U.S. BIOPHARMACOPEIA™ Registry of Biopharmaceutical Products
(proposed)
- nomenclature and registry systems for biopharmaceutical products and active agents, including biosimilars
- provides candidate unique, (bio)similar and (bio)generic BIOPHARMACOPEIA names for products and active agents for selective adoption
by regulatory agencies, formularies, reference sources, public use, etc.
- industry-based and -sponsored, including a free public Web site/database
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Biosimilars (and biogenerics and biobetters) are coming! This raises a number of issues that must be resolved
concerning how to define the most basic aspects and nomenclature (naming) of these and other biopharmaceutical products.
What are we giving names to?
Exactly what is a distinct 'biosimilar' (and 'biopharmaceutical'), and what differences or changes in active agents or finished products require considering these to be new/different products, requiring new names/identifiers?
What biosimilar names/identifiers are needed for active agents and products for different uses and user communities?
For example, the FDA-designated non-proprietary names used for marketing and prescription purposes are the first and most obvious thing (after the trademark) that everyone encounters, with these names framing the underlying perceptions of products (e.g., high-end distinct or low-end generic?). FDA will surely require unique names for biosimilars. But should these names be fully unique or partially unique (indicating biosimilarity); and if so, how and indicative of what type(s) of relationships (e.g., structure, product class, indications, etc.)?
Should these names be based on science (entity-based), regulatory (approvals) and/or market (real world) aspects of each product?
Who will develop and control needed product definitions, nomenclature, information resources, and information dissemination?
And if names are assigned to biosimilars,
will the same nomenclature system also apply to innovator/reference products?
These are difficult issues with broad ramifications (so far, all largely being ignored).
Someone (or, ideally, multiple organizations representing diverse interests) needs to provide recommendations for unique and biosimilar/biogeneric active agent and product nomenclature (names) relevant to diverse user communities and also publicy track/identify marketed products, particularly in the context of biosimilars.
But, essentially all organizations that should already have long been involved, including trade, professional associations and governments, have been avoiding these complex issues and/or have major conflicts-of-interest. And with information needing to be freely disseminated, there is no incentive for private sector publishers to do the job. The U.S. BIOPHARMACOPEIA™ Registry of Biopharmaceutical Products is proposed as, ideally, an industry-based and -funded collaborative scientific/educational project to provide what is needed. If interested please
contact me.
For further information, see the short proposal and Questions & Answers
Links are provided below to articles by the Web master, Ronald A. Rader, concerning
biopharmaceutical and biosimilar terminology, nomenclature systems and the infrastructure of information resources supporting the biopharmaceutical industry.
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New!
published in
BioProcess International, June 2011, by Ronald A. Rader, President,
Biotechnology Information Institute
"Nomenclature of Biosimilars Will Be Highly Controversial"
Abstract: The names to be used for biosimilars (and biogenerics and biobetters) will be highly controversial, including the nonproprietary names
to be designated by FDA for U.S. marketing and prescription purposes. Will these be fully unique? Will names reflect
biosimilarity and if so, by what criteria (e.g.,
structure, product class, indications, be indicative of the reference product or not, etc.)? And how will this be done? Should there a system and
consistency among official names? What exactly will names be assigned to (What is a product, and when what changes in a product require assinging or new
name (or do we need to think in terms of version numbers). Who will coordinate and disseminate nomenclature?
The U.S.
BIOPHARMACOPEIA Registry of Biophaarmaceutical Products is proposed to help resolve these problems.
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published in Nature Biotechnology, July 2008, 26(7), p. 743-751, by
Ronald A. Rader, President,
Biotechnology Information Institute
"Re(Defining) Biopharmaceutical"
Abstract: This peer-reviewed article updates and synthesizes
much of my prior two-part series, "What is a Biopharmaceutical?," and other articles (available below).
This includes discussion of the various definitions of 'biopharmaceutical'; the complexities of these agents/products and what differentiates
biopharmaceuticals from drugs (chemically-derived, chemical substance-based pharmaceuticals), including the process=product paradigm; the flaws and
problems caused by the aberrant definitions in common use promoted by vested interests, including in the context of biosimilars/follow-on proteins; and
proposes actions to resolve these problems, including the
U.S. BIOPHARMACOPEIA Registry of Biopharmaceutical Products.
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published in BioProcess International, March and May 2007, by Ronald A. Rader, President, Biotechnology Information Institute
"What Is a Generic Biopharmaceutical? Biogeneric? Follow-On Protein? Biosimilar? Follow-On Biologic?"
Part 1: Introduction and Basic Paradigms
Abstract: The concepts, paradigms, terminology and definitions concerning generic biopharmaceuticals (biogenerics) are still in a primitive state. Use of essentially all current terms may support, denigrate or obfuscate various views and discussions of the topic, e.g., to many 'biogeneric' evokes negative connotations from association with generic drugs and/or suggests that products are identical, rather than similar/related.
