SpeciesAcceptedBeyond the letter
Ocular toxicity studies in rabbit and dog, species in which the aptamer has very low activity; no monkey ocular study
Why: Monkey has no advantage over rabbit or dog for the ocular studies · Other reason
“The ocular studies were conducted in rabbit and dogs, which, as the Applicant indicated, are species in which ARC1905 is expected to have very low activity.”
✓ VerifiedFDA pharmacology/toxicology review, p. 35Source ↗ “Therefore, the monkey has no advantage over the rabbit or dog, and the reviewer considers that the rabbit and dog are acceptable species.”
✓ VerifiedFDA pharmacology/toxicology review, p. 37Source ↗ CarcinogenicityAcceptedBeyond the letter
No carcinogenicity studies; waiver granted
Why: Mechanism of action, intravitreal route, literature, pharmacological class effects and nonclinical and clinical data · Weight of evidence · Class precedent · Pharmacology or kinetics
“The Applicant justification to omit the conduct of nonclinical carcinogenicity studies is based on avacincaptad pegol mechanism of action, route of administration, a supportive literature review, an analysis of pharmacological class effects, and nonclinical and clinical data collected to date.”
✓ VerifiedFDA pharmacology/toxicology review, p. 69Source ↗ “The Applicant submitted a justification not to conduct carcinogenicity, fertility/early embryonic development, and pre-/postnatal development studies. The Pharmacology/Toxicology team concluded that the weight of evidence supports that the studies are not necessary for the intended dosing regimen and indication.”
✓ VerifiedFDA pharmacology/toxicology review, p. 8Source ↗ DARTAcceptedBeyond the letter
Fertility/early embryonic and pre-/postnatal development studies waived; only rat and rabbit EFD studies conducted
Why: Weight of evidence shows the studies are not necessary for the intended dosing regimen and indication · Weight of evidence
“Nonclinical recommendations for (1) submission for a waiver request for FEED (fertility and early embryonic developmental) and PPND (pre-and postnatal developmental), along with the justification and supporting data, (2) conduct of embryofetal development studies in relevant species”
✓ VerifiedFDA pharmacology/toxicology review, p. 19Source ↗ “The Applicant submitted a justification not to conduct carcinogenicity, fertility/early embryonic development, and pre-/postnatal development studies. The Pharmacology/Toxicology team concluded that the weight of evidence supports that the studies are not necessary for the intended dosing regimen and indication.”
✓ VerifiedFDA pharmacology/toxicology review, p. 8Source ↗ Safety marginVerdict not stated
Ocular NOAEL below the clinical dose: dog 1.0 mg/eye (0.66X the recommended clinical dose)
“The NOAEL is considered to be 1.0 mg/eye (0.66X the recommended clinical dose) even though optic tract vacuolation at 3.0 mg/eye was not associated with any adverse histopathology or significant ERG findings.”
✓ VerifiedFDA pharmacology/toxicology review, p. 7Source ↗