Summary Basis of Decision for Cotellic
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:
Summary Basis of Decision (SBD) documents provide information related to the original authorization of a product. The SBD for Cotellic is located below.
Recent Activity for Cotellic
The SBDs written for eligible drugs (as outlined in Frequently Asked Questions: Summary Basis of Decision [SBD] Project: Phase II) approved after September 1, 2012 will be updated to include post-authorization information. This information will be compiled in a Post-Authorization Activity Table (PAAT). The PAAT will include brief summaries of activities such as submissions for new uses of the product, and whether Health Canada's decisions were negative or positive. The PAATs will be updated regularly with post-authorization activity throughout the product life cycle.
Post-Authorization Activity Table (PAAT) for Cotellic
Updated: 2025-10-10
The following table describes post-authorization activity for Cotellic, a product which contains the medicinal ingredient cobimetinib. For more information on the type of information found in PAATs, please refer to the Frequently Asked Questions: Summary Basis of Decision (SBD) Project: Phase II and to the List of abbreviations found in Post-Authorization Activity Tables (PAATs).
For additional information about the drug submission process, refer to the Guidance Document: The Management of Drug Submissions and Applications.
Drug Identification Number (DIN):
- DIN 02452340 – 20 mg cobimetinib, tablet, oral administration
Post-Authorization Activity Table (PAAT)
| Activity/submission type, control number | Date submitted | Decision and date | Summary of activities |
|---|---|---|---|
| SNDS # 265306 | 2022-06-21 | Issued NOC 2023-03-28 | Submission filed as a Level I – Supplement to update the PM with pediatric data and to migrate the PM to the 2020 format. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Warnings and Precautions, Adverse Reactions, Clinical Pharmacology, and Clinical Trials sections of the PM, and corresponding changes were made to Part III: Patient Medication Information and to the package insert. An NOC was issued. |
| NC # 209926 | 2017-10-05 | Issued NOL 2018-01-05 |
Submission filed as a Level II (90 day) Notifiable Change (Risk Management Change) to update the PM with new safety information. As a result of the NC, modifications were made to the Warnings and Precautions, and Adverse Reactions sections of the PM, and corresponding changes were made to the PM Part III: Patient Medication Information. The submission was reviewed and considered acceptable, and an NOL was issued. |
| SNDS # 196612 | 2016-07-07 | Issued NOC 2017-06-01 |
Submission filed as a Level I - Supplement to provide a safety and efficacy update to the PM based on longer term follow up of patients in the pivotal trial and a supportive study. In addition, a new pharmacokinetic study in subjects with hepatic impairment was submitted to support dosing recommendation in this patient population. The benefit/risk profile for Cotellic remains positive when used for its approved indication. The submission review resulted in changes to the Serious Warnings and Precautions Box, Warnings and Precautions, Adverse Reactions, and Dosage and Administration sections of the PM, and corresponding changes were made to the PM Part III: Consumer Information. The submission was reviewed and considered acceptable, and an NOC was issued. |
| Drug Recall posted | Not applicable | Posted 2017-03-20 |
Drug Recall posted containing product safety information for healthcare professionals, hospitals, and the general public. |
| NC # 199785 | 2016-10-27 | Issued NOL 2017-02-03 |
Submission filed as a Level II (90 day) Notifiable Change (Risk Management Change) to update the PM to reflect revisions in the company core data sheet. As a result of the NC, modifications were made to the Warnings and Precautions, Adverse Reactions, and Dosage and Administration sections of the PM, and corresponding changes were made to the PM Part III: Consumer Information. The submission was reviewed and considered acceptable, and an NOL was issued. |
| SNDS # 199094 | 2016-10-14 | Issued NOL 2016-12-16 |
Submission filed as a Level I -- Supplement to make changes to the Cotellic outer and inner labels. The labels were reviewed and considered acceptable, and an NOC was issued. |
| NC # 195607 | 2016-05-31 | Issued NOL 2016-09-09 |
Submission filed as a Level II (120 day) Notifiable Change to update the PM with revised information. As a result of the NC, modifications were made to the Action and Clinical Pharmacology section of the PM. The submission was reviewed and considered acceptable, and an NOL was issued. |
| Drug product (DIN 02452340) market notification | Not applicable | Date of first sale: 2016-04-06 |
The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations. |
| NDS # 182788 | 2015-03-12 | Issued NOC 2016-02-22 |
Notice of Compliance issued for New Drug Submission. |
Summary Basis of Decision (SBD) for Cotellic
Date SBD issued: 2016-03-30
The following information relates to the New Drug Submission for Cotellic.
