Summary Basis of Decision for Prexige

Review decision

The Summary Basis of Decision explains why the product was approved for sale in Canada. The document includes regulatory, safety, effectiveness and quality (in terms of chemistry and manufacturing) considerations.


Product type:

Drug
Prexige

Lumiracoxib, 100 mg, Tablets, Oral

Novartis Pharmaceuticals Canada Inc.

Submission control no: 102465

Date issued: 2007-06-27

Health Products and Food Branch

Our mission is to help the people of Canada maintain and improve their health.
Health Canada

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Health Products and Food Branch

Également disponible en français sous le titre : Sommaire des motifs de décision (SMD), PrPREXIGE*, lumiracoxib, 100 mg comprimé, Novartis Pharmaceuticals Canada Inc., No de contrôle de la présentation 102465

Foreword

Health Canada's Summary Basis of Decision (SBD) documents outline the scientific and regulatory considerations that factor into Health Canada regulatory decisions related to drugs and medical devices. SBDs are written in technical language for stakeholders interested in product-specific Health Canada decisions, and are a direct reflection of observations detailed within the evaluation reports. As such, SBDs are intended to complement and not duplicate information provided within the Product Monograph.

Readers are encouraged to consult the 'Reader's Guide to the Summary Basis of Decision - Drugs' to assist with interpretation of terms and acronyms referred to herein. In addition, a brief overview of the drug submission review process is provided in the Fact Sheet entitled 'How Drugs are Reviewed in Canada'. This Fact Sheet describes the factors considered by Health Canada during the review and authorization process of a drug submission. Readers should also consult the 'Summary Basis of Decision Initiative - Frequently Asked Questions' document.

The SBD reflects the information available to Health Canada regulators at the time a decision has been rendered. Subsequent submissions reviewed for additional uses will not be captured under Phase I of the SBD implementation strategy. For up-to-date information on a particular product, readers should refer to the most recent Product Monograph for a product. Health Canada provides information related to post-market warnings or advisories as a result of adverse events (AE).

For further information on a particular product, readers may also access websites of other regulatory jurisdictions. The information received in support of a Canadian drug submission may not be identical to that received by other jurisdictions.

Other Policies and Guidance

Readers should consult the Health Canada website for other drug policies and guidance documents. In particular, readers may wish to refer to the 'Management of Drug Submissions Guidance'.

1 Product and submission information

Brand name:

Prexige

Manufacturer/sponsor:

Novartis Pharmaceuticals Canada Inc.

Medicinal ingredient:

Lumiracoxib

International non-proprietary Name:

Lumiracoxib

Strength:

100 mg

Dosage form:

Tablets

Route of administration:

Oral

Drug identification number(DIN):

  • 02288036

Therapeutic Classification:

Cyclooxygenase-2 (COX-2) selective non-steroidal anti-inflammatory agent (NSAID)

Non-medicinal ingredients:

Microcrystalline cellulose, povidone, titanium dioxide, croscarmellose sodium, magnesium stearate, hypromellose, polyethylene glycol, talc, ferric oxide, and lactose

Submission type and control no:

New Drug Submission, Control No. 102465

Date of Submission:

2005-11-15

Date of authorization:

2006-11-02

PrPREXIGE* is a registered trademark

2 Notice of decision

On November 2, 2006, Health Canada issued a Notice of Compliance to Novartis Pharmaceuticals Canada Inc. for the drug product Prexige*.

Prexige* contains the medicinal ingredient lumiracoxib which is a cyclooxygenase-2 (COX-2) selective non-steroidal anti-inflammatory drug (NSAID).

Prexige* is indicated for the acute and chronic treatment of the signs and symptoms of osteoarthritis (OA) of the knee in adults. Osteoarthritis is a chronic, irreversible, non-inflammatory degenerative joint disease characterized by degeneration of the articular cartilage, hypertrophy of bone at the margins, and changes in the synovial membrane. It is accompanied by pain, swelling, and stiffness of the joints. Prexige* exhibits anti-inflammatory activities by inhibiting prostaglandin synthesis via inhibition of COX-2.

The market authorization was based on submitted data from quality (chemistry and manufacturing), non-clinical, and clinical studies. The efficacy of Prexige* was evaluated in approximately 18,500 patients, including 1,850 patients treated with Prexige* at the 100 mg therapeutic dose. Results showed improvement in overall pain, patient and physician global assessments, OA-specific pain, stiffness, and functional physical measures of OA. Safety was evaluated in 18,325 patients in a large safety outcomes study, in addition to the clinical arthritis program comprising 9,395 patients treated with lumiracoxib. Compared to non-selective NSAIDs there was a greatly reduced frequency of gastrointestinal adverse events, fewer hypertensive adverse events, no significant increase in cardiovascular risk, no increase in edema or hematological risk, and no increase in serious skin adverse reactions. There was however, an increased risk of liver abnormalities (abnormalities > 3x the upper limit of normal were reported in approximately 1% of patients) and an increased potential for renal dysfunction (no clinically significant creatinine elevations were observed). An external review on the safety of COX-2 selective NSAIDs conducted by an Expert Advisory Panel (EAP) included input from the patient and scientific communities, as well as other interested members of the public. This consultation resulted in a series of recommendations (EAP Report, July 2005) which were also taken into account during the submission review.

Prexige* (100 mg, lumiracoxib) is presented as oral tablets. The recommended dose of Prexige* is 100 mg daily. The dose should not be increased as this does not provide any additional benefit. Use of Prexige* should be limited to the lowest effective dose for the shortest possible duration of treatment in order to minimize the potential risk for cardiovascular or gastrointestinal adverse events. Dosing guidelines are available in the Product Monograph.

Prexige* is contraindicated for patients with a wide variety of conditions which are outlined in the Product Monograph, along with additional warnings and precautions. For patients with an increased risk of developing cardiovascular and/or gastrointestinal adverse events, other management strategies that do not include the use of NSAIDs should be considered first.

Prexige* should be administered under the conditions stated in the Product Monograph taking into consideration the potential risks associated with the administration of this drug product. Detailed conditions for the use of Prexige* are described in the Product Monograph.

Based on the Health Canada review of data on quality, safety, and effectiveness, Health Canada considers that the benefit/risk profile of Prexige* is favourable for the acute and chronic treatment of the signs and symptoms of osteoarthritis of the knee in adults.

3 Scientific and Regulatory Basis for Decision

Lumiracoxib at doses of 200 and 400 mg o.d. was originally submitted to Health Canada in 2003 for several indications including the treatment of both osteoarthritis (OA) and rheumatoid arthritis (RA). A Notice of Non-Compliance (NON) followed by a NON-Withdrawal letter were issued in 2004, mainly due to recent concerns regarding the cardiovascular safety of selective COX-2 inhibitors and the short duration of the submitted studies. The review below covers the re-filed NDS, in which the sponsor was seeking the authorization of a lower dose of lumiracoxib (100 mg o.d.) for the sole indication of the acute and chronic treatment of the signs and symptoms of OA. An external review on the safety of COX-2 selective NSAIDs was conducted by an Expert Advisory Panel (EAP) and included input from the patient and scientific communities, as well as other interested members of the public. This consultation resulted in a series of recommendations (EAP Report, July 2005) which were also taken into account during the submission review.

