Sarclisa
isatuximab
Species
Monkey
Longest study
3 wk
Genotox
Not conducted Not conducted
Carcinogenicity
Not conducted Not conducted
Repro
Conducted Conducted
First dose
Conducted Stated
Speciesopen answer page →
Species
Cynomolgus monkey only (non-binding species, off-target toxicity assessment)
“The antibody does not bind to its target in animal species typically used in toxicology studies; however, a repeat-dose toxicology study in monkeys was conducted to investigate the potential off-target effects of isatuximab.”
Why that species
Binds only human and chimpanzee CD38; no binding to mouse, rat, rabbit, pig, cynomolgus or rhesus CD38; no pharmacologically relevant species
“The antibody bound to human and chimpanzee CD38, but did not bind to CD38 from the mouse, rat, rabbit, pig, or cynomolgus and rhesus monkey.”
Surrogate molecule
No surrogate; the clinical antibody was tested in cynomolgus monkey; monkey-reactive surrogates were evaluated but differed in tissue cross-reactivity
“The pattern of tissue cross-reactivity of both ch38SB25 and chOKT10 surrogates in monkey tissues was significantly different from the pattern of tissue-cross-reactivity observed with isatuximab in human tissues”
Species: general tox
Cynomolgus monkey (non-binding species; off-target toxicity study only)
“The antibody does not bind to its target in animal species typically used in toxicology studies; however, a repeat-dose toxicology study in monkeys was conducted to investigate the potential off-target effects of isatuximab.”
Species: DART
Not conducted (no pharmacologically relevant species); weight of evidence from CD38 literature
“Due to the lack of an appropriate pharmacologically relevant animal species for a study assessing the effects of isatuximab on embryo-fetal development, the evaluation of the reproductive and developmental toxicity of isatuximab is based on a weight of evidence (WOE) approach using literature on the involvement of CD38 in reproduction and development.”
Species: carcinogenicity
Not conducted
“No carcinogenicity studies were performed with isatuximab.”
Surrogate used in
No surrogate used; monkey-reactive surrogates ch38SB25 and chOKT10 evaluated but tissue cross-reactivity differed from isatuximab
“The pattern of tissue cross-reactivity of both ch38SB25 and chOKT10 surrogates in monkey tissues was significantly different from the pattern of tissue-cross-reactivity observed with isatuximab in human tissues”
Study lengthopen answer page →
Longest pivotal study
3 weeks
“Because an appropriate species for preclinical safety testing could not be identified, toxicology studies with isatuximab were limited to a repeat-dose (once weekly for 3 weeks) toxicity study in cynomolgus monkeys (preceded by a small exploratory study)”
Pivotal GLP studies
GLP 3-week cynomolgus monkey IV study, 20, 50 or 100 mg/kg/week, once weekly
“The weekly repeated intravenous administration of isatuximab for 3 weeks to cynomolgus monkeys at doses of 20, 50 or 100 mg/kg/week resulted in no isatuximab-related findings in any parameters and in any groups.”
Route in tox
IV
“Study title/ Study number: SAR650984 - Repeat-dose (once weekly for 3 weeks) intravenous (0.5-hour infusion) toxicity study in cynomolgus monkeys / TSK0154”
Skipped studiesopen answer page →
Genotoxicity
Not conducted (ICH S6)
“The FDA concurs with the Applicant that genotoxicity studies are not warranted per ICH guidance S6.”
Carcinogenicity
Not conducted; not warranted for the indication
“No fertility and early embryonic development, or carcinogenicity studies have been conducted or are warranted based on the proposed indication.”
Reproductive & developmental
No studies; weight of evidence from CD38 knockout models: fetal CD38+ immune cell depletion and reduced bone density
“Effects observed in target antigen CD38 knockout animal models include the depletion of fetal CD38 positive immune cells and a decrease in bone density.”
Safety pharmacology
Incorporated into repeat-dose monkey study; no effects on ECG, blood pressure, behavior or respiration up to 100 mg/kg/week
“No isatuximab-related effects were noted in this study on ECG parameters, blood pressure, gross behavior profile (including body temperature), and respiratory function up to the highest dose tested of 100 mg/kg/ week.”
Genotox: Ames
Not conducted (ICH S6)
“The FDA concurs with the Applicant that genotoxicity studies are not warranted per ICH guidance S6.”
Genotox: in vitro mammalian
Not conducted (ICH S6)
“The FDA concurs with the Applicant that genotoxicity studies are not warranted per ICH guidance S6.”
Genotox: in vivo
Not conducted (ICH S6)
“The FDA concurs with the Applicant that genotoxicity studies are not warranted per ICH guidance S6.”