Cobimetinib, 20 mg cobimetinib (as cobimetinib fumarate), tablet, oral
Drug Identification Number (DIN):
- 02452340
Hoffmann-La Roche Ltd.
New Drug Submission Control Number: 182788
On February 22, 2016, Health Canada issued a Notice of Compliance to Hoffmann-La Roche Limited for the drug product Cotellic.
The market authorization was based on quality (chemistry and manufacturing), non-clinical (pharmacology and toxicology), and clinical (pharmacology, safety, and efficacy) information submitted. Based on Health Canada's review, the benefit/risk profile of Cotellic in combination with vemurafenib is favourable for the treatment of patients with unresectable or metastatic melanoma with a BRAF V600 mutation.
1 What was approved?
Cotellic, a protein kinase inhibitor, was authorized for use in combination with vemurafenib for the treatment of patients with unresectable or metastatic melanoma with a BRAF V600 mutation.
Prior to initiation of treatment with Cotellic in combination with vemurafenib, patients must have BRAF V600 mutation-positive melanoma tumour status confirmed by a validated test.
Effectiveness of Cotellic in combination with vemurafenib is based on progression-free survival and objective response rate results. Prolongation of overall survival has not been demonstrated.
Clinical data supporting the effectiveness of Cotellic in combination with vemurafenib in patients with a BRAF V600K mutation are limited. There are no clinical data for other less common BRAF V600 mutations.
There are no clinical data to support the effectiveness of Cotellic in combination with vemurafenib in patients with non-cutaneous malignant melanoma.
The safety and efficacy of Cotellic in children and adolescents have not been established.
Cotellic is contraindicated for patients with a known hypersensitivity to cobimetinib or any of the excipients. Cotellic was approved for use under the conditions stated in the Cotellic Product Monograph taking into consideration the potential risks associated with the administration of this drug product.
Cotellic (20 mg cobimetinib, as cobimetinib fumarate) is presented as a tablet. In addition to the medicinal ingredient, the tablet contains croscarmellose sodium, lactose monohydrate, magnesium stearate, microcrystalline cellulose, polyethylene glycol 3350, polyvinyl alcohol, talc, and titanium dioxide.
For more information, refer to the Clinical, Non-Clinical, and Quality (Chemistry and Manufacturing) Basis for Decision sections.
Additional information may be found in the Cotellic Product Monograph, approved by Health Canada and available through the Drug Product Database.
2 Why was Cotellic approved?
Health Canada considers that the benefit/risk profile of Cotellic in combination with vemurafenib is favourable for the treatment of patients with unresectable or metastatic melanoma with a BRAF V600 mutation.
Cotellic (cobimetinib) is a reversible protein kinase inhibitor which inhibits the mitogen-activated protein kinase (MAPK)/extracellular signal-regulated kinase 1 (MEK1) and MEK2. MEK proteins are upstream regulators of the extracellular signal related kinase (ERK) pathway, which promotes cellular proliferation. BRAF V600 mutations result in constitutive activation of the BRAF pathway which includes MEK1 and MEK2. In vitro, cobimetinib inhibited MEK1 and MEK2 with half maximal inhibitory concentration (IC50) values of 0.95 nM and 199 nM, respectively.
Vemurafenib, marketed as Zelboraf, is also a kinase inhibitor which affects a different part of the same pathway and was authorized by Health Canada in 2012 as a monotherapy for the treatment of BRAF V600 mutation-positive unresectable or metastatic melanoma. Vemurafenib, a BRAF inhibitor, slows down or stops the growth of melanoma tumour cells expressing mutated BRAF V600 proteins. Using both cobimetinib and vemurafenib has the potential to further slow down or stop the growth of BRAF V600 mutation-positive melanoma tumours.
Melanoma was ranked seventh among both sexes in percent distribution of estimated new cancer cases in Canada in 2015. Approximately 20% of patients with early-stage melanoma eventually develop metastatic melanoma in which long-term survival is <10%. Approximately 50% of all melanomas harbor an activating mutation in BRAF, a serine-threonine kinase. In metastatic melanoma, approximately 90% of the BRAF mutations occur in codon V600.
Therapies currently approved in Canada for BRAF V600 mutation-positive unresectable or metastatic melanoma include cytotoxic chemotherapies, the targeted cancer therapies of Zelboraf (vemurafenib) monotherapy, Mekinist (trametinib) monotherapy, Tafinlar (dabrafenib) monotherapy, Tafinlar plus trametinib as combination therapy, and the immunotherapeutic agent Yervoy (ipilimumab). An additional immunotherapeutic agent, Keytruda (pembrolizumab) was approved for the same indication following ipilimumab therapy and following a BRAF inhibitor or MEK inhibitor. Randomized studies have shown that BRAF or MEK targeted monotherapies are superior to cytotoxic chemotherapies and combined BRAF and MEK inhibition is superior to BRAF inhibitor alone in advanced BRAF mutated melanoma.