3.1 Quality Basis for Decision

3.1.1 Drug Substance (Medicinal Ingredient)

Manufacturing Process and Process Controls

The manufacture of lumiracoxib consists of six chemical steps. Each step of the manufacturing process is considered to be controlled within acceptable limits:

  • The sponsor has provided information on the quality and controls for all materials used in the manufacture of the drug substance.
  • The drug substance specifications are found to be satisfactory. Impurity limits meet ICH requirements.
  • The processing steps have been evaluated and the appropriate ranges for process parameters have been established.

Characterization

Lumiracoxib is a white-to-yellowish or beige powder and has low solubility. The structure of lumiracoxib has been adequately elucidated and the representative spectra have been provided. Physical and chemical properties have been described and are satisfactory.

The sponsor has provided a summary of all drug-related impurities. Impurities arising from manufacturing were reported and characterized. These products were found to be within ICH established limits, and therefore considered to be acceptable.

Control of Drug Substance

Validation reports are considered satisfactory for all analytical procedures used for in-process and release testing of the drug substance, and to justify the specifications of the drug substance.

Data from the batch analyses were reviewed and are considered to be acceptable according to the specifications of the drug substance.

The proposed packaging components are also considered acceptable.

Stability

Based on the real-time and accelerated stability data submitted, the proposed shelf-life, storage and shipping conditions for the drug substance were supported and considered to be satisfactory.

3.1.2 Drug Product

Description and Composition

Prexige* is presented as 100 mg tablets. Tablets are oval, red, and film-coated, with 'NVR' debossed on one side and 'OB' debossed on the other side. Prexige is packaged in either round, white, high density polyethylene (HDPE) bottles with white HDPE closure and yellow tamper-evident (TE) band (100 tablets per 60 mL bottle), or in polyvinyl chloride (PVC) thermoformed blister packs (10 tablets per pack) backed with a heat-sealable lacquered aluminium foil.

Each tablet of Prexige* contains 100 mg of lumiracoxib and the following inactive ingredients: microcrystalline cellulose, croscarmellose sodium, povidone, magnesium stearate, hypromellose, polyethylene glycol, talc, ferric oxide, lactose, and titanium dioxide.

All excipients found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations. The compatibility of lumiracoxib with the excipients is demonstrated by the stability data presented on the proposed commercial formulation.

Pharmaceutical Development

Pharmaceutical development data, including development of the container closure system, are considered acceptable. Studies which justified the type and proposed concentration of excipients to be used in the drug product were reviewed and considered to be acceptable.

Manufacturing Process and Process Controls

The manufacturing process for Prexige* includes mixing, wet granulation, drying, milling, blending, tablet compression, film-coating, and packaging. All equipment, operating parameters, in-process tests and detailed instructions are adequately defined in the documentation. The manufacturing process is considered to be acceptable and adequately controlled within justified limits.

Control of Drug Product

Prexige* batches are tested to verify that the appearance, blend uniformity, dissolution, weight, thickness, hardness, friability, disintegration time, and the presence of impurities and degradation products are within acceptance criteria. The test specifications and analytical methods are considered acceptable; the shelf-life and the release limits, for individual and total degradation products, are within acceptable limits.

Validation reports submitted for all analytical procedures used for in-process and release testing of the drug product are satisfactory, and justify the specifications of the drug product.

Data from final batch analyses were reviewed and considered to be acceptable according to the specifications of the drug product.

Stability

Stability data show that HDPE bottles capped with HDPE caps and the PVC thermoformed blister packs with aluminum backing are acceptable container/closure systems for the drug product. Prexige* tablets are photostable.

Based on the real-time and accelerated stability data submitted, the proposed 24-month shelf-life for the commercial product is considered acceptable when stored at 15-30°C.

3.1.3 Facilities and Equipment

The design, operations and controls of the facility and equipment that are involved in the production are considered suitable for the activities and products manufactured. All of the proposed manufacturing sites comply with the requirements of Division 2 of the Food and Drug Regulations.

3.1.4 Adventitious Agents Safety Evaluation

The non-medicinal ingredient lactose is of animal origin and is derived from bovine material sourced from Belgium, Germany, The Netherlands, Austria, Czech Republic, Croatia, Hungary, Italy, or Slovenia. Signed declarations have been provided from all suppliers indicating compliance with the European Medicines Agency (EMEA) Public Statement EMEA/CPMP/571/02 regarding lactose prepared using calf rennet. This information is considered acceptable.

3.1.5 Summary and Conclusion

The Chemistry and Manufacturing information submitted for Prexige* has demonstrated that the drug substance and drug product can be consistently manufactured to meet the approved specifications. Proper development and validation studies were conducted, and adequate controls are in place for the commercial processes.

3.2 Non-Clinical Basis for Decision

3.2.1 Pharmacodynamics

The non-clinical pharmacology program demonstrated that lumiracoxib is a selective inhibitor of COX-2 both in vitro and in vivo. As with most COX-2 selective inhibitors, lumiracoxib demonstrated dose-dependent inhibition of COX-2 and not of COX-1.

Potent inhibition of COX-2-derived PGE2 by lumiracoxib was demonstrated in the lipopolysaccharide (LPS)-induced air pouch inflammation model (ED50 0.2 mg/kg) 4 hours after an oral dose. The ED50 in this assay (33.5 mg/kg) exceeded the doses required for efficacy in models of inflammation and hyperalgesia. Inhibition of inflammatory hyperalgesia was also demonstrated in rats. Lumiracoxib, celecoxib, and diclofenac caused a reversal in Complete Freund's adjuvants (CFA)-induced hyperalgesia when measured one hour post dose (D30 of 5.1, 5.5, and 6.8 mg/kg, respectively).

Lumiracoxib also caused a modest inhibition of renal PGE2 (~50%). This effect was observed at an oral dose of 30 mg/kg, which is well in excess of that needed for anti-inflammatory efficacy in the animal studies. Since COX-1 and COX-2 are both expressed in the kidney, this result can be expected.

Based on the results of the cardiovascular safety pharmacology studies and ECG evaluations in the repeat-dose toxicity studies in monkeys, it is concluded that no non-clinical signals of QT prolongation relevant for humans have been detected. This is confirmed by the absence of effect on the QT interval in clinical studies.

3.2.2 Pharmacokinetics

The non-clinical pharmacokinetic studies used established methods in animals. The following conclusions can be drawn from the data regarding PK in humans:

Absorption

Absorption of lumiracoxib was rapid following oral administration. Over the dose range of 25 mg to 800 mg lumiracoxib, the amount of drug exposure (AUC) increased in a dose-proportional manner, and the peak plasma concentration (Cmax) was roughly dose proportional. Absolute bioavailability of lumiracoxib was approximately 74% and the terminal half-life was approximately 4 hours. Lumiracoxib did not accumulate in plasma under once-daily administration. Median time to maximum plasma concentration (Tmax) of lumiracoxib was 1.1 hours. Steady state was achieved on the first day of administration, with no increase in Cmax or AUC after extended dosing.

