Nonclinical precedent Request an invite
Flexibility accepted
CarcinogenicityAccepted with a conditionBeyond the letter
No carcinogenicity studies before approval; carcinogenic potential to be assessed post-approval
Why: Life-threatening ALS, negative genotoxicity and no (pre)neoplastic changes in chronic mouse and monkey studies · Serious disease · Weight of evidence
“Due to the severity of the indication, the carcinogenic potential of tofersen is to be conducted post-approval.”
✓ VerifiedFDA integrated review, p. 180Source ↗
“In agreement with the CHMP (EMA/CHMP/SAWP/229464/2019) carcinogenicity studies with tofersen are regarded dispensable with respect to the life-threatening nature of ALS, the negative genotoxic potential and the absence of (pre)neoplastic changes, cell proliferation, and immune or endocrine dysfunction in chronic toxicity studies in mice and NHP’s.”
✓ VerifiedEMA assessment report, p. 33Source ↗
DARTAccepted with a conditionBeyond the letter
DART studies only in mice and rabbits, species in which tofersen is not pharmacologically active
Why: Literature on SOD1 down-regulation suggests low but unknown risk; gap reflected in SmPC sections 4.6 and 5.3 · Weight of evidence · No relevant species
“Considering that tofersen is not pharmacologically active in mice and rabbits, these studies do not provide data regarding the pharmacological activity of tofersen in terms of its potential effects on reproduction or development. This limits the predictive value of these studies in terms of human safety.”
✓ VerifiedEMA assessment report, p. 37Source ↗
“A literature review of the available data on the effects of SOD1 down-regulation indicates that the potential effects of ASO (tofersen) on reproduction and development are likely to be low; however, they are currently unknown. The lack of pharmacologically relevant studies with regard to pregnancy and fertility is now also adequately reflected in sections 4.6 and 5.3 of the SmPC.”
✓ VerifiedEMA assessment report, p. 37Source ↗
Safety marginVerdict not stated
Only 1.2-fold margin at the 9-month monkey NOAEL (12 mg, CSF-volume scaled) to the 100 mg human dose
“The NOAEL from the 9-month NHP toxicology study was determined to be 12 mg, which converts to a HED of 120 mg (based on the monkey-to-human CSF volume scaling) thus providing safety margins of 1.2-fold, based on CSF volumetric scaling (10x), relative to the human dose of 100 mg.”
✓ VerifiedEMA assessment report, p. 32Source ↗

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Flexibility for Qalsody, each with the regulator's own words, the page and a link. Ready to paste into a briefing document or send to your team.

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

Givlaari

givosiran · ALAS1 (siRNA)
2-year rat carcinogenicity study still ongoing at approval; only the 26-week Tg-rasH2 mouse study completed

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

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 →