Nonclinical precedent Request an invite

Qalsody: what was done before first-in-human, and what came after?

tofersen · SOD1 (ASO)

Before first-in-human

First-in-human: where
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
Repeat-dose tox before first-in-human
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
First-in-human starting dose
Not stated in public reviews
Why it's blank

The public FDA and EMA reviews of Qalsody don't say how the first human dose was chosen. That rationale is in the IND, which is confidential, so it is missing for most approved products.

How it's usually set for oligonucleotides outside oncology

Find the highest dose with no adverse effects (NOAEL) in each animal species, convert it to a human equivalent dose, usually by body surface area, pick the most appropriate species, then divide by a safety factor (default 10) to get the maximum recommended starting dose.

“In general, one should consider using a safety factor of at least 10. The MRSD should be obtained by dividing the HED by the safety factor.”
✓ VerifiedFDA 2005: Estimating the Maximum Safe Starting Dose in Initial Clinical…, p. 7Source ↗
This product's starting point

NOAEL / key findings: Monkey 9-month IT NOAEL 12 mg Q2W (neurological signs at 35 mg); ~1.2-fold margin by CSF-volume scaling; mouse platelet decreases, no NOAEL (FDA integrated review, p. 180)

Full method, every step sourced →

Longest repeat-dose systemic studies

Longest repeat-dose study and recovery
9-month (39-week) cynomolgus monkey (intrathecal, every other week) with recovery groups; recovery duration not stated
“In monkeys, IT administration of 0, 4, 12, and 35 mg tofersen in male and female cynomolgus monkeys every other week for 9 months resulted in histologic findings of neuronal vacuolation at all doses; however, vacuolation was not accompanied by neurodegeneration and was not present in recovery groups.”
✓ VerifiedFDA integrated review, p. 84Source ↗
Pivotal GLP studies
Monkey IT Q2W 13-week and 9-month; mouse SC 12- and 26-week; rat single-dose IT; full genetox and DART
“Nonclinical toxicity studies submitted to the NDA consisted of single dose (rat) and repeat dose (mouse and monkey) general toxicity studies, as well a complete battery of genetic toxicology and reproductive and developmental toxicology studies.”
✓ VerifiedFDA integrated review, p. 84Source ↗

DART package

Species: DART
Mouse (combined fertility/EFD and pre/postnatal) and rabbit (EFD)
“The reproductive and developmental toxicity of tofersen was investigated in a combined study on fertility and embryo-foetal development in mice, a study on embryo-foetal development in rabbits, and on pre￾postnatal development in mice.”
✓ VerifiedEMA assessment report, p. 33Source ↗
Reproductive & developmental
Mouse fertility (seminiferous tubule degeneration, NOAEL 10 mg/kg), mouse/rabbit EFD and mouse PPND negative; pharmacologically non-relevant species
“There were no effects on embryofetal development in CD1 mouse or NZW rabbit, or on pre- and postnatal development in CD1 mouse.”
✓ VerifiedFDA integrated review, p. 84Source ↗
PPND / ePPND: when
PPND in CD1 mouse completed before the marketing application; no effects on pre- and postnatal development
“There were no effects on embryofetal development in CD1 mouse or NZW rabbit, or on pre- and postnatal development in CD1 mouse.”
✓ VerifiedFDA integrated review, p. 84Source ↗

Carcinogenicity

Species: carcinogenicity
Not conducted pre-approval (severity of indication); to be assessed post-approval
“Due to the severity of the indication, the carcinogenic potential of tofersen is to be conducted post-approval.”
✓ VerifiedFDA integrated review, p. 180Source ↗
Carcinogenicity model
Not conducted (severity of indication); to be assessed post-approval
“Due to the severity of the indication, the carcinogenic potential of tofersen is to be conducted post-approval.”
✓ VerifiedFDA integrated review, p. 180Source ↗
Carcinogenicity timing
Not conducted before approval; carcinogenicity studies to be conducted after approval given the severity of the indication
“Due to the severity of the indication, the carcinogenic potential of tofersen is to be conducted post-approval.”
✓ VerifiedFDA integrated review, p. 180Source ↗

Email me this as a cited memo

Tox package 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

Dawnzera

donidalorsen · Prekallikrein / KLKB1 (ASO)
Canada: first-in-human study in healthy volunteers

Givlaari

givosiran · ALAS1 (siRNA)
US, UK and Sweden: 6 clinical study centers (4 US, 1 UK, 1 Sweden)

Oxlumo

lumasiran · HAO1 (siRNA)
UK: single ascending dose in healthy subjects (Study 001 Part A)

Zanvastro

zilganersen · GFAP (ASO)
United States and other countries: ION373-CS1, the single combined first clinical and pivotal trial in AxD patients

Amondys 45

casimersen · DMD exon 45 (PMO)
Not stated in public reviews

Amvuttra

vutrisiran · TTR (siRNA)
Not stated in public reviews

Defitelio

defibrotide · Fragmented DNA oligonucleotides
Not stated in public reviews

Exondys 51

eteplirsen · DMD exon 51 (PMO)
Not stated in public reviews

Hibsago

bepirovirsen · HBV RNA (ASO)
Not stated in public reviews

Izervay

avacincaptad pegol · C5 (aptamer)
Not stated in public reviews

Kynamro

mipomersen · APOB (ASO)
Not stated in public reviews

Leqvio

inclisiran · PCSK9 (siRNA)
Not stated in public reviews

Macugen

pegaptanib · VEGF-165 (aptamer)
Not stated in public reviews

Onpattro

patisiran · TTR (siRNA)
Not stated in public reviews

Qfitlia

fitusiran · Antithrombin / SERPINC1 (siRNA)
Not stated in public reviews

Redemplo

plozasiran · APOC3 (siRNA)
Not stated in public reviews

Rivfloza

nedosiran · LDHA (siRNA)
Not stated in public reviews

Rytelo

imetelstat · Telomerase (oligo)
Not stated in public reviews

Spinraza

nusinersen · SMN2 (ASO)
Not stated in public reviews

Tegsedi

inotersen · TTR (ASO)
Not stated in public reviews

Tryngolza

olezarsen · APOC3 (ASO)
Not stated in public reviews

Viltepso

viltolarsen · DMD exon 53 (PMO)
Not stated in public reviews

Vitravene

fomivirsen · CMV IE2 mRNA (ASO)
Not stated in public reviews

Vyondys 53

golodirsen · DMD exon 53 (PMO)
Not stated in public reviews

Wainua

eplontersen · TTR (ASO)
Not stated in public reviews

Waylivra

volanesorsen · APOC3 (ASO)
Not stated in public reviews

Summary across all 27 oligonucleotides →