Distribution

Lumiracoxib had strong binding affinity to plasma proteins (≥98%) and a negligible amount of lumiracoxib was found in the red blood cells. One hour after oral administration of 14C-labelled lumiracoxib in a rat model of inflammation, the ratio of radioactivity detected at the site of inflammation vs. that detected in the blood was 2:1, increasing to 8:1 four hours post-dose. Lumiracoxib and/or its metabolites were preferentially retained in inflamed tissue. Concentrations of lumiracoxib in human synovial fluid (in patients with rheumatoid arthritis) were higher than plasma by approximately 5 hours post-dose and remained substantially higher than the plasma levels for the remainder of the dose interval (AUC12-24 in synovial fluid was 2.6 times higher).

Metabolism

In humans, lumiracoxib undergoes extensive hepatic metabolism primarily mediated via the cytochrome P450 isoenzyme 2C9. Of the total drug-related material in plasma, unchanged lumiracoxib is the major component. Three major metabolites were identified in plasma: 4'-hydroxy-lumiracoxib, 5-carboxy-lumiracoxib, and 4'-hydroxy-5-carboxy-lumiracoxib. Various conjugates (e.g., glucuronides) are formed with these metabolites. The 4'-hydroxy metabolite appears to have a similar potency and COX-2 selectivity compared to lumiracoxib but the concentration of the 4'-hydroxy metabolite in plasma and synovial fluid is low, and therefore is unlikely to contribute to efficacy. The other metabolites are inactive as either COX-1 or COX-2 inhibitors.

Excretion

Lumiracoxib is eliminated predominantly via hepatic metabolism. Plasma clearance is 128 mL/min. The mean plasma terminal half-life of lumiracoxib is approximately four hours.

3.2.3 Toxicology

Studies were conducted to elucidate the potential toxicity of lumiracoxib. The protocols used were similar to those used in the non-clinical studies of other non-steroidal anti-inflammatory drugs (NSAIDs) with selectivity for COX-2. Mice, rats and monkeys were the animals used. The cynomolgus monkey was selected as the non-rodent species for toxicity studies with lumiracoxib due to experience with other NSAIDs that indicated a greater sensitivity of the dog to gastrointestinal (GI) effects of NSAIDs.

Acute Studies

The minimum lethal dose in rodents ranged from 500-1200 mg/kg after a single oral dose of lumiracoxib, and 750-1000 mg/kg after a single intraperitoneal dose. Intestinal perforations and/or peritonitis were frequently found in gross examinations of the animals that died. Death was generally delayed, and occurred 4-6 days post-dosing.

Consistent with the known non-clinical toxicity profile of COX-2 inhibitors, two primary target organs of toxicity were identified in the repeat-dose rodent studies: the GI tract and the kidney. The GI toxicity was characterized by erosions, ulcerations, perforations and peritonitis. These lesions were found in all parts of the GI tract, but especially in the small intestine. Secondary to these lesions was leakage of intestinal contents with subsequent inflammation and adhesions on the peritoneal surfaces of various organs in the abdominal cavity, as well as mortality associated with the gastrointestinal lesions.

The hematology and clinical chemistry changes were likely secondary to the GI toxicity, and included: elevations in white blood cell counts; decreases in red blood cell counts, hematocrit, and hemoglobin; reticulocytosis; increased platelet counts; extramedullary hematopoiesis; granulopoiesis in bone marrow; and lymphocyte/plasma cell hyperplasia in various, often enlarged, lymphoid organs (in reaction to the blood loss). Decreases in albumin and total serum protein were also reported.

Sub-chronic Studies

The no-observed-adverse-effect level (NOAEL) in rodents was 10 mg/kg, which is equivalent to an exposure of approximately 2.1- 3.6 times the human dose. Mortality due to GI lesions occurred at 30 mg/kg in rats treated for 13 weeks by diet and for 26 weeks by oral gavage. Systemic exposure ratios were 11.6 and 12.3 times that of the human dose, respectively. After a 4-week recovery period, GI lesions and related findings were not observed.

Nephropathy was characterized by corticomedullary tubular dilation, and was noted in mice and rats when lumiracoxib was administered in the diet, but not by oral gavage. In mice, nephropathy was found at doses ≥150 mg/kg in a 2-week study and at doses ≥50 mg/kg after 13-weeks administration. In rats, nephropathy was noted at doses of ≥50 mg/kg and ≥30 mg/kg in the 2-week and 13-week studies, respectively.

Lumiracoxib was better tolerated in monkeys than in rodents, however the GI tract and kidney were identified as target organs. Mortality due to intestinal ulcers was observed in a 4-week study at the initial dose of 500 mg/kg. Secondary clinical pathology (anemia and decreased serum proteins) and microscopic findings were similar to those in rodents with gastrointestinal lesions. Evidence of GI toxicity was observed at doses ≥300 mg/kg and 500/200 mg/kg in 2- and 4-week studies, respectively, but was not detected in monkeys treated with lumiracoxib for 39-weeks at up to 150 mg/kg.

The NOAEL for monkeys treated chronically with lumiracoxib was 40 mg/kg (yielding approximately 12 times the human systemic exposure).

Indications of renal toxicity in monkeys were minimal increases in blood urea nitrogen (BUN) in all studies, and a microscopic finding of tubular dilation in the outer cortex of the kidney in the 4-week study at the high dose of 500/200 mg/kg. Elevated BUN levels occurred at doses as low as 40 mg/kg. The increases in BUN were not accompanied by changes in serum creatinine, with the exception of one moribund animal (500 mg/kg) in the 4-week study. Reversibility of the effect on BUN was evident after a 4-week recovery period.

Two-week intravenous toxicity studies in rats and cynomolgus monkeys with the clinical formulation were conducted to support single dose intravenous (IV) administration of lumiracoxib in humans. Skin lesions at or near injection sites were observed at doses ≥10 mg/kg in rats and at all doses (4, 20, and 40 mg/kg) in monkeys. In monkeys, the severity of the injection site lesions at 40 mg/kg necessitated early termination and therefore no NOAEL could be established.

The NOAEL for lumiracoxib administered by the IV route in rats was 4 mg/kg.

Chronic Studies

In long-term studies, lumiracoxib was administered orally by gavage to rats and monkeys for up to 26 or 39 weeks, respectively, or as dietary admixtures to mice and rats for up to 104 weeks. Absorption from the oral route was rapid and almost complete (90-100%) in the mouse, rat, rabbit and monkey, and bioavailability ranged from 33-100%. No gender differences in exposure to lumiracoxib were apparent. The primary targets of toxicity identified in the non-clinical studies with lumiracoxib included the GI tract, kidneys, and female reproductive tract. The effects on these organs are consistent with toxicities of other NSAIDs.

