Safety marginAcceptedBeyond the letter
26-week rat NOAEL exposure below human AUC at the MRHD (~0.1x males, ~0.8x females)
Why: Dose-limiting body weight reductions would be monitorable in humans; no unmonitorable toxicities below those doses · Other reason
“At the NOAEL, male AUC is lower than (~0.1x), and female AUC is approximately equal to (~0.8x), human AUC at the MRHD.”
✓ VerifiedFDA multi-discipline review, p. 42Source ↗ “The reductions in body weight were dose-limiting in animals and would be monitorable in humans. There were no unmonitorable toxicities observed at doses below those with adverse effects on body weight.”
✓ VerifiedFDA multi-discipline review, p. 35Source ↗ Safety marginVerdict not stated
Rat embryofetal NOAEL for maternal toxicity and fetal development below human exposure at the MRHD
“The No Observed Adverse Effect Level (NOAEL) for both maternal toxicity and fetal development was 10 mg/kg/day, which is below the human exposure at the MRHD based on AUC.”
✓ VerifiedFDA multi-discipline review, p. 35Source ↗ Impurity or metaboliteAcceptedBeyond the letter
Enantiomer impurity EB-1070 specified above the ICH Q3A(R2) qualification threshold
Why: Qualified by the submitted toxicology data · Weight of evidence
“The Applicant’s drug specification proposed a limit for the enantiomer impurity (EB-1070) which was above the qualification threshold recommended in the ICH Q3A(R2)1 guidance. Based on the toxicology data submitted by the Applicant, the proposed limit for the EB-1070 impurity is considered qualified.”
✓ VerifiedFDA multi-discipline review, p. 36Source ↗