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 ↗