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Givlaari: what flexibility did regulators accept, and why?

givosiran · ALAS1 (siRNA)
Flexibility accepted
CarcinogenicityVerdict not stated
2-year rat carcinogenicity study still ongoing at approval; only the 26-week Tg-rasH2 mouse study completed
“There was no evidence of carcinogenicity in the 26-week conducted in f Tg-rasH2 mice. A longer, 2-year carcinogenicity study in Sprague Dawley rats (AS1-GLP18-007), currently ongoing, will be submitted upon its completion.”
✓ VerifiedEMA assessment report, p. 47Source ↗
Juvenile toxAcceptedBeyond the letter
No dedicated juvenile animal studies; young monkeys (13 to 17 months old) in the 39-week study used to support adolescents
Why: Monkeys aged 13 to 17 months at study start cover the developmental age of adolescents 12 years and older · Weight of evidence
“Dedicated studies were not conducted in juvenile animals. In the chronic monkey GLP toxicology study, givosiran was administered once weekly at dose levels between 10 and 100 mg/kg for 39 weeks, followed by a 13-week recovery phase.”
✓ VerifiedEMA assessment report, p. 47Source ↗
“At initiation of the treatment, monkeys were 13 to 17 months old. Monkeys at 24 to 36 months old are generally considered the corresponding development age of adolescent up to 12 years of age in human.”
✓ VerifiedEMA assessment report, p. 47Source ↗
OtherVerdict not stated
Repeat-dose toxicity studies dosed once weekly rather than the once-monthly clinical schedule
“The studies were conducted using the subcutaneous route of administration, which is consistent with the intended clinical route of administration; however, animals were dosed once weekly instead of the once monthly dose schedule used to treat patients.”
✓ VerifiedFDA multi-discipline review, p. 27Source ↗
SpeciesVerdict not stated
Rabbit embryo-fetal study conducted in a pharmacologically inactive species (no hepatic ALAS1 knockdown)
“Pharmacodynamics measurement on GD 22 indicated that givosiran did not reduce hepatic ALAS1 transcript levels in pregnant rabbits at any dose level, confirming that givosiran is not pharmacologically active in rabbits.”
✓ VerifiedFDA multi-discipline review, p. 28Source ↗

Same question, other oligonucleotides

Amondys 45

casimersen · DMD exon 45 (PMO)
No reproductive and developmental toxicity studies; male reproductive organs and sperm evaluated in chronic studies instead

Amvuttra

vutrisiran · TTR (siRNA)
No carcinogenicity studies at approval; rat and mouse studies deferred to postmarketing requirements

Dawnzera

donidalorsen · Prekallikrein / KLKB1 (ASO)
No rabbit embryo-fetal study with donidalorsen; DART in mice only, rabbit data leveraged from the unconjugated analogue ISIS 546254

Defitelio

defibrotide · Fragmented DNA oligonucleotides
Fertility and pre/postnatal studies only from 1970s non-GLP intramuscular rat studies; not fully reviewed

Exondys 51

eteplirsen · DMD exon 51 (PMO)
No carcinogenicity studies before approval; transgenic mouse and rat studies deferred to postmarketing requirements

Hibsago

bepirovirsen · HBV RNA (ASO)
No exposure margin in mouse fertility study: no adverse effects up to 0.7 times the MRHD (BSA)

Izervay

avacincaptad pegol · C5 (aptamer)
Ocular toxicity studies in rabbit and dog, species in which the aptamer has very low activity; no monkey ocular study

Kynamro

mipomersen · APOB (ASO)
Mipomersen inactive in rodents and only partly active in monkey; pivotal rodent studies added a species-specific surrogate arm

Leqvio

inclisiran · PCSK9 (siRNA)
No juvenile toxicology study

Macugen

pegaptanib · VEGF-165 (aptamer)
No carcinogenicity studies for a chronic intravitreal therapy

Onpattro

patisiran · TTR (siRNA)
No 2-year rat carcinogenicity study; 26-week TgRasH2 mouse study only

Oxlumo

lumasiran · HAO1 (siRNA)
Rat 2-year and transgenic mouse 6-month carcinogenicity studies incomplete at approval; deferred to postmarketing requirements

Qalsody

tofersen · SOD1 (ASO)
No carcinogenicity studies before approval; carcinogenic potential to be assessed post-approval

Qfitlia

fitusiran · Antithrombin / SERPINC1 (siRNA)
No reproduction studies in female animals (no embryo-fetal or pre/postnatal studies); male fertility assessed within 26-week rat study

Redemplo

plozasiran · APOC3 (siRNA)
2-year rat carcinogenicity study ongoing at approval; completion to be submitted postmarketing

Rivfloza

nedosiran · LDHA (siRNA)
No carcinogenicity assessment before approval; studies deferred to postmarketing

Rytelo

imetelstat · Telomerase (oligo)
No carcinogenicity studies before approval; ICH S9 waiver claim not accepted by FDA; mouse and rat studies required postmarketing

Spinraza

nusinersen · SMN2 (ASO)
No chronic rodent toxicity study to assess systemic exposure

Tegsedi

inotersen · TTR (ASO)
2-year rat carcinogenicity study not submitted before approval; required post-marketing

Tryngolza

olezarsen · APOC3 (ASO)
No carcinogenicity studies with olezarsen; lifetime mouse and rat studies of unconjugated same-sequence ASO volanesorsen relied on

Viltepso

viltolarsen · DMD exon 53 (PMO)
No carcinogenicity studies before approval; Tg.rasH2 mouse and two-year rat studies required as postmarketing requirements

Vitravene

fomivirsen · CMV IE2 mRNA (ASO)
No carcinogenicity studies; waiver requested citing lack of meaningful systemic exposure

Vyondys 53

golodirsen · DMD exon 53 (PMO)
No carcinogenicity studies before approval; 26-week transgenic mouse and 2-year rat studies deferred post-approval

Wainua

eplontersen · TTR (ASO)
Carcinogenic potential not assessed at FDA approval; 26-week Tg.rasH2 mouse study made a postmarketing requirement

Waylivra

volanesorsen · APOC3 (ASO)
Mouse and rat carcinogenicity studies of limited value: high toxicity-related mortality and early termination of study groups

Zanvastro

zilganersen · GFAP (ASO)
No carcinogenicity studies before approval; completion required as postmarketing requirements

Summary across all 27 oligonucleotides →