CarcinogenicityAccepted with a conditionBeyond the letter
Mouse and two-year rat carcinogenicity studies deferred to after approval as postmarketing requirements
Why: Nature of the indication (DMD) and negligible in vivo mutation risk · Serious disease · Weight of evidence
“The Applicant was therefore informed in a Type C meeting (May 11, 2020) that, due to the nature of the proposed indication (i.e., DMD), carcinogenicity studies for givinostat may be deferred until post approval.”
✓ VerifiedFDA integrated review, p. 133Source ↗ “PMR 4575-2 Conduct a 2-year carcinogenicity study of givinostat in rat.”
✓ VerifiedFDA integrated review, p. 221Source ↗ GenotoxicityAcceptedBeyond the letter
Positive Ames result accepted after a follow-up transgenic rat (Big Blue, Pig-a) mutagenesis assay
Why: In vivo transgenic rat assay showed negligible in vivo mutation risk · Weight of evidence
“Based on a review of these data by the PTCC Genetic Toxicology Subcommittee, it was determined that the risk of in vivo mutation was negligible for givinostat.”
✓ VerifiedFDA integrated review, p. 133Source ↗ Safety marginAccepted with a conditionBeyond the letter
No Cmax- or AUC-based safety margins at repeat-dose NOAELs in mice, rats and monkeys
“However, no relevant Cmax- and AUC-based safety margins could be established for givinostat at the respective NOAELs in subchronic and chronic toxicity studies in mice, rats and monkeys compared to the envisaged therapeutic human doses of 25 to 70 mg bid in DMD patients.”
✓ VerifiedEMA assessment report, p. 31Source ↗ “For this reason, non-clinical repeat-dose toxicity studies cannot significantly support the clinical safety of givinostat, which is adequately reflected in section 5.3 of the SmPC.”
✓ VerifiedEMA assessment report, p. 31Source ↗