Equivalence and Substitution

Regulations fall within the jurisdiction of the individual states.

Pharmaceutical equivalence: same active ingredient, same dosage form, same route of administration, identical in dosage strength or concentration, may contain different excipients 

Therapeutic equivalence:  pharmaceutical equivalence and bioequivalent 

Bioequivalence | ADME

A = absorption

D = distribution

M = metabolism

E = elimination 

The manufacturer must submit graphs to the FDA illustrating the two products containing the same drug have similar blood concentration vs. time curves, including: 

Time to peak

Peak concentrations

Area under the curve (AUC)

References

Approved Drug Products with Therapeutic Equivalence Evaluations aka The Orange Book

The Electronic Orange Book (internet version)

United States Pharmacopeia Dispensing Information (USP/DI) Volume III plus supplements 

Facts and Comparisons, Inc Approved Bioequivalence Codes 

FDA’s Internet Website http://www.fda.gov

Drugs marketed before 1938 are not required to be in The Orange Book.

A Rated

Bioequivalent to the innovator’s drug product 

Therapeutically equivalent to the brand name or reference product

A-rated products may be substituted for one another.

B Rated

NOT bioequivalent to the innovator’s drug product 

B-rated products may not be substituted for one another.

Generally, a tablet cannot be substituted for a capsule, an ointment for a cream.  Most sustained-release or controlled-release are not interchangeable. 

AB Rated

Previously not considered to be bioequivalent and now organized into bioequivalence groups (AB1, AB2, AB3, etc)

Must have the same number or lack of number to be bioequivalent 

Cannot substitute an AB1 product for a product designated as AB2

The Federal government has not passed regulations limiting the substitution of these products although a few states have.

Examples:

Carbamazepine

Digoxin

Levothyroxine

Lithium

Phenytoin

Theophylline

Valproic acid

Warfarin

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