Carcinogenicity model
Not conducted (ICH S6, ICH S9)
“In line with relevant guidelines no genotoxicity, carcinogenicity and reproductive toxicity studies were conducted (ref. ICH S6, ICH S9; SmPC section 5.3).”
Carcinogenicity timing
Not warranted for the proposed (oncology) indication
“No fertility and early embryonic development, or carcinogenicity studies have been conducted or are warranted based on the proposed indication.”
hERG / QT
No ECG, blood pressure or respiratory effects up to 100 mg/kg/week in monkeys (no hERG assay)
“No isatuximab-related effects were noted in this study on ECG parameters, blood pressure, gross behavior profile (including body temperature), and respiratory function up to the highest dose tested of 100 mg/kg/ week.”
First doseopen answer page →
First-in-human starting dose
MABEL and in vitro receptor occupancy: 0.0001 mg/kg, about 10% predicted CD38 occupancy in B and T cells
“Based on the overall data, the recommended starting human dose for the first-in-human study was 0.0001 mg/kg, which is approximately 10% of the predicted CD38 receptor occupancy measured in normal human B and T cells.”
NOAEL / key findings
Monkey NOAEL 100 mg/kg/week, highest dose; no isatuximab-related findings
“Therefore, under these study conditions, the dose of 100 mg/kg/week was considered to be the no-observed adverse effect level (NOAEL)”
Risksopen answer page →
Immune & cytokine safety
No significant cytokine release from human PBMCs or WBCs in vitro
“In contrast, no significant release of cytokines was observed after isatuximab incubation under any of the various assays and conditions used and for any of the donors tested.”
Biodistribution & persistence
Human TCR: lymphoid tissues and bone marrow, plus pituitary endothelium and prostate epithelium
“The TCR test indicated that isatuximab-specific binding was mainly in the lymphoid tissues (spleen, thymus, lymph node and tonsil) and in the bone marrow; binding was also detected in the pituitary gland (endothelial cells) and prostate gland (glandular epithelial cells).”
Modality-specific risk
No relevant tox species; safety assessment relies on mechanism of action and clinical findings
“The safety assessment of isatuximab for general toxicity is mainly based on the mechanism of action (MOA) and findings in patients.”
Anti-drug antibodies: animals
No ADA with the clinical batch; 4 of 6 monkeys given an expired batch ADA positive (titers 160-320)
“All samples collected from animals treated with batch C1053598 (20, 50 and 100 mg/kg/week) were found to be ADA negative, while the majority of the samples from animals (4 out of 6) that received the batch VAB-LCX1-000004, which was beyond its current shelf-life, were ADA positive, with titers ranging from 160 to 320.”
Anti-drug antibodies: patients
Treatment-emergent ADA 2.3% (N=564); persistent ADA 0.35%; neutralizing status not determined
“In antidrug-antibody (ADA) evaluable patients from all completed studies (N=564), the incidence of treatment emergent ADAs was low (2.3%), with 2 patients having a persistent treatment induced ADA (0.35%). However, since no confirmed positive ADA samples were detected in the pivotal Phase 3 study, the neutralizing ADA status was not determined.”
Label warnings
- Hypersensitivity and Other Administration Reactions
- Neutropenia
- Infections
- Second Primary Malignancies
- Laboratory Test Interference
- Embryo-Fetal Toxicity
Hypersensitivity & infusion reactionsCytopeniasInfectionsSecondary malignancyEmbryo-fetal toxicity
US prescribing information, Warnings and PrecautionsDailyMed ↗
Tox packageopen answer page →
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
MABEL and in vitro receptor occupancy: 0.0001 mg/kg, about 10% predicted CD38 occupancy in B and T cells
“Based on the overall data, the recommended starting human dose for the first-in-human study was 0.0001 mg/kg, which is approximately 10% of the predicted CD38 receptor occupancy measured in normal human B and T cells.”
Longest repeat-dose systemic studies
Longest repeat-dose study and recovery
3-week (once weekly IV) GLP cynomolgus monkey study; recovery phase not stated
“toxicology studies with isatuximab were limited to a repeat-dose (once weekly for 3 weeks) toxicity study in cynomolgus monkeys (preceded by a small exploratory study)”
Pivotal GLP studies
GLP 3-week cynomolgus monkey IV study, 20, 50 or 100 mg/kg/week, once weekly
“The weekly repeated intravenous administration of isatuximab for 3 weeks to cynomolgus monkeys at doses of 20, 50 or 100 mg/kg/week resulted in no isatuximab-related findings in any parameters and in any groups.”
DART package
Species: DART
Not conducted (no pharmacologically relevant species); weight of evidence from CD38 literature
“Due to the lack of an appropriate pharmacologically relevant animal species for a study assessing the effects of isatuximab on embryo-fetal development, the evaluation of the reproductive and developmental toxicity of isatuximab is based on a weight of evidence (WOE) approach using literature on the involvement of CD38 in reproduction and development.”
