Impurity or metaboliteAccepted with a conditionBeyond the letter
Major active human metabolites CC112273 and CC1084037 under-represented in pivotal toxicity, carcinogenicity and DART studies
Why: Higher CC112273 exposure not achievable by direct dosing; inadequate coverage addressed through SmPC embryo-fetal and carcinogenic risk wording · Pharmacology or kinetics
“Overall, the nonclinical studies are adequate to support approval of ozanimod for the proposed indication, although systemic exposures to the two major (and active) human metabolites (CC112273 and CC1084037) were lower in several pivotal studies than in humans at the maximum recommended human dose (0.92 mg/day).”
✓ VerifiedFDA pharmacology/toxicology review, p. 8Source ↗ “The Applicant was requested to address the clinical implications of the inadequate coverage of CC112273 and CC1084037 levels in the above-mentioned studies by amendments of sections 4.4 and 4.6 of the SmPC concerning the embryo-foetal risks and section 4.4 of the SmPC concerning carcinogenic risks (immunosuppressive effects and cutaneous neoplasms).”
✓ VerifiedEMA assessment report, p. 33Source ↗ DARTCriticised but acceptedBeyond the letter
Rat pre- and postnatal development study lacked adequate exposure to metabolite CC1084037; primary reviewer sought a postmarketing study
Why: Clear adverse developmental effects including teratogenicity already shown for ozanimod and should discourage use in pregnancy · Weight of evidence · Pharmacology or kinetics
“Dr. Toscano concluded that the PPND study is inadequate because of the lack of sufficient exposure to CC1084037 and recommended the metabolite be assessed in a PPND study as a post-marketing requirement.”
✓ VerifiedFDA pharmacology/toxicology review, p. 8Source ↗ “However, the available data demonstrate that ozanimod, administered to pregnant animals, has clear adverse effects on the developing organism, including teratogenicity, which are consistent with the critical role of the S1P1 and S1P5 receptors in embryogenesis (including vascular and neural development) and should discourage use during pregnancy. Therefore, I do not believe the sponsor needs to conduct such a study.”
✓ VerifiedFDA pharmacology/toxicology review, p. 8Source ↗ Safety marginVerdict not stated
No NOAEL and no safety margin in the rabbit embryo-fetal study: malformations at the lowest dose
“However, in this species, malformations were already noted at the lowest dose level and consequently no NOAEL and no safety margin with respect to clinical exposure could be established.”
✓ VerifiedEMA assessment report, p. 30Source ↗