# \[e-drug\] Bio equivalence studies of endogenous substances

**URL:** <https://talk.edrugplus.org/t/e-drug-bio-equivalence-studies-of-endogenous-substances/43913>\
**Category:** e-drug\
**Created:** [September 26, 2017, 3:09pm UTC](https://talk.edrugplus.org/t/e-drug-bio-equivalence-studies-of-endogenous-substances/43913 "2017-09-26T15:09:58Z")\
**Posts on this page:** 1\
**Page:** 1

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**Author:** ![Maryam\_Bigdeli](https://avatars.discourse-cdn.com/v4/letter/m/b77776/32.png) [@Maryam\_Bigdeli](https://talk.edrugplus.org/u/Maryam_Bigdeli)\
**Post date:** [September 26, 2017, 3:09pm UTC](https://talk.edrugplus.org/t/e-drug-bio-equivalence-studies-of-endogenous-substances/43913/1 "2017-09-26T15:09:58Z")

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E-DRUG: Bio equivalence studies of endogenous substances  
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Dear e-druggers  
Some of you may have followed the Levothyroxine crisis in France.

To avoid overloading this discussion group, I will not relate the crisis  
itself and will keep my question very simple: How does your country manage  
approval of endogenous substance substitutes, based on bioequivalence  
studies ? Or in other terms what norms of bioequivalence does your country  
apply? Especially for Levothyroxine.

A small background information:  
As you know, generic medicines can be approved based on bioequivalence  
studies. However, these bioequivalence studies are difficult to realise for  
substitutes of endogenous hormones such as thyroxine.

Bioequivalence on healthy volunteers is problematic because these subjects  
have a natural production of T4 that will bias the results.

FDA requirements are therefore to do bioequivalence studies with  
supra-therapeutic doses (600 mcg bolus dose) and measurement of plasmatic  
T4 levels corrected for baseline (the correction being negligible because  
of the large bolus dose)

The American Endocrine Society disputes these norms because of the narrow  
therapeutic range of Levothyroxine and urges FDA to either change their  
requirements (and require switch studies of therapeutic doses on patients  
without a thyroid) or to NOT declare thyroxine substitutes as equivalent.  
Several publications also contend this approach to bioequivalence of  
Levothyroxine.

However,the alternative option is to test new formulations on patients  
without a thyroid, and checking for TSH levels rather than T4: this  
alternative raises an ethical issue of subject recruitment and length of  
the study (several weeks, to allow TSH levels to stabilize).

Hence my question: do you know what requirements your country applies? And  
can you share these with me?

Many thanks in advance  
Maryam Bigdeli  
Health Systems Speciaist  
Maryam Bigdeli \<maryam.bigdeli@zenerves.net\>