The GI tract was identified as the main target organ in studies with lumiracoxib, as mortality due to perforating ulcers and sequelae was dose limiting in all species investigated. Most of the drug-related findings in all species were either directly or indirectly related to the GI effects. Direct findings included GI erosions, ulcers, and perforations that progressed to secondary effects including peritonitis, blood loss, and anemia. Neutrophilia and monocytosis were often observed as a result of the peritonitis. Splenic erythropoiesis, hematological changes (decreased red blood cell counts, hematocrit, and hemoglobin, increased reticulocyte and platelet counts), and clinical chemistry changes (decreased total serum protein, albumin levels, and albumin/globulin ratio) were generally associated with blood loss and anemia. Inflammatory changes observed in various organs were attributed to the widespread peritonitis. Many animals died during the studies from the intestinal assaults.

The kidney was also identified as a target organ. The renal effects of lumiracoxib are probably related to its pharmacology as both COX-1 and COX-2 are found in the kidney. In a safety pharmacology study to evaluate the effects of lumiracoxib on water and electrolyte balance in saline-loaded rats, urine volume and sodium excretion were decreased at doses of 10 and 30 mg/kg, and chloride excretion was decreased at ≥1 mg/kg. These effects may be secondary to reduced prostaglandin levels in the kidney. Urinary prostaglandin E2 was decreased following oral administration of lumiracoxib (30 mg/kg) to normal rats.

Lumiracoxib treatment in rats or mice for two years did not increase the incidence of either benign or malignant tumors.

Reproductive and Developmental Studies

The effects observed in reproductive and developmental toxicity studies with lumiracoxib were not unexpected, considering the critical role that cyclooxygenase-derived prostaglandins play in female reproduction. In female rats, findings of decreased corpora lutea and implantation sites with consequent increases in pre-implantation loss and decreased numbers of viable fetuses may be explained by the requirement for COX-2 in ovulation and implantation. In the fertility assessment, there were no treatment-related effects on estrous cycles, pre-coital intervals, mating indices, or pregnancy rates. Although a small number of females in each dose group were noted to have irregular estrous cycles or were acyclic, this did not affect their ability to mate and become pregnant. In these studies, male fertility was unaffected by lumiracoxib treatment 4 weeks prior to and during mating, and no effects on male reproductive organs were identified in the 4- or 26-week repeat-dose toxicity studies.

There was no evidence of teratogenic effects in rats and rabbits at doses that resulted in exposure ratios of 5.7 and 20.8 times the expected human dose, respectively. Embryo-fetal toxicity however, was observed in both rats and rabbits. Although the mean number of corpora lutea was comparable among all dose groups in rats, the number of implantation sites was decreased at 100 mg/kg, correlating with an increase in pre-implantation loss and decreased numbers of viable fetuses. In the rabbit, decreases in viable fetuses were associated with statistically significant increases in resorptions at ≥ 60 mg/kg. Lumiracoxib was poorly absorbed into rabbit fetuses. No detectable levels of lumiracoxib were found in fetuses of females treated with <60 mg/kg and fetal tissue concentrations at the maternal dose of 200 mg/kg were about 5% of the maternal plasma concentration.

In rats there was an increase in the number of stillborn pups and decreased survival in the post-natal day 0-4 interval at dose levels ≥3 mg/kg. It is possible that maternal toxicity may have been associated with the fetal/neonatal mortality, based on clinical observations and their onset, however a direct effect of lumiracoxib on the fetuses/pups cannot be excluded. Lumiracoxib is excreted into milk of lactating rats.

COX-2 mediated events in late gestation include the induction of parturition and closure of the ductus arteriosus in fetuses. The effect of lumiracoxib on closure of the ductus arteriosus was not examined, however this is a recognized effect of this class of drugs and it may have contributed to the observed embryo-fetal effects in rats. Gestation length was slightly increased (0.4-0.5 days) at all dose levels. Due to the small magnitude of change, which is within the limit of precision of this measurement, the biological significance is questionable.

Neonatal/juvenile rats administered lumiracoxib from postpartum day 7 through 27 showed no signs of toxicity at dose levels up to and including 30 mg/kg in a dose range-finding study. A definitive GLP (Good Laboratory Practices) study using dose levels of 3, 10, and 30 mg/kg is ongoing.

Genotoxicity Studies

The genotoxic potential of lumiracoxib was evaluated in a series of in vitro and in vivo studies. There was no evidence of genotoxic potential in vivo in the rat in a liver comet assay, a liver micronucleus assay, or a bone marrow micronucleus assay. Negative results were also obtained in bacterial mutagenicity assays (Ames test), and a chromosomal aberration study using human lymphocytes. In V-79 cells, lumiracoxib produced an increased incidence of chromosome aberrations in 3 out of 4 studies, when tested at cytotoxic doses. Effects were seen both in the presence and absence of metabolic activation.

Two degradation products and one bromo-derivative by-product of lumiracoxib were qualified in in vitro genotoxicity studies in rats. All were negative in the Ames test for mutagenic effects and the impurities had no effect on the toxicity-induced clastogenicity of lumiracoxib in V79 cells.

3.2.4 Summary and Conclusion

The non-clinical pharmacology program demonstrated that lumiracoxib is a selective inhibitor of COX-2 both in vitro and in vivo. The toxicology studies with lumiracoxib have demonstrated neither teratogenic, immunotoxic, nor carcinogenic effects. An in vitro clastogenic response found only at high concentrations was not considered to pose a risk to humans, in light of negative in vivo genotoxicity tests and lack of tumorigenicity. The GI, renal, and embryo-fetal toxicities seen with lumiracoxib are not unexpected, based on its pharmacologic effects on these target organs.

3.3 Clinical basis for decision

3.3.1 Pharmacodynamics

Ex vivo COX-2 selectivity was evaluated in healthy subjects following single oral administration of lumiracoxib (25-800 mg). The percent inhibition of PGE2 formation was measured as a marker of COX-2 inhibition and the percent inhibition of formation of TxB2 as a marker of COX-1 inhibition. Following lumiracoxib treatment, there was substantial dose-dependent ex vivo inhibition of PGE2 formation. Ex vivo inhibition of TxB2 was highly variable and there was no dose-dependent trend in the data. Thus lumiracoxib remains highly selective even at concentrations near or at the Cmax following a single dose as high as 800 mg. As no accumulation is expected, this selectivity is expected to be maintained under multiple oral administrations.

In order to confirm the selectivity of lumiracoxib in vivo, additional studies with multiple doses for up to nine days were conducted in which lumiracoxib was compared with naproxen and indomethacin as non-selective COX-2 inhibitors. Naproxen (500 mg) inhibited both PGE2 as well as TxB2 but while lumiracoxib (800 mg) inhibited formation of PGE2 to the same extent, it had only a small effect on TxB2 formation. Indomethacin (50 mg) provided a strong and sustained inhibition of TxB2 (>80% compared to placebo) while the effect of 200 or 400 mg lumiracoxib was not different from that of placebo. These data confirm the selectivity of lumiracoxib at clinically relevant doses and at higher doses of up to 800 mg, and at plasma concentrations in excess of 25,000 ng/mL.

