Emgality: what was done before first-in-human, and what came after?
galcanezumab · CGRP
Before first-in-human
First-in-human: where
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
Repeat-dose tox before first-in-human
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
First-in-human starting dose
Not stated in public reviews
Why it's blank
The public FDA and EMA reviews of Emgality don't say how the first human dose was chosen. That rationale is in the IND, which is confidential, so it is missing for most approved products.
How it's usually set for monoclonal antibodies
Use pharmacology data (target binding, receptor occupancy, in vitro human cells, PK/PD modelling) to estimate the lowest dose expected to have any biological effect (MABEL) and the active dose (PAD), and, for healthy volunteers, start at an exposure below the PAD unless robustly justified.
“these data should be used to determine the minimal anticipated biological effect level (MABEL) in humans and an estimation of the pharmacologically active dose (PAD) and/or anticipated therapeutic dose range (ATD) in humans.”
This product's starting point
NOAEL / key findings: Rat 6-month NOAEL low dose (2 high-dose male deaths, drug relation not ruled out); monkey 6-month NOAEL high dose (injection-site irritation non-adverse) (FDA pharmacology/toxicology review, p. 60)
Longest repeat-dose systemic studies
Longest repeat-dose study and recovery
6-month SC studies in rat and cynomolgus monkey; no recovery listed for them (shorter studies had 9- and 6-week recovery)
“The pivotal (GLP) subcutaneous (SC) toxicity studies (6-week + 9-week recovery, 3-month + 6- week recovery, and 6-month) were conducted in Sprague-Dawley rat and cynomolgus monkey.”
Pivotal GLP studies
Rat and cynomolgus monkey SC: 6-week (+9-week recovery), 3-month (+6-week recovery) and 6-month studies
“The pivotal (GLP) subcutaneous (SC) toxicity studies (6-week + 9-week recovery, 3-month + 6-week recovery, and 6-month) were conducted in Sprague-Dawley rat and cynomolgus monkey.”
DART package
Species: DART
Rat (male and female fertility, EFD, pre/postnatal) and rabbit (EFD)
“Studies in rats were conducted to assess the potential effects of galcanezumab on male and female fertility, embryo-fetal development (also in rabbits), and prenatal and postnatal development.”
Reproductive & developmental
Rat and rabbit studies: no drug-related fetal/offspring effects; an unexplained high-dose dam death in the rat pre- and postnatal study
“No drug-related effects were observed in the fetuses/offspring of either species. The only maternal finding of note was a death (Lactation Day 15) at the high dose in the pre- and postnatal study; the cause of death was not identified.”
PPND / ePPND: when
PPND in rat completed before the marketing application
“The toxicology package consisted of general toxicology studies up to 6 months in rat and monkey, which included a safety pharmacology assessment in monkeys; fertility and embryofetal development studies in rat and rabbit; a pre- and postnatal development study in rat; and a juvenile animal toxicology study in rat.”
Carcinogenicity
Species: carcinogenicity
Not conducted (weight-of-evidence; not required)
“Carcinogenicity studies were not required, based on the potential for galcanezumab to counter CGRP associated angiogenesis and immunosuppression, specificity of galcanezumab for CGRP, lack of structural alerts on galcanezumab, and submitted toxicity and clinical studies, which indicated that galcanezumab has a low potential for carcinogenicity.”
Carcinogenicity model
Not conducted: CGRP biology, target specificity, no structural alerts and tox/clinical data indicate low potential
“Carcinogenicity studies were not required, based on the potential for galcanezumab to counter CGRP associated angiogenesis and immunosuppression, specificity of galcanezumab for CGRP, lack of structural alerts on galcanezumab, and submitted toxicity and clinical studies, which indicated that galcanezumab has a low potential for carcinogenicity.”
Carcinogenicity timing
Not required (weight-of-evidence: CGRP biology, specificity, no structural alerts, tox and clinical data)
“Carcinogenicity studies were not required, based on the potential for galcanezumab to counter CGRP associated angiogenesis and immunosuppression, specificity of galcanezumab for CGRP, lack of structural alerts on galcanezumab, and submitted toxicity and clinical studies, which indicated that galcanezumab has a low potential for carcinogenicity.”
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