The FDA's assessment of follow-on protein products: a historical perspective

The scientific and regulatory issues associated with the possible introduction of 'follow-on' versions of protein drug products are currently attracting much attention. Past examples are discussed of the FDA's actions involving the evaluation of various types of follow-on and second-generation protein products and within-product manufacturing changes with a view to illustrating the FDA's scientific reasoning in this area. The scientific and regulatory issues that are associated with the possible introduction of 'follow-on' versions of protein drug products are the topic of considerable debate at present. Because of the differences between protein drug products and small-molecule drugs, the development of follow-on versions of protein products presents more complex scientific challenges than those presented by the development of generic versions of small-molecule drugs. Here, with a view to illustrating the Food and Drug Administration's (FDA's) scientific reasoning and experience in this area, we discuss past examples of the FDA's actions involving the evaluation of various types of follow-on and second-generation protein products and within-product manufacturing changes. The FDA believes its evaluation of the safety and effectiveness of follow-on protein products will evolve as scientific and technological advances in product characterization and manufacturing continue to reduce some of the complexity and uncertainty that are inherent in the manufacturing of protein products.