The effect of seven days of treatment with lumiracoxib (200 and 400 mg) on the production of several eicosanoids was studied in vivo in normotensive, salt-depleted, volume replete, healthy subjects. Lumiracoxib had no significant effect on thromboxane excretion. Systemic and renal prostacyclin production as measured by urinary excretion of 6-keto-PGF1-á was significantly decreased by lumiracoxib, however the inhibitory effect was transient. Compared to placebo, maximum inhibition (25 to 40%) was achieved at 2 to 4 hours post-dose. After reaching the nadir, the effect of lumiracoxib began to diminish so that by hours 12 to 24 post-dose 6-keto-PGF1-á excretion was at or near that observed in the placebo group. The data are consistent with previous published studies demonstrating that part of prostacyclin production is under the control of COX-2 activation. Renal PGE2 production was significantly decreased to an equal degree, approximately 45-50%. The inhibitory effect was transient.

In a parallel group study in rheumatoid arthritis (RA) patients, the effect of lumiracoxib (800 and 1200 mg) and naproxen (500 mg) on platelet aggregation was investigated. Both lumiracoxib and naproxen appeared to have no substantial effect on ADP (adenosine diphosphate) and collagen-induced platelet aggregation.

The effect of multiple-dose treatment with lumiracoxib, naproxen, and placebo on GI mucosa was studied by endoscopy in healthy volunteers in a parallel group and crossover studies. Both studies included measurements of inhibition of TxB2 in blood and the crossover study incorporated investigations of small intestine permeability (small and large bowel permeability by 51Cr-EDTA absorption) and PGE2 measurement in gastric biopsies. No erosions were detected in the subjects treated with lumiracoxib at 200 mg or 800 mg and in this respect lumiracoxib was found to be statistically significantly different from naproxen and not different from placebo. Consistent with these findings, lumiracoxib was not different from placebo in terms of gastric permeability. There was a small effect on gastric PGE2 inhibition by lumiracoxib compared to placebo. These are the expected findings of a selective COX-2 NSAID compared to naproxen.

The effects of seven days treatment with lumiracoxib (200 and 400 mg), rofecoxib (25 mg), indomethacin (50 mg) or placebo on renal function were studied in normotensive, salt-depleted, volume replete healthy subjects; a model sensitive to the inhibition of prostanoids. On the first day of treatment, lumiracoxib resulted in a significant 18% reduction in glomerular filtration rate compared to placebo. Consistent with renal adaptation to lumiracoxib treatment, this effect was not detectable after seven days of dosing. Compared to the placebo treatment group, the lumiracoxib and rofecoxib groups resulted in a significantly decreased sodium, chloride, potassium, and water urinary excretion during the first six hours of the dosing interval. This effect decreased during the 6 to 12 hours interval and was not observed during the latter part of the dosing interval (12-24 hours post-dose). Endogenous lithium clearance measured up to six hours post-dose was significantly reduced by both lumiracoxib and rofecoxib treatment. There was no consistent dose-response effect between the two lumiracoxib dose cohorts based on the pharmacodynamic variables measured in this study. These findings indicate that both classes of NSAIDs carry the potential risk of increase volume retention, oedema and hyperkalaemia. However, over the course of this study, the changes in renal physiology in healthy individuals were not accompanied by any clinical signs of salt and water retention. In comparison with placebo, none of the treatments had an effect on mean diastolic and systolic blood pressure or body weight. Edema was not observed. Patients with illnesses (the targeted population) may react differently as compared to healthy individuals.

3.3.2 Pharmacokinetics

Absorption

Absorption of lumiracoxib was rapid with a median tmax of 2.3 hours. The mean plasma half-life of lumiracoxib was 3.98±1.37 hours after oral administration; the shorter half-life (2.17±0.34 h) observed after intravenous dosing is probably underestimated. Mean plasma clearance was 7.7±1.5 L/h. Based on a blood to plasma ratio of ~0.5, the mean blood clearance is estimated to be ~15 L/h which is roughly 16% of hepatic blood flow (about 90 L/h). The volume of distribution at steady state (Vss) was 9.0±1.7 L.

The relative bioavailability of lumiracoxib was studied in 11 healthy subjects in a crossover study in which lumiracoxib (100 mg) was delivered to specific sites of the GI tract: stomach, proximal small bowel, distal small bowel and colon. The relative bioavailability compared to the reference release site of the stomach was consistently high in all regions. The tmax and Cmax were lower for the stomach compared to the small bowel, presumably due to gastric emptying and dissolution effects. Mean absolute bioavailability of lumiracoxib was 74.0±8.6%.

Three studies were conducted to examine the effect of food on the bioavailability of lumiracoxib. All three studies were of a randomized crossover design in which healthy subjects received 2 x 100 mg lumiracoxib capsules, a 200 mg lumiracoxib tablet, or a 400 mg lumiracoxib tablet (65% drug load) under fasting conditions and after a high fat breakfast (FDA recommended high fat meal). While slight changes in AUC, Cmax, and tmax were observed in the three studies, data suggest that lumiracoxib may be taken without regard to the timing of meals.

Distribution

The steady state pharmacokinetics (PK) of lumiracoxib were characterized over nine days in healthy subjects, over 28 and 91 days in osteoarthritis (OA) and rheumatoid arthritis (RA) patients. Following repeated oral administration of lumiracoxib to healthy subjects, both Cmax and AUCT did not exhibit significant change from Day 1 through the last day of dosing. In addition, there was no evidence for a rise in trough plasma concentrations collected throughout the multiple dose administration period. In OA/RA patients, there was no evidence for accumulation from the first dose (Day 0) compared to doses on days 28 or 91. Doses as high as 1200 mg orally in RA patients also did not result in accumulation. Thus, the pharmacokinetics of lumiracoxib are time-independent and no accumulation or auto-induction is observed.

Binding of lumiracoxib to plasma proteins was high (≥98%, almost exclusively to albumin) and independent of concentration over the 0.1 to 100 µg/mL test range. Plasma protein binding of lumiracoxib ex vivo in normal volunteers and patients with end stage renal disease requiring hemodialysis was analyzed. The mean bound percent of lumiracoxib was 98% in both patients with renal failure and in normal subjects.

Plasma protein binding of lumiracoxib was also studied ex vivo in patients with moderate hepatic impairment. The mean bound percent of lumiracoxib was 98% in both patients with moderate hepatic impairment and in normal subjects. There is no evidence that binding in synovial fluid differs from binding to plasma proteins. Human plasma protein binding of lumiracoxib and its major metabolites was investigated at a concentration of 100 µg/mL. Lumiracoxib and 4'-hydroxy-lumiracoxib, were found to have comparably high plasma protein binding with bound percents of 99.6-99.7% and 99.5%, respectively. Protein binding of 4'-hydroxy-5-carboxy-lumiracoxib and 5-carboxy-lumiracoxib was slightly lower at 97.5-98.0% and 96.5-97.0%, respectively.

Metabolism

Following oral administration of lumiracoxib to healthy subjects, lumiracoxib was subject to only a modest first-pass effect with unchanged drug accounting for most (80-90%) of the drug-related material during the first 2.5 h post dose. The metabolite 4'-hydroxy-lumiracoxib was shown to be similar in potency and selectivity to lumiracoxib in assays of inhibition of thromboxane B2 and prostaglandin E2 production in whole blood, and therefore may have similar COX-2 inhibitory activity in humans in vivo. The relatively low concentrations of this metabolite in both plasma and synovial fluid with respect to lumiracoxib however, suggest that it is unlikely to contribute significantly to efficacy.