There are three basic views/paradigms/definitions of generic biopharmaceuticals. Entity-based views concentrate on the products and active agents, including chemical structures and the unique aspects imparted by their biological source/identity, manufacturing process and specifications (process=product paradigm). Regulatory-based views concentrate on biopharmaceuticals as being approved or on track for approval as biogenerics (involving abbreviated filings based on comparative testing, sometimes therapeutic equivalence/substitution). Market/commercial-based views concentrate on products as competing for similar/same indications, having similar names, or any other perceived similarities. Depending on the view/paradigm/definition used and whether one takes a world or just Western (major market)-centric view, there are currently either many (hundreds), some or just a few biogeneric products in commerce; and biosimilars/follow-on biologics/biogenerics have either been around for a century or more, a few decades, a few years or do not yet even exist.
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Part 2: Information, Nomenclature, Perceptions, and the Market
Abstract: Because of their complexity,
biopharmaceutical products defy use of various
conventional chemical and
pharmaceutical information paradigms and
methods that work well
with drugs and other chemical
substances. Before one can deal with biogenerics, difficult questions must be answered, e.g., What
defines a biopharmaceutical agent or
product as unique and distinct from
others?; And, what entity-, regulatory-,
and/or market-based changes in an
agent or product require it to be
considered a new, different one? Biopharmaceuticals
will have to be defined, named, and tracked. But how should names be assigned, particularly to biogenerics? Should generic/similar names be
assigned, facilitating marketing as generics but likely decreasing safety, or
should unique names be assigned, favoring safety but likely decreasing the cost savings
generic offer? Both unique and (bio)generic names for
both finished products and active
ingredients will be required for different uses/users. However, current nomenclature systems are
inadequent for biopharamceuticals, e.g., with systematic nomenclature (IUPAC and CAS) designed to index the chemical literature, and nonproprietary
pharmaceutical nomenclature (USAN and INN) designed to handle small molecule, particularly generic, drugs.
New paradigms, terminology,
taxonomy, and nomenclature systems
are needed for biopharmaceuticals,
particularly ones that include
biogenerics. This industry maturation
will be painful, requiring industry and regulators to define products, their relationships and develop related
information resources and educational
programs. The U.S.
BIOPHARMACOPEIA Registry of Biopharamceuticals will assist in this process by developing new nomenclature systems, candidate names and a public Registry of biopharmaceutical products.
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published in the March and May 2005 issues of BioExecutive, by Ronald A. Rader, President, Biotechnology Information Institute:
"What is a Biopharmaceutical?"
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Part 1:
(Bio)Technology-Based Definitions
- This reviews the four very different basic views/paradigms/definitions of what is a biopharmaceutical, concentrating on
technology-based definitions, and the terms and definitions used by U.S. and European Union regulatory authorities.
- Part 2:
Company and Industry Definitions
- This reviews and critiques the views/paradigms/definitions of 'biopharmaceutical' no longer linked to biotechnology, with these aberrant definitions often adopted by many
in the financial community, press, companies and even major U.S. trade associations (BIO and PhRMA).
Abstract - Pharmaceuticals are composed of two major subsets - biopharmaceuticals and drugs (the vast majority). Biopharmaceuticals are pharmaceuticals inherently, usually obviously, biological in nature (e.g., proteins, cells) manufactured using biotechnology (involving live organisms). A derivative view limits this to recombinant proteins. Two other common views/paradigms/definitions ignore linkage to biological nature/biotechnology and take business/market-centric views. These either include as being biopharmaceuticals any/all pharmaceuticals connected with a biotechnology-like (small, entrepreneurial) company or that otherwise can be portrayed as being high-tech; or simply consider all pharmaceuticals to now be biopharmaceuticals (i.e., the drug/pharmaceutical industry is now the biopharmaceutical industry). These later two views are very common, but are dysfunctional, e.g., they arbitrarily include many or even all small molecule and other drugs (pharmaceuticals inherently chemical, not biological, in nature and manufactured by chemical means). With the biopharmaceutical industry lacking its own trade organization representing its interests [and sponsoring projects such as the BIOPHARMACOPIEA], the widespread misuse, cooptation and obfuscation of 'biopharmaceutical' (and 'biotechnology') places the underlying definitions, identity and public perception of the industry at risk to public relations, lobbying and rebranding efforts; and confounds discussions of biopharmaceuticals and related issues, e.g., biogenerics.
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"Nomenclature and Registry Systems for
Biopharmaceuticals and Biosimilars":
[The links below provide access to sections of a large draft article, much of which is discussed more briefly in the ""What Is a Generic Biopharmaceutical?..." articles above].
Abstract:
There are no simple ways to define and assign useful nomenclature (names and other identifiers) to specific biopharmaceutical products, including biogenerics, which add further levels of complexity. This includes names that are unique, unambiguous and useable (relatively short, pronounceable, etc), and generic names that convey information regarding entity, activity, therapeutic equivalence/substitution, class or other relationships among products. Nomenclature systems that work well for chemical substances and drugs fail when applied to biopharmaceuticals, biosimilars, biobetters and biogenerics. This article discusses problems with conventional drug/chemical nomenclature and registry systems as applied to biopharmaceuticals, and the controversies likely to be associated with selection of official names, both unique and generic, for biopharmaceuticals, particularly biogenerics. Nomenclature, since it greatly affects marketing, particularly the names to be officially adopted (for filling of prescriptions) for biogenerics, will be a very contentious issue.
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Nomenclature in Biopharmaceutical Products in the U.S. and European Markets (the book/database by this author)