Study lengthAcceptedBeyond the letter
No repeat-dose study longer than 4 weeks; 13-week monkey study waived
Why: High ADA incidence in monkeys caused loss of exposure and effect; effects similar to other B-cell depleting agents · Pharmacology or kinetics · Class precedent
“Studies longer than 4 weeks were not performed, as glofitamab was highly immunogenic in cynomolgus monkeys leading to loss of exposure and loss of the pharmacologic effect.”
✓ VerifiedFDA multi-discipline review, p. 57Source ↗ “The waiver for omitting the 13-week study is therefore accepted, also as the observed effects of glofitamab is similar to that observed for other B-cell depleting agents, and no unexpected findings have been observed.”
✓ VerifiedEMA assessment report, p. 33Source ↗ DARTAccepted
No animal reproductive or developmental toxicity studies; weight-of-evidence risk assessment instead
Why: Weight-of-evidence per ICH S6(R1); further testing unlikely to add to current nonclinical and clinical knowledge · Weight of evidence · Within the guideline · Class precedent
“While no animal studies were conducted to assess the reproductive and developmental risks of glofitamab, a weight of evidence (WoE)-based risk assessment report was submitted.”
✓ VerifiedFDA multi-discipline review, p. 41Source ↗ “Based on the justification provided, and in accordance with ICH S6 (R1) it is agreed that no further testing is required in order to elucidate the reproductive toxicity of glofitamab in cynomolgus monkeys, as it is not likely it will add further information to the current non-clinical and clinical knowledge to support the mitigation of this risk in humans.”
✓ VerifiedEMA assessment report, p. 35Source ↗ Safety marginAccepted
Monkey exposures below clinical: AUC multiples 0.03 to 0.28 in studies without obinutuzumab pretreatment
Why: Advanced cancer indication; adverse effects from exaggerated pharmacology; no alternative species besides monkey · Serious disease · Within the guideline · Pharmacology or kinetics
“In summary, obtained exposure levels in toxicology studies conducted without Gpt did not exceed those obtained in the clinical setting, as estimations of exposure multiples resulted in values of 0.03 to 0.28 (based on AUC), implying that CRS-related effects occur at clinically relevant dose levels.”
✓ VerifiedEMA assessment report, p. 35Source ↗ “The low exposure multiples are considered acceptable, taking into account the indication (advanced cancer), that the expected adverse effects of glofitamab occurs mainly due to exaggerated pharmacology or secondary to it, and that no obvious alternative animal species besides the monkey are available for toxicology studies.”
✓ VerifiedEMA assessment report, p. 35Source ↗