Russell G. Katz, M.D.

July 3, 2003

Page 4

 

 

CMC: Methods Validation

We have not completed validation of the regulatory methods for this application.  We will expect our continued cooperation to resolve any problems that may be identified.

 

GSK commits to continue its cooperation with the Agency to resolve any problems associated with confirming the validation of the analytical methods contained in NDA 21-515 for Wellbutrin XL Tablets.

 

CMC: Categorical Exclusion

We have completed our review of the Environmental Assessment information provided by your firm, and we agree with your request for a Categorical Exclusion from the requirement to perform a full Environmental Assessment for this application.

 

Thank you for completing this review.

 

 

Clinical Pharmacology and Biopharmaceutics

 

  1. Please adopt the following dissolution method and specifications for both strengths of Wellbutrin XL tablets.  Note change in specifications at 4 and 8 hours:

 

Apparatus:                        USP Apparatus 1 (Basket) at 75 RPM

Medium:                        900 mL of 0.1N hydrochloric acid at 37±0.5°C

Specifications:                        2 hours:  [blacked out]

                        4 hours [blacked out]

                        8 hours [blacked out]

                        16 hours [blacked out]

Sample Size:                        12 tablets for each time point in the dissolution profile

 

Item 6 contains the dissolution method and proposed specifications for both Wellbutrin XL Tablets, 150mg and 300mg.

 

2.  Bupropion hydroxylated by CYP2B6.  Recently, in vitro studies have identified more substrates and inhibitors of CYP2B6, and the results of recent in vitro studies suggest that several SSRIs and antiretroviral drugs may inhibit the hydroxylation of bupropion by CYP2B6.  It would be useful to characterize the requirement for dosing modifications, if necessary, when such drugs are given concomitantly with

 

 

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