Excretion

Following oral administration of 400 mg [14C]-lumiracoxib to healthy subjects, a mean of 54% of the radioactive dose was recovered in urine and a mean of 43% was recovered in feces. Means of 3.3% and 2.0% of the dose were recovered as unchanged lumiracoxib in urine and feces, respectively. Renal clearance was determined following doses of 25-800 mg to healthy subjects and was found to be typically between 0.05-0.2 L/h. Lumiracoxib is thus mainly cleared by metabolism.

Sub-Population Pharmacokinetics

PK data from subjects included in 16 studies were used in an analysis of the influence of demographic factors (age, gender, race, and body weight) on the PK of lumiracoxib. No clinically relevant treatment effects were noted with respect to any of these factors.

In an open-label study, eight subjects with end stage renal disease (ESRD) and eight matched healthy controls each received an oral dose of 200 mg lumiracoxib. The AUC of lumiracoxib in ESRD patients was about 27% lower than in healthy subjects, and neither AUC nor Cmax appeared to be influenced by dialysis. Treatment with lumiracoxib is not recommended in patients with advanced renal disease.

The PK of lumiracoxib was also examined in patients with moderate hepatic impairment. AUC was increased by only 1%, therefore no dose adjustment is required in patients with mild to moderate hepatic impairment. The impact of severe hepatic impairment has not been assessed.

As lumiracoxib is cleared principally by metabolism catalyzed by CYP2C9, there exists a possibility of a group of poor metabolizers in the general population, with consequent potential for increased exposure and possible loss of COX-2 selectivity. This has been studied in vitro and in vivo. No correlation between the CYP2C9 genotype and exposure to lumiracoxib was observed. The data support the use of lumiracoxib in the general population without concern for loss of COX-2 selectivity in patients who possess CYP2C9 genotypes which bear a potential for lower clearance of drugs mainly metabolized by CYP2C9.

With respect to drug-drug interactions, lumiracoxib appears to have a low potential for interactions with compounds cleared by cytochrome P450. Interactions of clinical significance resulting from plasma protein binding effects of lumiracoxib on other drugs or by effects of co-administered drugs on lumiracoxib are not anticipated. No significant effect on the PK of lumiracoxib was noted when taken concomitantly with omeprazole or antacids, and lumiracoxib was not found to influence treatment with methotrexate or oral contraceptives.

Healthy volunteers were pre-treated with multiple-doses of fluconazole, then concomitantly administered lumiracoxib. The modest effect of fluconazole on lumiracoxib pharmacokinetics may suggest that under conditions of inhibition of CYP2C9, an alternative route of clearance is available for lumiracoxib, likely via an alternative metabolic pathway. As lumiracoxib may form an acyl glucuronide directly, this seems to be a likely alternative pathway, however other mechanisms cannot be excluded.

In a parallel group study, healthy subjects were treated with warfarin, warfarin and lumiracoxib, or warfarin and placebo administered concomitantly for five days. This study suggests that the PK of substrates less sensitive to CYP2C9 inhibition than warfarin are unlikely to be affected by co-administration with lumiracoxib. On the basis of the pharmacodynamic (PD) analysis in this study, additional monitoring of anticoagulant activity should be conducted in patients receiving warfarin, particularly in the first few days after initiating or changing lumiracoxib therapy. This admonition regarding testing patients on anticoagulants is generic to all selective COX-2 NSAIDs. Bleeding problems (some fatal) were reported in some patients in post-marketing reports.

3.3.3 Clinical Efficacy

The efficacy of 100 mg lumiracoxib once daily (o.d.) in the treatment of the signs and symptoms of knee OA was evaluated in two new double-blind, phase III placebo- and active-controlled OA studies (Study 2360, n=1551, and Study 2361, n=1684) comparing the efficacy and safety of 100 mg lumiracoxib o.d.) to that of placebo and 200 mg celecoxib o.d. for 13 weeks, followed by extension phases of 52 weeks. Study 2360 was extended to 52 weeks as an open-label, long-term efficacy/safety study in patients treated with 100 mg lumiracoxib o.d., while Study 2361 was extended to 52 weeks as an active-controlled efficacy/safety study in patients treated with 100 mg lumiracoxib o.d. or 200 mg celecoxib o.d.

Three co-primary efficacy variables were used in the two pivotal trials: OA pain intensity at 13 weeks in the target joint in the last 24 hours, the patient's global assessment of disease activity at 13 weeks, and the total score of the Western Ontario and McMaster Universities (WOMAC) questionnaire at 13 weeks. Key secondary variables were also evaluated; the OMERACT-OARSI response, and other common secondary variables (PASS and MPCI).

Data from the two major efficacy studies showed superior efficacy of 100 mg lumiracoxib o.d. to placebo and comparable efficacy to 200 mg celecoxib o.d. at 13 weeks for all three co-primary variables.

Treatment with 100 mg lumiracoxib o.d. resulted in improvement throughout the 52-week time points in overall pain, patient and physician global assessments, OA-specific pain (e.g., walking, stair climbing, resting, standing upright), stiffness (in the morning and later in the day), and functional physical measures of OA (as quantified by the WOMAC questionnaire or the AUSCAN Hand Osteoarthritis Index).

3.3.4 Clinical Safety

The relevant safety data for lumiracoxib was presented in three separate safety datasets. In each dataset, clinical studies were grouped based on similarities in the study design, patient population, and exposure. Dataset 1 represented pooled safety data from 13 short-term OA studies of up to 13 weeks exposure, dataset 2 represented pooled safety data from three long-term OA studies of up to one year exposure, and dataset 9 represented pooled safety data from 23 combined short and long-term OA and RA studies of up to one year exposure. All three datasets included safety data from patients taking 100 mg lumiracoxib o.d. as well as higher doses. In datasets 1 and 9, the safety of lumiracoxib was compared to that of different selective COX-2 inhibitors, non-selective NSAIDs, and placebo. In dataset 2, the safety of lumiracoxib at doses of 100, 200, and 400 mg o.d. was compared to that of 200 mg celecoxib o.d. with no placebo comparison.

Safety data also included results from a large GI outcome study (TARGET); an international, double-blind, phase III study conducted to further investigate the GI safety of lumiracoxib. In the TARGET study, 18,325 OA patients were randomized to receive treatment with 400 mg lumiracoxib o.d. (a supra-therapeutic dose, four-times the maximum recommended chronic daily dose), 500 mg naproxen twice daily (b.i.d.) or 800 mg ibuprofen three times daily (t.i.d.) for one year. TARGET was prospectively designed to include patients who were taking low-dose aspirin (75-100 mg daily) for primary or secondary prevention of coronary heart disease.

In standard clinical trials, lumiracoxib was evaluated for safety in approximately 18,500 patients combined, including approximately 15,850 patients with OA and 2,650 patients with RA. Of those, approximately 1,850 OA patients were treated with 100 mg lumiracoxib o.d. for 3 months, and approximately 750 patients were treated with 100 mg lumiracoxib o.d. for one year.

