Safety marginAcceptedBeyond the letter
No exposure margin: NOAEL exposures in all species below human exposure at 600 mg QD
Why: Toxicity reflects polycythemia in healthy animals; in anemic patients erythropoiesis is the treatment intent and a monitoring endpoint · Pharmacology or kinetics
“Exposure in animals at the ‘no observed adverse effect level’ (NOAEL) were all below human exposure at the clinical dose of 600 mg QD (Table 63). Key to interpreting the toxicology data is to understand that the nonclinical toxicology studies were conducted in healthy and non-anemic animals, in which vadadustat produces polycythemia.”
✓ VerifiedFDA integrated review, p. 270Source ↗ “However, a similar exposure-response to vadadustat would not necessarily occur in patients with anemia for whom increased erythropoiesis is the intent of treatment, and for which the degree of induced erythropoiesis is a primary efficacy and safety monitoring endpoint.”
✓ VerifiedFDA integrated review, p. 270Source ↗ CarcinogenicityVerdict not stated
Rat carcinogenicity study scheduled for 104 weeks terminated early (week 85/86 females, week 94 males)
Why: No pre-neoplastic changes or other toxicity increasing over time
“The carcinogenicity study in rats was scheduled for 104 weeks of daily treatment, however it was terminated at week 85/86 for females and week 94 for males as no signs of pre-neoplastic changes was observed or any other sign of toxicity increasing over time.”
✓ VerifiedEMA assessment report, p. 31Source ↗ GenotoxicityAcceptedBeyond the letter
Clastogenic in in vitro CHO chromosomal aberration and GreenScreen assays; negative in vivo chromosome aberration and comet assays
Why: Negative in vivo chromosome aberration and comet assays plus negative Ames; weight of evidence not genotoxic · Weight of evidence
“Vadadustat was negative for mutagenicity (Ames assay) but positive results were obtained in the in vitro CHO assay for chromosomal aberrations and the GreenScreen assay.”
✓ VerifiedEMA assessment report, p. 30Source ↗ “Overall, the in vivo chromosome aberration assay and COMET assays tested negative and, in conjunction with the negative Ames assay result, the weight of evidence suggests that vadadustat is not genotoxic, which is agreed.”
✓ VerifiedEMA assessment report, p. 30Source ↗