM, ROUTE OF ADMINISTRATION AND
`STRENGTH/POTENCY:
`(cid:190) Solution in LDPE dropper bottle.
`(cid:190) Topical ophthalmic.
`(cid:190) 1.5%.
`
`METHOD(S) OF STERILIZATION: Sterile filtration followed by
`.
`
`PHARMACOLOGICAL CATEGORY: The drug product is indicated
`for the treatment of ocular itching associated with allergic conjunctivitis.
`
`
`SUPPORTING/RELATED DOCUMENTS: None.
`
`REMARKS:
`The NDA is submitted electronically in the CTD format.
`
`As of 13 January 2009 there is no ONDQA Initial Quality Assessment in DFS.
`
`An information request was forwarded by this reviewer to the OND project
`manager for dissemination to the applicant on 15 May 2009. Following is the
`information request:
`
`
`A sterility assurance review of NDA 22-288 is on-going. Please address the
`following comments:
`
` Section 4.2 of Process Validation Plan: 1.5% Bepotastine Besilate
`Ophthalmic Solution (Module 3.2.P.3.3) states the following:
`
`
`“A bulk solution hold study will be performed to demonstrate
`that the bulk solution can be held for a predetermined length of
`time (e.g. multiple days) and will meet chemistry and bioburden
`specifications. The hold time for the sterile filtered bulk solution
`will also be validated.”
`
`
`
`
`
`Page 2 of 17
`
`
`
` (cid:190)
`
`3.
`
`
`4.
`
`
`5.
`
`
`6.
`
`B.
`
`C.
`
`
`
`
`
`(b) (4)
`
`(b) (4)
`
`
`
`NDA 22-288/N-000
`
`
`
`
`Provide the holding times and supporting data/rationale for the bulk solution
`prior to filtration and the sterile solution prior to filling.
`
`Microbiology Review #1
`
`
`
`The applicant amended the NDA on 03 June 2009 with responses to this
`information request. The applicant responses are summarized and reviewed in
`appropriate sections of this review.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`File Name: N022288R1.doc
`
`
`
`
`
`
`Page 3 of 17
`
`
`
`(b) (4)
`
`
`
`NDA 22-288/N-000
`
`Executive Summary
`
`
`
`
`
`Microbiology Review #1
`
`
`Recommendations
`
`A.
`
`Recommendation on Approvability – NDA 22-288/N-000 is
`recommended for approval on the basis of issues pertaining to
`sterility assurance.
`
`
`B.
`
`Recommendations on Phase 4 Commitments and/or
`Agreements, if Approvable – Not applicable.
`
`
`Summary of Microbiology Assessments
`
`I.
`
`II.
`
`
`Brief Description of the Manufacturing Processes that relate to
`A.
`Product Quality Microbiology - Following compounding, the bulk drug
`solution is sterilized
`
`
`
`
`
`
`
`
`Brief Description of Microbiology Deficiencies – There are no
`microbiology deficiencies identified.
`
`Assessment of Risk Due to Microbiology Deficiencies – Not
`applicable.
`
`
`III. Administrative
`
`
`B.
`
`
`C.
`
`A.
`
`
`
`B.
`
`
`
`C.
`
`
`
`
`
`
`
`Reviewer's Signature _____________________________
`
`
`
`
`John W. Metcalfe, Ph.D.
`
`Endorsement Block_______________________________
`
`
`
`
`Stephen Langille, Ph.D.
`
`CC Block
`N/A
`
`
`
`Page 4 of 17
`
`
`
`(b) (4)
`
`13 Page(s) has been Withheld in Full following this page as B4 (CCI/TS)
`
`
`
`---------------------------------------------------------------------------------------------------------------------
`This is a representation of an electronic record that was signed electronically and
`this page is the manifestation of the electronic signature.
`---------------------------------------------------------------------------------------------------------------------
` /s/
`---------------------
`John Metcalfe
`6/17/2009 02:06:27 PM
`MICROBIOLOGIST
`
`Stephen Langille
`6/17/2009 02:07:15 PM
`MICROBIOLOGIST
`
`
`
`
`Deliverables by Mid-Cycle for Product Quality Microbiology
`
`(1)
`
`Team participation requested, submission received and assigned to Microbiology
`reviewer (by day 21).
`(2) Microbiology reviewer performs filing review and a preliminary review of draft
`labeling (by day 45).
`(3) Microbiology reviewer completes the filing checklist and identifies filing issues
`and/or other major deficiencies. Checklist is signed off in DFS by secondary
`reviewer/Team Leader (by day 45).
`(4) When potential fileability issues or serious deficiencies are identified, the
`Microbiology reviewer attends the filing meeting and presents the filing issues
`and/or deficiencies to be communicated to the applicant.
`First review completed prior to mid-cycle meeting with secondary reviewer’s
`concurrence. Information request sent soon after completion of the first review
`(by month 5).
`(6) Microbiology reviewer attends appropriate team meetings and the mid-cycle
`meeting and presents findings accordingly.
`Reviewer and secondary reviewer/Team Leader communicate frequently
`regarding the review status, submission data and deficiencies.
`
`(5)
`
`(7)
`
`
`
`Drug Name: Bepreve™
`Bepotastine besilate
`ophthalmic solution
`
`The following are necessary to initiate a review of the NDA application:
`Content Parameter
`Yes No
`
`
`Is the product quality microbiology information described
`X
`in the NDA and organized in a manner to allow substantive
`review to begin? Is it legible, indexed, and/or paginated
`adequately?
`
`2 Has the applicant submitted an overall description of the
`manufacturing processes and microbiological controls used
`in the manufacture of the drug product?
`3 Has the applicant submitted protocols and results of
`validation studies concerning microbiological control
`processes used in the manufacture of the drug product?
`4 Are any study reports or published articles in a foreign
`language? If yes, has the translated version been included
`in the submission for review?
`5 Has the applicant submitted preservative effectiveness
`studies (if applicable) and container-closure integrity
`studies?
`6 Has the applicant submitted microbiological specifications
`for the drug product and a description of the test methods?
`7 Has the applicant submitted the results of analytical method
`verification studies?
`8 Has the applicant submitted all special/critical studies/data
`requested during pre-submission meetings and/or
`discussions?
`
`
`1
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PRODUCT QUALITY MICROBIOLOGY FILING CHECKLIST
`NDA Number: 22-288
`Letter Date: 12 NOV 2008
`Applicant:
`Ista Pharmaceuticals®, Inc.
`NDA Type: Standard
`
`Stamp Date: 12 NOV 2008
`
`Comments
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I am unaware of any
`pre-submission special
`studies/data that were
`requested.
`
`
`X
`
`
`
`Is this NDA fileable? If not, then describe why.
`
`9
`
`Additional Comments: None.
`
`
`
`
`
`Reviewing Microbiologist
`
`Stephen Langille, Ph.D.
`
`
`
`
`
`Microbiology Secondary Reviewer/Team Leader
`
`
`
`
`
`
`John W. Metcalfe, Ph.D.
`
`
`
`
`
`09 DEC 2008
`Date
`
`Date
`
`
`
`---------------------------------------------------------------------------------------------------------------------
`This is a representation of an electronic record that was signed electronically and
`this page is the manifestation of the electronic signature.
`---------------------------------------------------------------------------------------------------------------------
` /s/
`---------------------
`John Metcalfe
`12/17/2008 07:44:01 AM
`MICROBIOLOGIST
`
`Stephen Langille
`12/18/2008 09:28:00 AM
`MICROBIOLOGIST
`
`