Compared to the other NSAID comparators used in the clinical program for the study of lumiracoxib, the following safety conclusions could be drawn:

1) A superior gastrointestinal safety profile relative to non-selective NSAIDs
GI toxicity leading to ulcers, perforations, and bleeding is one of the major health risks associated with NSAID therapy and accounts for significant mortality and morbidity. An enhanced GI safety profile for lumiracoxib compared to non-selective NSAIDs was clearly demonstrated in all clinical safety datasets. GI AEs and ulcers were reported much less frequently with lumiracoxib than with non-selective NSAIDs. In long-term OA studies, GI adverse events (AEs) and ulcers were also less frequently reported with 100 mg lumiracoxib o.d. (the indicated dose in the current submission) compared to 200 mg celecoxib o.d. (the only other COX-2 selective inhibitor currently authorised in Canada).

A superior GI safety profile for lumiracoxib compared to non-selective NSAIDs was also demonstrated in the TARGET study. A highly statistically significant 79% reduction in complicated ulcers [perforations, obstructions, bleeds (POBs)] of the upper GI tract was demonstrated with the use of a four-fold supra-therapeutic dose of 400 mg lumiracoxib o.d. dose vs. the use of naproxen and ibuprofen in patients not taking low-dose ASA. A highly significant 66% reduction in POBs in favor of lumiracoxib vs. the combined non-selective NSAIDs was also seen in the overall study population (including patients taking low-dose aspirin). Furthermore, the risk of upper GI tract (UGIT) ulcer complications and/or symptomatic ulcers [perforations, ulcers, and bleeds (PUBs)] was significantly lower with lumiracoxib vs. non-selective NSAIDs in patients not taking low-dose ASA and in the overall study population. In the TARGET study, the GI benefit of lumiracoxib versus non-selective NSAIDs was decreased when low-dose ASA treatment was added. Consequently, the reduction in serious GI adverse events was not statistically significant for lumiracoxib compared to non-selective NSAIDs in patients taking both lumiracoxib and low-dose ASA. However, both for POBs and PUBs, there was a consistent numerical advantage for lumiracoxib compared to either non-selective NSAIDs in the subgroup of patients taking ASA simultaneously with lumiracoxib.

2) Fewer hypertensive adverse events compared to other NSAIDs
In the TARGET study, the incidence rates of increases in mean systolic or diastolic blood pressure were significantly less with a four-fold supra-therapeutic dose of 400 mg lumiracoxib o.d. compared to ibuprofen or naproxen. Furthermore, there was a significantly lower incidence rate of de novo or aggravated hypertensive AEs with lumiracoxib compared to ibuprofen.

Hypertension was also less frequently reported with 100 mg lumiracoxib o.d. compared to 200 mg celecoxib o.d. in long-term OA studies. In combined short and long-term OA/RA studies, hypertension was reported with a similar frequency for both 100 mg lumiracoxib o.d. and 200 mg celecoxib o.d., but was reported with a lower frequency for 100 mg lumiracoxib o.d. compared to non-selective NSAIDs.

In the one-year OA studies with lumiracoxib at a daily dose of 100 mg, hypertension and edema were observed in 3.3% and 2.6% of patients, respectively. In the TARGET study, the rates of hypertension in the overall patient population taking 400 mg lumiracoxib o.d. and common therapeutic doses of naproxen and ibuprofen were 5.1%, 5.6%, and 7.2%, respectively. These differences were not statistically significant, except for lumiracoxib vs. ibuprofen. The corresponding rates for edema were 3.6%, 3.1%, and 4.3%, respectively.

3) No statistically significant increase in cardiovascular risk relative to other currently authorised NSAIDs
No increase in the risk of myocardial infarction (MI), cardiovascular (CV) death, or stroke was observed with lumiracoxib compared to placebo in short-term OA studies (up to 13 weeks). Fewer CV ischemic events were reported with 100 mg lumiracoxib o.d. compared to 200 mg celecoxib o.d. in both short and long-term (up to one year) OA studies.

In the TARGET study, the treatment groups demonstrated no significant differences in the total number of patients with confirmed or probable cardio- and cerebro-vascular severe adverse events (SAEs). The incidence of the APTC (Anti-Platelet Trialists' Collaboration) composite CV endpoint (including the incidence of clinical or silent MI, stroke, and CV death) with a four-fold supra-therapeutic dose of 400 mg lumiracoxib o.d. was not statistically significantly different from that with the non-selective NSAIDs naproxen and ibuprofen. For patients with pre-existing CV risks or those taking low dose aspirin, the risks of CV events with lumiracoxib were no greater than those with naproxen or ibuprofen. The incidence of MI was similar for lumiracoxib and ibuprofen whether the patients were receiving low-dose aspirin or not. An increase in the incidence of MI was observed for lumiracoxib when compared to naproxen in patients not receiving low-dose aspirin. However, this increase in the incidence of MI did not reach statistical significance and was not seen in patients receiving low-dose aspirin.

Both the long-term OA studies and the TARGET study were conducted for only one year and hence, the CV risk associated with the long-term use of lumiracoxib for more than one year, is still undetermined.

4) No increase in edema or hematological risk relative to other NSAIDs
Edema was less frequently reported with 100 mg lumiracoxib o.d. compared to non-selective NSAIDs in short-term OA studies. In long-term OA studies, the incidence of edema was similar for the two COX-2 selective inhibitors lumiracoxib (100 mg o.d.) and celecoxib (200 mg o.d.). In combined short- and long-term OA/RA studies, edema was reported less with 100 mg lumiracoxib o.d. and other selective COX-2 inhibitors compared to non-selective NSAIDs. In the TARGET study, edema was reported with similar frequencies in both naproxen and lumiracoxib patients but was slightly less frequent in patients treated with 400 mg lumiracoxib o.d. compared to patients treated with 800 mg ibuprofen t.i.d.

In short-term OA studies, less frequent decreases in hemoglobin, hematocrit, neutrophils, and lymphocytes were reported with lumiracoxib compared to non-selective NSAIDs. The percentage of patients with hematological abnormalities was slightly lower for 100 mg lumiracoxib o.d. compared to 200 mg celecoxib o.d. in long-term OA studies.

5) No increase in serious skin adverse reactions compared to other NSAIDs and no new safety concerns
There was no incidence of serious skin adverse reactions in pre-approval clinical studies with lumiracoxib, but a few cases of serious skin reaction have been reported with lumiracoxib in the post-marketing experience. No additional risks or new types of safety problems have been identified, other than those already known and labelled as drug class effects of NSAIDs or COX-2 inhibitors.

6) An increased risk of liver abnormalities compared to other NSAIDs
Elevations in liver enzymes are a drug class effect for NSAIDs which can signal more serious liver problems. Hepatic toxicity, as indicated by elevations in liver transaminases ALT and/or AST, was noted more frequently with lumiracoxib compared to other NSAIDs in some clinical trials (long term studies at 200 and 400 mg o.d. lumiracoxib). In long-term pooled OA studies, notable elevations in ALT and alkaline phosphatase were slightly more frequent with 100 mg lumiracoxib o.d. compared to 200 mg celecoxib o.d. Increases in hepatic function enzymes were also more frequent with 200 and 400 mg lumiracoxib o.d. compared to 100 mg lumiracoxib o.d. and 200 mg celecoxib o.d. In the combined short- and long-term OA/RA studies, notable elevations and shifts from normal to high post-baseline ALT values were more frequent with all lumiracoxib doses (with a dose related trend) than with non-selective NSAIDs, other COX-2 inhibitors, or placebo.

