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

imetelstat · Telomerase (oligo)

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 Rytelo 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 oncology oligonucleotides (ICH S9)

HNSTD/STD10 is the method used for anticancer drugs in patients: the start dose is one-sixth of the highest non-severely toxic dose (HNSTD) in non-rodents, or one-tenth of the dose severely toxic to 10% of rodents (STD10), scaled by body surface area. The aim is a dose that is pharmacologically active yet reasonably safe.

“A common approach for many small molecules is to set a start dose at 1/10 the Severely Toxic Dose in 10% of the animals (STD 10) in rodents. If the non-rodent is the most appropriate species, then 1/6 the Highest Non-Severely Toxic Dose (HNSTD) is considered an appropriate starting dose.”
✓ VerifiedICH 2009: ICH S9: Nonclinical Evaluation for Anticancer Pharmaceuticals, p. 13Source ↗
This product's starting point

NOAEL / key findings: Mouse NOAEL 20 mg/kg; monkey HNSTD 15 mg/kg/week; cytopenias, complement activation, aPTT prolongation, liver/kidney (EMA assessment report, p. 32)

Full method, every step sourced →

Longest repeat-dose systemic studies

Longest repeat-dose study and recovery
9-month (39-week) cynomolgus monkey (IV infusion, weekly) with 14-week recovery
“002-TOX-2008 was a 9-month toxicity study of GRN163L in Cynomolgus Monkeys followed by a 14- week recovery period.”
✓ VerifiedEMA assessment report, p. 31Source ↗
Pivotal GLP studies
GLP IV: 6-month mouse (bolus BIW) and 9-month cynomolgus monkey (2-h infusion weekly); mouse and rabbit EFD
“Additional imetelstat toxicities observed in the chronic pivotal toxicity studies, ie, the 6-month study in mice (003-TOX-2008) and the 9-month study in monkeys, included microscopic findings in the liver and kidney”
✓ VerifiedFDA multi-discipline review, p. 56Source ↗

DART package

Species: DART
Mouse and rabbit (EFD)
“The mouse and monkey were used for the single- and repeat-dose toxicity studies, and mouse and rabbit were used for the EFD toxicity studies.”
✓ VerifiedFDA multi-discipline review, p. 56Source ↗
Reproductive & developmental
EFD in mice and rabbits: post-implantation loss/resorptions; no fertility or PPND studies
“Increased rates of post-implantation loss and early resorptions that resulted in a decreased number of viable fetuses and litter size per animal, and decreased uterine weight were observed at”
✓ VerifiedFDA multi-discipline review, p. 42Source ↗
PPND / ePPND: when
No PPND study: considered acceptable for an indication mainly in older people and negligible oral bioavailability
“No PPND study has been submitted. This was considered acceptable based on the proposed indication which is primarily relevant for older people and that imetelstat has little or no oral bioavailability thereby removing the likelihood of postnatal exposure via lactation.”
✓ VerifiedEMA assessment report, p. 39Source ↗

Carcinogenicity

Species: carcinogenicity
Not conducted; mouse and rat carcinogenicity studies required as PMRs
“To address the carcinogenicity risk assessment of imetelstat, there will be separate Post Marketing Requirements (PMRs) for carcinogenicity assessments in the mouse and rat species.”
✓ VerifiedFDA multi-discipline review, p. 43Source ↗
Carcinogenicity model
Not conducted pre-approval; mouse and rat studies to follow as PMRs
“To address the carcinogenicity risk assessment of imetelstat, there will be separate Post Marketing Requirements (PMRs) for carcinogenicity assessments in the mouse and rat species.”
✓ VerifiedFDA multi-discipline review, p. 43Source ↗
Carcinogenicity timing
Not conducted before approval; mouse and rat carcinogenicity studies are postmarketing requirements
“To address the carcinogenicity risk assessment of imetelstat, there will be separate Post Marketing Requirements (PMRs) for carcinogenicity assessments in the mouse and rat species.”
✓ VerifiedFDA multi-discipline review, p. 43Source ↗

Email me this as a cited memo

Tox package for Rytelo, 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

Qalsody

tofersen · SOD1 (ASO)
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

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 →