DARTAcceptedBeyond the letter
Rat DART used Matrix-M1 below the absolute human dose (maximum volume of clinical formulation)
Why: Dose exceeds the human dose 40-fold on a weight-adjusted basis and induced an immune response in rats · Pharmacology or kinetics
“The administered dose was the maximum volume of clinical formulation (used for the early clinical studies) and, although the dose is smaller than the absolute dose that will be administered to humans, it does exceed the human dosage on a weight-adjusted basis by 40-fold.”
✓ VerifiedEMA assessment report, p. 54Source ↗ “In addition, the final audited DART report includes data showing that the dose used in this study did induce an immune response. The study design and generated results are therefore considered acceptable.”
✓ VerifiedEMA assessment report, p. 54Source ↗ OtherVerdict not stated
Rabbit repeat-dose study used antigen/adjuvant 50/50 µg instead of the clinical 5/50 µg ratio
“Of note, the dosing schedule used was not in accordance with the proposed clinical schedule (the dose ratio of SARS-CoV-2 rS nanoparticle/Matrix-M1 used is different: 50/50 in the study vs 5/50 in the clinical situation).”
✓ VerifiedEMA assessment report, p. 51Source ↗ DARTAcceptedBeyond the letter
DART done in rat although rabbit placental antibody transfer is more similar to humans
Why: Fetal titers about 8.0% and pup titers 70-82% of maternal levels showed sufficient antibody transfer · Pharmacology or kinetics
“For the evaluation of reproduction toxicology, the applicant has used the rat as animal model. It is noted that placental transfer of antibodies in rabbits is more similar to humans compared to rodents.”
✓ VerifiedEMA assessment report, p. 54Source ↗ “Titers measured in foetuses were approximately 8.0% of those present in dams, whereas nursing pups had anti-S lgG levels approximately 70-82 % of the IgG levels of the dams, indicating that sufficient antibody transfer occurred via placenta and especially lactation.”
✓ VerifiedEMA assessment report, p. 54Source ↗ DARTVerdict not stated
No male fertility study
Why: No adverse findings in male reproductive organs in the GLP repeat-dose study · Weight of evidence
“No male fertility studies were performed given no adverse observations in male reproductive organs were observed in the GLP repeat-dose toxicology study.”
✓ VerifiedEMA assessment report, p. 52Source ↗ BiodistributionAcceptedBeyond the letter
Matrix-M1 adjuvant biodistribution study not completed before approval
Why: Extensive clinical package at initial marketing approval · Human data
“Considering the extensive clinical package available at the time of initial marketing approval, the safety profile of the adjuvanted vaccine was considered acceptable without finalisation of the biodistribution study.”
✓ VerifiedEMA assessment report, p. 53Source ↗