CarcinogenicityAccepted with a conditionBeyond the letter
2-year rat carcinogenicity study not submitted before approval; required post-marketing
“A 2-year carcinogenicity study in rat has not been submitted. A study protocol was submitted on October 27, 2015, for Special Protocol Assessment and was reviewed by the division and the Executive CAC committee (Minutes dated December 2, 2015).”
✓ VerifiedFDA pharmacology/toxicology review, p. 9Source ↗ “The nonclinical data submitted for inotersen are adequate to support approval of the NDA, with a PMR for a 2-year carcinogenicity study in rat.”
✓ VerifiedFDA pharmacology/toxicology review, p. 9Source ↗ Safety marginVerdict not stated
NOAEL AUC margins for severe thrombocytopenia (monkey) and kidney toxicity (rat) about 2-fold or less
“Safety margins based on AUCs at the no observed adverse effect levels (NOAELs) for severe thrombocytopenia in monkeys and kidney toxicity in rats were ≤ ~2-fold.”
✓ VerifiedFDA pharmacology/toxicology review, p. 15Source ↗