In the TARGET study, 400 mg lumiracoxib o.d., a four-fold supra-therapeutic dose, was more hepatotoxic than the non-selective NSAID comparators naproxen and ibuprofen. ALT/AST elevations were seen in 2.6% of patients treated with Prexige compared to 0.6% of patients treated with NSAIDs. Six patients treated with 400 mg lumiracoxib o.d. had adjudicated serious hepatic AEs (significant elevations in liver function parameters accompanied by a concomitant increase in bilirubin). There were no instances of hepatic failure. After study medication withdrawal all of the patients fully recovered.

In general, lumiracoxib at a four-fold supra-therapeutic dose of 400 mg o.d. induced a higher frequency of adverse liver reactions compared to the 100 mg o.d. lumiracoxib dose and 200 mg celecoxib o.d. At 12 months, the percentage of patients with ALT >3 x ULN was 0.9% for the lumiracoxib 100 mg o.d. and 0.4% for celecoxib 200 mg o.d. groups and 2.6% and 2.2% for lumiracoxib 200 mg o.d. and 400 mg o.d., respectively (supra-therapeutic doses). For AST, the percentage of patients with notable abnormalities tended to be slightly higher in the lumiracoxib 200 mg o.d. group.

7) An increased potential for kidney dysfunction
Decreased renal function is a drug class effect for NSAIDs. Renal toxicity, as indicated by elevations in serum creatinine and decreases in creatinine clearance, was observed more frequently with lumiracoxib compared to some NSAIDs in the clinical studies. In short-term OA studies, elevations in serum creatinine were similar for 100 mg lumiracoxib o.d. and non-selective NSAIDs, but were higher for 100 mg lumiracoxib o.d. compared to 200 mg celecoxib o.d. In both short- and long-term OA/RA studies, the incidence of serum creatinine elevation >35.36 µmol/L above baseline was higher for 100 mg lumiracoxib o.d. compared to 200 mg celecoxib o.d. and displayed dose-dependent increases with increasing doses of lumiracoxib. More frequent increases in serum creatinine >35.36 µmol/L above baseline and more frequent decreases in creatinine clearance <81 mL/min, as well as similar decreases in creatinine clearance <30 mL/min (0.3% lumiracoxib 100 mg o.d. vs. 0.3% celecoxib 200 mg o.d.), were noted for 100 mg lumiracoxib o.d. compared to 200 mg celecoxib o.d. in combined short- and long-term OA/RA studies. In some clinical studies, decreased creatinine clearance and hyperkalemia were observed more frequently with 100 mg lumiracoxib o.d., whereas increased creatinine, BUN, and potassium values were more common in the All NSAIDs group. Mean increases from baseline creatinine levels tended to be lower in the lumiracoxib groups and highest in the All NSAID group.

In the TARGET study, although there was no statistically significant difference in the incidence of major renal events between the treatment groups, the increases in serum creatinine ≥100% above baseline were statistically significantly less frequent with naproxen compared to lumiracoxib, but there was no significant difference between lumiracoxib and ibuprofen. Increases in serum creatinine  100% and/or urine protein >3g/L, which were defined as major renal events in the study, were more frequent with 400 mg lumiracoxib o.d., a four-fold supra-therapeutic dose, compared to 500 mg naproxen b.i.d. or 800 mg ibuprofen t.i.d. Increases in serum creatinine >35.36 µmol/L above baseline were also more frequent with lumiracoxib compared to the two non-selective NSAIDs, and the difference was statistically significant for lumiracoxib vs. naproxen but not for lumiracoxib vs. ibuprofen.

3.4 Benefit/Risk Assessment and Recommendation

3.4.1 Benefit/Risk Assessment

The submitted clinical studies have shown that 100 mg lumiracoxib o.d. provides clinically relevant symptom relief in knee OA which is comparable to that of 200 mg celecoxib o.d.

Compared to non-selective NSAIDs, the benefits of lumiracoxib include a greatly reduced frequency of GI complicated AEs (the source of the largest morbidity with NSAIDs), fewer hypertensive AEs, no significant increase in CV risk, no increase in edema or hematological risk, and no increase in serious skin adverse reactions. Set against these benefits are a dose-proportional increased risk of liver abnormalities (more evident at 400 mg - a four-fold supra-therapeutic dose) and a dose-dependent increased potential for renal dysfunction (more evident at 400 mg - a four-fold supra-therapeutic dose).

Overall, the benefit-risk assessment for lumiracoxib is positive and favours 100 mg lumiracoxib o.d. over non-selective NSAIDs, mainly due to the clinical relevance of the greatly improved GI tolerability and the absence of a statistically significant increase in CV risk compared to other NSAIDs.

The sponsor has submitted a Pharmacovigilance Plan (PVP) with a strong commitment for monitoring the post-marketing safety of lumiracoxib. The plan contains a prospective Phase IV observational study which will compare the safety of lumiracoxib to that of other selective and non-selective NSAIDs in the Canadian population for 24 months. The PVP, with its different commitments, has been reviewed by Health Canda and found to be acceptable.

3.4.2 Recommendation

Based on the Health Canada review of data on quality, safety and effectiveness, Health Canada considers that the benefit/risk profile of Prexige* is favourable for the acute and chronic treatment of the signs and symptoms of osteoarthritis of the knee in adults. The New Drug Submission complies with the requirements of sections C.08.002 and C.08.005.1 and therefore Health Canada has granted the Notice of Compliance pursuant to section C.08.004 of the Food and Drug Regulations.

4 Submission Milestones

Submission Milestones: Prexige

Submission MilestoneDate
Control No. 082754: Submission filed2003-02-19
Screening 1
Screening Deficiency Notice issued2003-04-02
Response filed2003-04-29
Screening Acceptance Letter issued2003-05-06
Review 1
Biopharmaceutics Evaluation complete2004-02-27
Quality Evaluation complete2003-11-17
Clinical Evaluation complete2004-02-25
NON issued by Director General (clinical and biopharmaceutics issues)2004-03-01
Response filed2004-06-01
Screening 2
Screening Acceptance Letter issued2004-07-14
Review 2
Biopharmaceutics Evaluation complete2004-07-23
Quality Evaluation complete2004-10-01
Clinical Evaluation complete2004-12-08
NON/W issued by Director General2004-12-10
Pre-submission meeting2005-09-25
Control No. 102465: Submission re-filed2005-11-15
Screening
Screening Acceptance Letter issued2006-01-06
Review
Quality Evaluation complete2006-10-27
Clinical Evaluation complete2006-11-02
Biostatistics Evaluation complete2006-04-12
Labelling Review complete2006-11-02
NOC issued by Director General2006-11-02