Reproductive & developmental
No studies; weight of evidence from CD38 knockout models: fetal CD38+ immune cell depletion and reduced bone density
“Effects observed in target antigen CD38 knockout animal models include the depletion of fetal CD38 positive immune cells and a decrease in bone density.”
PPND / ePPND: when
No PPND study conducted; FDA concurred under ICH S9 (oncology)
“Prenatal and Postnatal Development The Applicant's Position: No study or assessment conducted. The FDA's Assessment: FDA concurs based on the ICH S9 guidance.”
Carcinogenicity
Species: carcinogenicity
Not conducted
“No carcinogenicity studies were performed with isatuximab.”
Carcinogenicity model
Not conducted (ICH S6, ICH S9)
“In line with relevant guidelines no genotoxicity, carcinogenicity and reproductive toxicity studies were conducted (ref. ICH S6, ICH S9; SmPC section 5.3).”
Carcinogenicity timing
Not warranted for the proposed (oncology) indication
“No fertility and early embryonic development, or carcinogenicity studies have been conducted or are warranted based on the proposed indication.”
Safety marginopen answer page →
Safety margin at NOAEL
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.
NOAEL / key findings
Monkey NOAEL 100 mg/kg/week, highest dose; no isatuximab-related findings
“Therefore, under these study conditions, the dose of 100 mg/kg/week was considered to be the no-observed adverse effect level (NOAEL)”
Efficacy evidenceopen answer page →
Efficacy evidence
SU-DHL-8 non-Hodgkin lymphoma xenograft in SCID mice (in vivo proof of concept)
“A xenograft model with a Non-Hodgkin Lymphoma (NHL) cell line in severe combined immunodeficient (SCID) mice (SU DHL-8 tumours; study IMP23018) was used to provide in vivo POC for isatuximab.”
Why that model
Human CD38-expressing tumour xenograft in SCID mice considered the most relevant efficacy model
“From the pharmacokinetic point of view, the SCID mice with a xenograft consisting of cells from a CD38 expressing cancer cell line was the most relevant species for non-clinical efficacy testing.”
Reviewer's view of the efficacy data
EMA: xenograft gives evidence of anti-CD38 anti-tumour effect despite limitations (NHL not MM line, not systemic, lacks T/B cells)
“Notwithstanding the limitations of the model: whether the use of an NHL cell line is representative for the proposed indication (MM), the model not fully simulating a systemic tumour, the extent of mediated cytotoxicity as this model lacks T and B cells, this study provides evidence for the anti-tumour effect of isatuximab towards CD38.”
Flexibilityopen answer page →
Flexibility accepted
SpeciesAccepted
No pharmacologically relevant toxicology species (only chimpanzee binds); monkey toxicity study in a non-relevant species
Why: Only chimpanzee binds CD38, not appropriate for toxicity studies; no adequate transgenic mouse model available · No relevant species · Within the guideline
“The used species for toxicity testing, cynomolgous monkey, was not regarded a pharmacological relevant species as the antibody does not recognise the target in this species.”
“The FDA concurs with the conclusion that no pharmacologically relevant animal species is available for the safety assessment (e.g., in vivo safety pharmacology or toxicology studies) of isatuximab.”
DARTAccepted
No reproductive toxicity studies; literature weight-of-evidence on CD38 in reproduction and development instead
Why: No pharmacologically relevant species for an embryo-fetal study · No relevant species · Weight of evidence · Within the guideline
“The FDA's Assessment: Due to the lack of an appropriate pharmacologically relevant animal species, the evaluation of embryofetal development of isatuximab is based on a weight of evidence (WOE) assessment in lieu of conducting studies in animals.”
Efficacy modelCriticised but acceptedBeyond the letter
In vivo proof of concept only in a subcutaneous non-Hodgkin lymphoma xenograft, not a myeloma model
Why: Model still provides evidence of anti-tumour effect towards CD38 · Pharmacology or kinetics
“Notwithstanding the limitations of the model: whether the use of an NHL cell line is representative for the proposed indication (MM), the model not fully simulating a systemic tumour, the extent of mediated cytotoxicity as this model lacks T and B cells, this study provides evidence for the anti-tumour effect of isatuximab towards CD38.”
Similar precedents
DarzalexAntibodies · daratumumab · CD38Monkey only · 6 wkBavencioAntibodies · avelumab · PD-L1Monkey only · 13 wkCyramzaAntibodies · ramucirumab · VEGFR2Monkey only · 39 wkHerceptinAntibodies · trastuzumab · HER2Monkey only · 26 wkImfinziAntibodies · durvalumab · PD-L1Monkey only · 13 wkImjudoAntibodies · tremelimumab · CTLA-4Monkey only · 26 wk