Cotellic (a MEK inhibitor), in combination with vemurafenib (a BRAF inhibitor) has been shown to be efficacious in patients with unresectable or metastatic melanoma with a BRAF V600 mutation. The market authorization of Cotellic was based on a pivotal Phase III, multicentre, randomized, double-blind placebo-controlled study where Cotellic in combination with vemurafenib was compared to vemurafenib plus placebo, in patients with previously untreated BRAF V600 mutation-positive unresectable locally advanced (stage IIIc) or metastatic melanoma (stage IV).
Cotellic in combination with vemurafenib showed a statistically significant increase in median Progression-Free Survival (PFS) and objective response rate (ORR) as compared to placebo in combination with vemurafenib in adult patients with previously untreated BRAF V600 mutation-positive unresectable locally advanced or metastatic melanoma. The median PFS was 9.9 months in patients who received Cotellic and vemurafenib versus 6.2 months in patients who received placebo and vemurafenib. In the Cotellic plus vemurafenib group, 67.6% of patients had an ORR (complete response or partial response) versus 44.8% in the placebo plus vemurafenib group. Median overall survival (OS) had not been reached in either treatment group at the time of the pre-specified interim OS analysis, and the analysis did not cross the pre-specified boundary for statistical significance. Clinical data supporting the effectiveness of Cotellic in combination with vemurafenib in patients with a BRAF V600K mutation are limited and there are no clinical data for other less common BRAF V600 mutations. The median duration of follow-up was only 7.3 months; however, Phase Ib study results which were generally consistent with those from the pivotal study provided a median follow-up time of 12.7 months.
Key safety issues included left ventricular dysfunction, haemorrhage (including major haemorrhage), serous retinopathy and retinal vein occlusion, hypertension, hepatotoxicity, hypersensitivity, increased serum creatine phosphopkinase (CPK) levels and rhabdomyolysis, photosensitivity, and rash. Additional common adverse events that occurred with greater frequency in the Cotellic plus vemurafenib group were diarrhea, nausea, vomiting, pyrexia, blurred vision, dehydration, hypophosphatemia, hyponatremia, basal cell carcinoma, hyperglycemia, atrial fibrillation, visual impairment, and pneumonitis. Adverse events were monitored for and managed using treatment interruption, dose reduction, and treatment discontinuation. The majority of adverse events were not severe. Severe events often improved or resolved with dose modification. However, clinically important groups of patients were not enrolled in the pivotal study, including those with left ventricular ejection fraction (LVEF) below the institutional lower limit of normal or below 50%, symptomatic congestive heart failure of New York Heart Association (NYHA) class 2 or higher, QTcF >450 msec, or uncontrolled hypertension ≥Grade 2, significant hepatic impairment, and patients with retinal pathology on ophthalmologic examination that is considered a risk factor for neurosensory retinal detachment, retinal vein occlusion (RVO), or neovascular macular degeneration. Warnings of left ventricular dysfunction, hemorrhage (including major hemorrhage), serous retinopathy, and retinal vein occlusion have been included in a Serious Warnings and Precautions box in the Cotellic Product Monograph. Also included in the Serious Warnings and Precautions box are warning statements that Cotellic has not been studied in patients with moderate and severe hepatic impairment, that Cotellic should not be used concomitantly with a strong or moderate cytochrome P450 (CYP) 3A inhibitor, and that Cotellic in combination with vemurafenib should be prescribed and supervised by a qualified physician experienced in the use of anti-cancer agents.
A Risk Management Plan (RMP) for Cotellic was submitted by Hoffmann-La Roche Limited to Health Canada. Upon review, a revised RMP was requested. The RMP is designed to describe known and potential safety issues, to present the monitoring scheme and when needed, to describe measures that will be put in place to minimize risks associated with the product.
Health Canada reviewed the Look-alike Sound-alike Report submitted by the sponsor and accepted the proprietary name for the drug product.
The efficacy of Cotellic combined with vemurafenib is supported by a manageable safety profile. Risk mitigation strategies have been incorporated into the Cotellic Product Monograph to communicate the key safety issues that have been observed, provide guidance with regard to monitoring and laboratory tests, and provide comprehensive guidance with regard to dose modifications associated with adverse events. Appropriate labelling is in place with respect to the potential for clinically significant drug-drug interactions with CYP3A inhibitors and to address the limited data establishing safe use in patients with hepatic impairment.
