CarcinogenicityAccepted
No carcinogenicity studies for a chronic prophylactic antibody; written carcinogenicity assessment used instead
Why: No pharmacologically relevant rodent species; sponsor's carcinogenicity assessment judged sufficient, with ECAC concurrence · No relevant species · Within the guideline · Weight of evidence
“Carcinogenicity studies were not conducted due to lack of a pharmacologically relevant rodent species.”
✓ VerifiedFDA multi-discipline review, p. 42Source ↗ “The Sponsor subsequently submitted the requested carcinogenicity assessment to the IND on July 9, 2015, and upon our review the Division agreed that the carcinogenicity assessment was sufficient to waive the requirement for additional nonclinical carcinogenicity studies.”
✓ VerifiedFDA multi-discipline review, p. 155Source ↗ DARTVerdict not stated
No reproductive or developmental toxicity studies (fertility, embryo-fetal, pre/postnatal)
Why: Hemophilia A is X-linked recessive; 99% of patients are male, so use in females exceedingly rare · Other reason
“Animal reproductive and developmental toxicology studies were not conducted with emicizumab as hemophilia A is inherited in an X-linked recessive manner. Males represent 99% of the patients with hemophilia A, thus it would be exceedingly rare for females to be prescribed this drug.”
✓ VerifiedFDA multi-discipline review, p. 42Source ↗ Efficacy modelCriticised but acceptedBeyond the letter
Monkey acquired hemophilia A efficacy models poorly characterised at initial application
Why: Adequate justification of the parameters measured was subsequently provided · Other reason
“While the results are supportive of the proposed use, at the time of initial application, the models were poorly characterised. However, adequate justification of the choice of parameters measured was subsequently provided.”
✓ VerifiedEMA assessment report, p. 36Source ↗