Study lengthCriticised but acceptedBeyond the letter
No chronic toxicity study, although the long-life-expectancy indication falls outside ICH S9
Why: Clinical experience (136 patients over 12 months, 79 over 24 months) considered sufficient; 3Rs principles · Human data
“The applicant has submitted a non-clinical package according to the recommendations mentioned in the ICH guideline S9; however, given the long-life expectancy of the patients the claimed indication does not fall under the scope of the ICH S9 guideline.”
✓ VerifiedEMA assessment report, p. 33Source ↗ “Since the current clinical experience (more than 136 patients are treated for more than 12 months of which 79 are treated for more than 24 months) could be considered sufficient and in accordance with the 3R’s principles, no chronic toxicity studies will be requested.”
✓ VerifiedEMA assessment report, p. 33Source ↗ CarcinogenicityAccepted with a conditionBeyond the letter
No carcinogenicity studies before approval; mouse and rat studies required post-marketing given long survival
Why: Chronic use given the life expectancy of the patient population
“Carcinogenicity studies in mice and rats are warranted to determine the risk of carcinogenicity from vorasidenib for chronic use given the life expectancy of the proposed patient population. Two nonclinical Post Marketing Requirements (PMRs) for rodent carcinogenicity studies were communicated to the Applicant.”
✓ VerifiedFDA multi-discipline review, p. 80Source ↗ DARTAccepted with a conditionBeyond the letter
No fertility or pre- and postnatal development studies; ICH S9 waiver not accepted by CHMP for this indication
Why: Women of childbearing potential with long life expectancy; rat PPND study committed post-approval
“The claimed indication being out of the scope of the ICH S9 guideline, therefore waiving the conduct of other developmental and reproduction toxicity studies is not considered justified on this sole basis.”
✓ VerifiedEMA assessment report, p. 35Source ↗ “Since the patient population also includes women of childbearing potential who might have a wish to become pregnant due to the relatively long life-expectancy, the applicant has committed to perform and submit a PPND study in rats post-approval with submission of the final study report by Q2 2026.”
✓ VerifiedEMA assessment report, p. 35Source ↗ Impurity or metaboliteCriticised but acceptedBeyond the letter
No longer-term toxicity data for the major human metabolite AGI-69460
Why: Slow formation in humans limits long-term exposure; no safety concern in substantial clinical experience · Human data · Pharmacology or kinetics
“The lack of longer term toxicity data for metabolite AGI-69460 is not considered acceptable considering that the claimed indication does not fall under the ICH S9 guideline. Formation and accumulation of AGI-69460 is slow in humans, and therefore significant long-term exposure is limited.”
✓ VerifiedEMA assessment report, p. 34Source ↗ “Since no safety concern was detected in significant clinical experience (more than 136 patients were treated for more than 12 months of which 79 were treated for more than 24 months), dedicated chronic toxicity studies of AGI-69460 are not considered required.”
✓ VerifiedEMA assessment report, p. 34Source ↗