Based on the data reviewed, the benefit-risk assessment is considered to be positive. Efficacy has been demonstrated and toxicity is considered tolerable and manageable. The combination of Cotellic and vemurafenib represents an effective addition to the currently approved therapeutic options for patients with advanced BRAF-mutated melanoma.
This 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. For more information, refer to the Clinical, Non-Clinical, and Quality (Chemistry and Manufacturing) Basis for Decision sections.
3 What steps led to the approval of Cotellic?
The sponsor filed a request for Priority Review Status under the Priority Review Policy for the review of the new drug submission (NDS) for Cotellic. An assessment was conducted to determine if sufficient evidence was provided demonstrating that the drug provides:
- An effective treatment, prevention or diagnosis of a disease or condition for which no drug is presently marketed in Canada; or
- A significant increase in efficacy and/or significant decrease in risk such that the overall benefit/risk profile is improved over existing therapies, preventatives or diagnostic agents for a disease or condition that is not adequately managed by a drug marketed in Canada.
The efficacy results provided from the pivotal study did not provide evidence of a significant increase in efficacy over existing therapies. In addition, the safety data provided did not provide evidence of a significant decrease in risk compared with other existing therapeutic options. For these reasons, Health Canada made the decision that the submission did not meet the criteria for Priority Review and therefore the request was denied. The submission was subsequently filed and reviewed as a regular NDS.
Submission Milestones: Cotellic
| Submission Milestone | Date |
|---|---|
| Request for priority status | |
| Filed: | 2015-01-16 |
| Rejection issued by Director, Bureau of Metabolism, Oncology, and Reproductive Sciences: | 2015-02-20 |
| Submission filed: | 2015-03-12 |
| Screening | |
| Screening Acceptance Letter issued: | 2015-04-29 |
| Review | |
| Quality Evaluation complete: | 2016-02-19 |
| Biopharmaceutics Evaluation complete: | 2016-01-06 |
| Clinical Evaluation complete: | 2016-02-20 |
| Labelling Review complete: | 2016-02-19 |
| Notice of Compliance (NOC) issued by Director General: | 2016-02-22 |
The Canadian regulatory decision on the non-clinical and clinical review of Cotellic was based on a critical assessment of the Canadian data package. The foreign reviews completed by the United States Food and Drug Administration (FDA) were used as an added reference.
For additional information about the drug submission process, refer to the Management of Drug Submissions Guidance.
4 What follow-up measures will the company take?
6 What other information is available about drugs?
Up to date information on drug products can be found at the following links:
- See MedEffect Canada for the latest advisories, warnings and recalls for marketed products.
- See the Notice of Compliance (NOC) Database for a listing of the authorization dates for all drugs that have been issued an NOC since 1994.
- See the Drug Product Database (DPD) for the most recent Product Monograph. The DPD contains product-specific information on drugs that have been approved for use in Canada and have been market notified (that is, the company has told Health Canada the product is being marketed).
- See the Notice of Compliance with Conditions (NOC/c)-related documents for the latest fact sheets and notices for products which were issued an NOC under the Notice of Compliance with Conditions (NOC/c) Guidance Document, if applicable. Clicking on a product name links to (as applicable) the Fact Sheet, Part III: Patient Medication Information, Qualifying Notice, and Dear Health Care Professional Letter.
- See the Patent Register for patents associated with medicinal ingredients, if applicable.
- See the Register of Innovative Drugs for a list of drugs that are eligible for data protection under C.08.004.1 of the Food and Drug Regulations, if applicable.
7 What was the scientific rationale for Health Canada's decision?
7.1 Clinical Basis for Decision
Clinical Pharmacology
The clinical pharmacology program for Cotellic included reports on human pharmacodynamic and pharmacokinetic studies. The clinical pharmacological data support the use of Cotellic for the specified indication.
Cotellic (cobimetinib) is a reversible inhibitor of the mitogen-activated protein kinase (MAPK)/extracellular signal-regulated kinase 1 (MEK1) and MEK2. MEK proteins are upstream regulators of the extracellular signal related kinase (ERK) pathway, which promotes cellular proliferation. In vitro, cobimetinib inhibited MEK1 and MEK2 with half maximal inhibitory concentration (IC50) values of 0.95 nM and 199 nM, respectively.
The major pathways of metabolism for cobimetinib are oxidation by the cytochrome P450 (CYP) enzymes CYP3A4 and CYP3A5, and glucuronidation by UDP-Glucuronosyltransferase 2 Family, Polypeptide B7 (UGT2B7), therefore cobimetinib has the potential for drug-drug interactions with CYP3A modulators. Coadministration of cobimetinib with a strong CYP3A inhibitor (itraconazole) resulted in a significant increase in cobimetinib exposure (a 6.7-fold increase).The effect of strong and moderate CYP3A inhibitors on the increased exposure of cobimetinib is of clinical significance and they should not be used concomitantly with Cotellic. An appropriate warning is included in the Serious Warnings and Precautions box in the Cotellic Product Monograph.
Study results have also suggested that strong and moderate inducers of CYP3A (rifampicin and efavirenz) could decrease cobimetinib system exposure by 83% and 72%, respectively. Therefore, co-administration of cobimetinib with strong or moderate CYP3A inducers should be avoided.
The pharmacokinetics of cobimetinib have not been studied in patients with moderate to severe hepatic impairment; therefore, no dosing recommendations have been established for Cotellic in these patients. Given that cobimetinib is metabolized and eliminated via the liver, patients with hepatic impairment may have increased exposure. The precaution that Cotellic has not been studied in patients with moderate and severe hepatic impairment has been included within the Serious Warnings and Precautions box in the Cotellic Product Monograph.
The sponsor submitted the results of a food effect study comparing the bioavailability of a prototype of the Cotellic commercial tablet formulation following its administration in the fasted and high-fat fed states in healthy volunteers. There were excipient changes in formulation between the prototype of Cotellic used in this study and the final commercial tablet formulation; however, the commercial formulation of Cotellic was used during the pivotal Phase III clinical study, during which product administration was conducted without regards to food, consistent with the dosing administration instructions in the Cotellic Product Monograph. The results of the food effect study met standards for bioequivalence, indicating that the rate and extent of absorption of cobimetinib were not significantly different when the proposed Cotellic prototype tablets were administered under standard fasting and high-calorie, high-fat fed conditions.
For further details, please refer to the Cotellic Product Monograph, approved by Health Canada and available through the Drug Product Database.
Clinical Efficacy
The clinical efficacy of Cotellic in combination with vemurafenib for the treatment of adult patients with BRAF V600-mutation positive unresectable or metastatic melanoma was evaluated in a pivotal Phase III Study GO28141 (coBRIM) and in a supportive Phase Ib Study NO25395 (BRIM7). Clinical data to support the efficacy of Cotellic monotherapy were limited to a small number of patients with advanced melanoma treated in a Phase I study. No further monotherapy studies are planned and monotherapy is not recommended for the treatment of patients with advanced melanoma.
Study G028141 was an international, multicentre randomized (1:1), double-blind, placebo-controlled Phase III study conducted in patients with previously untreated BRAF V600 mutation-positive unresectable locally advanced or metastatic melanoma. Eligible patients were randomized to receive Cotellic in combination with vemurafenib (number of patients [n] = 247) or to receive placebo in combination with vemurafenib (n = 248). The Cotellic plus vemurafenib group received Cotellic 60 mg once daily on Days 1-21 of each 28-day treatment cycle and 960 mg vemurafenib twice daily on Days 1-28. The placebo plus vemurafenib group received placebo once daily on Days 1-21 of each 28-day treatment cycle and 960 mg vemurafenib twice daily on Days 1-28.
Overall, demographic characteristics and patient baseline disease characteristics were well balanced between the two treatment groups. Key baseline characteristics included: 58% of patients were male, 93% reported White race, median age was 55 years (range 23-88 years), 60% had metastatic melanoma stage M1c, Eastern Cooperative Oncology Group performance status was 0 in 72% and 1 in 28%, serum lactate dehydrogenase was elevated in 45%, prior adjuvant therapy had been administered to 10%, and <1% had previously-treated brain metastases.
Treatment continued until disease progression, death, unacceptable toxicity, or withdrawal of consent, whichever occurred earliest. Patients in the placebo plus vemurafenib group were not eligible to cross over to the Cotellic plus vemurafenib group at disease progression.
The primary efficacy endpoint was progression-free survival (PFS) as assessed by the investigator (Inv) using Response Evaluation Criteria In Solid Tumors (RECIST) version 1.1. Secondary efficacy endpoints included overall survival (OS), objective response rate (ORR), and PFS as assessed by a blinded independent review facility (IRF). Global health status/health-related quality of life by patient-report was an additional secondary efficacy endpoint. This endpoint was measured for each treatment group using the European Organisation for Research on the Treatment of Cancer (EORTC) Quality of Life Questionnaire (QLQ-C30).
Cotellic in combination with vemurafenib demonstrated a statistically significant increase in PFS (Inv) with a hazard ratio of 0.51 (95% confidence interval [CI] 0.39-0.68, p<0.0001). The median PFS (Inv) was 9.9 months for the Cotellic plus vemurafenib group versus 6.2 months for the placebo plus vemurafenib group. The effect on PFS was also supported by the analysis of PFS (IRF). The PFS (Inv) benefit for Cotellic in combination with vemurafenib was observed in pre-specified BRAF V600 mutation subgroups (V600E and V600K).
The ORR (complete response or partial response) in the Cotellic plus vemurafenib group was 67.6% of patients versus 44.8% in the placebo plus vemurafenib group. A pre-specified interim OS analyses was performed at the time of the primary PFS analysis. Median OS had not been reached in either treatment group and the analysis did not cross the pre-specified boundary for statistical significance. A clinically meaningful change between the two treatment groups was not demonstrated in quality of life.
Study NO25395 was designed to assess the safety, tolerability, pharmacokinetics and efficacy of Cotellic when combined with vemurafenib for the treatment of patients with BRAF V600 mutation-positive unresectable or metastatic melanoma. A total of 129 patients were enrolled, 63 were BRAF inhibitor therapy naïve (BRAFi-naïve) and 66 had previously progressed on prior vemurafenib therapy (vemurafenib-progressive disease [PD]). BRAFi-naïve patients achieved an 87% ORR, including complete response in 10% of patients, and a median PFS of 13.7 months. Vemurafenib-PD patients achieved a 15% ORR, all partial responses, and a median PFS of 2.8 months. A total of 66 patients in this study were treated with the recommended dose and schedule, 39 of whom were BRAFi-naïve and 27 of whom were vemurafenib-PD. In this subgroup, BRAFi-naïve patients achieved an 85% ORR and median PFS of 12.7 months; and vemurafenib-PD patients achieved a 26% ORR and median PFS of 2.8 months.
Efficacy Limitations
Clinical data supporting the efficacy of Cotellic in combination with vemurafenib in patients with a BRAF V600K mutation are limited and there are no clinical data for other less common BRAF V600 mutations. This lack of data is communicated in the Indications and Clinical Use section of the Cotellic Product Monograph; however, inclusion of all BRAF V600 mutations (V600E, V600K, and other rare mutations) in the indication is considered reasonable.
Patients with active central nervous system lesions were excluded from the Phase III study, and <1% of enrolled patients had previously treated brain metastases. A tissue distribution study conducted in rats demonstrated low levels of cobimetinib in central nervous system tissues protected by the blood-brain barrier. As a result, a warning was placed in the Cotellic Product Monograph stating that Cotellic is not recommended for patients with BRAF V600 mutation-positive melanoma who have active untreated brain metastases.
Patients with non-cutaneous malignant melanoma were not enrolled in clinical studies; however, these patients are rare and it can be anticipated that similar biological activity would be observed.
The efficacy of the addition of Cotellic in patients who have progressed on vemurafenib has not been established. The efficacy results in the Phase Ib study N025395 reported fewer responses and shorter PFS for the subgroup with vemurafenib-PD compared with the BRAFi-naïve group. Furthermore, the pivotal Phase III study G028141, by design, excluded patients who had progressed on a prior BRAF inhibitor, and did not allow patients in the vemurafenib plus placebo arm to cross over to the vemurafenib plus Cotellic group at disease progression. Thus, efficacy data from the Phase 1b study are not included in the Cotellic Product Monograph.
Indication
The sponsor proposed the following indication:
Cotellic (cobimetinib) is indicated for use in combination with Zelboraf (vemurafenib) for the treatment of patients with unresectable or metastatic melanoma with BRAF V600 mutation.
Patients treated with Cotellic in combination with Zelboraf must have BRAF V600 mutation-positive melanoma tumour status confirmed by a validated test.
Health Canada recommended the following indication in order to communicate additional limitations of usefulness and situations where use of the product is not therapeutically appropriate:
Cotellic (cobimetinib) is indicated for use in combination with vemurafenib for the treatment of patients with unresectable or metastatic melanoma with a BRAF V600 mutation.
Prior to initiation of treatment with Cotellic in combination with vemurafenib, patients must have BRAF V600 mutation-positive melanoma tumour status confirmed by a validated test.
Effectiveness of Cotellic in combination with vemurafenib is based on progression-free survival (PFS) and objective response rate (ORR) results. Prolongation of overall survival (OS) has not been demonstrated.
Clinical data supporting the effectiveness of Cotellic in combination with vemurafenib in patients with a BRAF V600K mutation are limited. There are no clinical data for other less common BRAF V600 mutations.
There are no clinical data to support the effectiveness of Cotellic in combination with vemurafenib in patients with non-cutaneous malignant melanoma.
For more information, refer to the Cotellic Product Monograph, approved by Health Canada and available through the Drug Product Database.
Clinical Safety
The clinical safety of Cotellic in combination with vemurafenib at the recommended dose and schedule was primarily based on data from the safety population in the pivotal Phase III Study GO28141 (n = 254). For patients in the Cotellic in combination with vemurafenib group, the median duration of Cotellic exposure was 179 days and the median duration of vemurafenib exposure was 183 days. Supportive safety data were provided from the Phase Ib Study N025395. Both studies are described in the Clinical Efficacy section.
Overall, the safety profile of Cotellic in combination with vemurafenib was tolerable and adverse events (AEs) were manageable with dosing modification and/or supportive care. In Study GO28141, the most common AEs (≥ 20%) that occurred with greater frequency in the Cotellic plus vemurafenib group were diarrhea, rash, nausea, increased blood creatine phosphokinase (CPK) levels, photosensitivity reaction, pyrexia, increased alanine transaminase (ALT) levels, increased aspartate aminotransferase (AST) levels, and vomiting. Diarrhea was the AE most commonly reported while taking Cotellic plus vemurafenib. The majority of AEs were Grade 1 or 2, and Grade 3 or 4 events were less common and were generally managed adequately with dose modification guidelines. There were few patients who experienced Grade 5 AEs, and for most patients the underlying disease was considered a contributing factor. Adverse events leading to permanent discontinuation of the combination were documented in 10.6% of patients receiving Cotellic plus vemurafenib compared with 7.1% of patients receiving placebo plus vemurafenib. Adverse events led to dose interruption or reduction of the combination in 42.1% of patients treated with Cotellic plus vemurafenib versus 32.6% treated with placebo plus vemurafenib.
The addition of Cotellic to vemurafenib attenuated the development of secondary cutaneous lesions such as squamous cell carcinomas and keratoacanthomas which are well-recognized toxicities associated with use of single-agent BRAF inhibitors such as vemurafenib. While the frequency of cutaneous squamous cell carcinomas and keratoacanthomas was decreased, the incidence of basal cell carcinomas was increased. Second primary melanoma occurred uncommonly and was reported at a decreased frequency compared with the placebo plus vemurafenib group.
Events of serous retinopathy and visual disturbances, elevations in CPK, and reductions in left ventricular ejection fraction (LVEF), all recognized effects of drugs that are MEK inhibitors, were observed with higher frequency in the Cotellic plus vemurafenib group compared with the placebo plus vemurafenib group. Rhabdomyolysis may also occur with Cotellic use. Retinal vein occlusion, observed with other MEK inhibitors and with vemurafenib, was reported in a single patient in each treatment group.
The incidence of severe photosensitivity, rash, and liver laboratory abnormalities (hepatotoxicity) was higher in the Cotellic plus vemurafenib group compared to the placebo plus vemurafenib group.
Hypertension and atrial fibrillation were also identified as clinically significant adverse drug reactions. The frequency of QT interval prolongation was comparable across treatment groups, as was the frequency of Grade ≥3 QTc prolongation group term events.
Bleeding events which included major hemorrhage, defined as symptomatic bleeding in a critical area or organ, were observed more frequent in the Cotellic plus vemurafenib group. In the Phase III study, Grade 3-5 hemorrhagic events were experienced by 1.6 % in the Cotellic plus vemurafenib group and 0.4% in the placebo plus in vemurafenib group.
Grade 3 hypersensitivity events were reported in 1.2% of the patients that received Cotellic in combination with vemurafenib compared with no such events in the placebo plus vemurafenib group.
Compared with patients <65 years old, more patients ≥65 years old experienced AEs that led to discontinuation of the treatment regimen and to dose modification of the treatment regimen. Increased sensitivity of some geriatric patients cannot be ruled out.
A thorough QT study was not conducted. Cotellic causes a decrease in heart rate and increases in the PR interval and QRS duration. In a Phase I, non-randomized, open-label, safety and pharmacokinetic dose-escalation and expansion study, 20 cancer patients received Cotellic at a dose of 60 mg/day for 28 day cycles (21 days on-treatment, 7 days off treatment).Serial electrocardiogram (ECG) recordings were performed on Day 21 (pre-dose, 1.5 h, 3 h, and 6 h) of Cycle 1, for 13 of the patients. Statistically significant decreases in heart rate from pre-treatment baseline were observed on Cycle 1, Day 21 at all time points, with a maximum mean decrease of -10.7 bpm at 1.5 h post-dosing. Statistically significant mean increases from baseline in the PR interval and QRS duration were observed at all time points on Day 21. The maximum mean increase in the PR interval was 15.0 ms at 3 h post-dosing and the maximum mean increase in the QRS duration was 5.8 ms at 1.5 h post-dosing. For the QTcF interval, the maximum mean increase from baseline was 1.2 ms. Based on these findings, revisions were made to the Cotellic Product Monograph to communicate that caution should be observed in patients with concurrent cardiac conditions or medications that affect heart rate or ECG parameters. Patients should be assessed for electrocardiogram intervals prior to initiating treatment and periodically during steady-state treatment with Cotellic.
Overall, Cotellic has a tolerable and manageable safety profile. Appropriate warnings and precautions are in place in the approved Cotellic Product Monograph to address the identified safety concerns. Warnings of left ventricular dysfunction, hemorrhage (including major hemorrhage), serous retinopathy, and retinal vein occlusion have been included in a Serious Warnings and Precautions box. Also included are warning statements that Cotellic has not been studied in patients with moderate and severe hepatic impairment, that Cotellic should not be used concomitantly with a strong or moderate cytochrome P450 (CYP) 3A inhibitor, and that Cotellic in combination with vemurafenib should be prescribed and supervised by a qualified physician experienced in the use of anti-cancer agents. To mitigate risk, the Monitoring and Laboratory Tests section of the Cotellic Product Monograph provides advice on monitoring patients who are taking Cotellic while the Dosage and Administration section of the Cotellic Product Monograph provides dose modification recommendations for concomitant drugs and for adverse drug reactions.
For more information, refer to the Cotellic Product Monograph, approved by Health Canada and available through the Drug Product Database.
7.2 Non-Clinical Basis for Decision
The sponsor submitted non-clinical pharmacology and safety pharmacology, pharmacokinetic, general toxicology, genetic toxicology, developmental toxicology and phototoxicity studies for the non-clinical review.
In vitro, cobimetinib was shown to be a selective inhibitor of MEK1 and MEK2. The combination of cobimetinib and vemurafenib demonstrated synergistic inhibition of cellular proliferation in vitro in BRAF V600E-mutant melanoma cell lines and demonstrated increased tumour growth inhibition in vivo compared to treatment with either inhibitor alone.
Cobimetinib is metabolized by CYP3A therefore concomitant use of Cotellic and drugs that strongly or moderately inhibit CYP3A can increase cobimetinib exposure. Appropriate warnings and precautions are in place in the Cotellic Product Monograph to address this identified safety concern. Cobimetinib is a substrate of efflux transporter P-glycoprotein (P-gp). The Cotellic Product Monograph communicates that concomitant use of Cotellic and drugs that inhibit P-gp may increase cobimetinib plasma concentrations.
The non-clinical toxicology profile of Cotellic (cobimetinib) was adequately characterized in the non-clinical studies in support of the specified clinical indication. A steep exposure-response was demonstrated in animals. In non-clinical toxicology studies, cobimetinib exhibited high systemic toxicity in animals. Mortality was observed in rats and dogs at plasma exposures below that observed in humans. The primary non-clinical toxicities included multiple-organ degeneration in rats and gastrointestinal degeneration in dogs. These findings were generally reversible upon discontinuation of cobimetinib administration and are considered clinically manageable. Cobimetinib also has the potential for embryo-fetal toxicity and impaired fertility, as such pregnancy while undergoing treatment with cobimetinib should be avoided. Cobimetinib was not genotoxic and demonstrated low potential for phototoxicity, cardiovascular, neurobehavioral, or respiratory effects in patients. In a non-clinical toxicology study, at exposures lower than those reported for adult humans administered the recommended dose of 60 mg, mortality was seen in juvenile rats approximately equivalent in age to 1-2 year old humans, the cause of which was not defined.
The results of the non-clinical studies as well as the potential risks to humans have been included in the Cotellic Product Monograph. In view of the intended use of Cotellic, there are no pharmacological/toxicological issues within this submission which preclude authorization of the product.
For more information, refer to the Cotellic Product Monograph, approved by Health Canada and available through the Drug Product Database.
7.3 Quality Basis for Decision
The Chemistry and Manufacturing information submitted for Cotellic 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. Changes to the manufacturing process and formulation made throughout the pharmaceutical development are considered acceptable upon review. Based on the stability data submitted, the proposed shelf-life of 24 months is acceptable when the product is stored between 15-30°C.
Proposed limits of drug-related impurities are considered adequately qualified (that is within International Council for Harmonisation [ICH] limits and/or qualified from toxicological studies).
All sites involved in production are compliant with Good Manufacturing Practices.
All non-medicinal ingredients (excipients) found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations.
The excipients used in the manufacture of the finished product are not of human or animal origin with the exception of lactose monohydrate, which is derived from cow's milk. Safety information on the suitability of lactose monohydrate was provided indicating that it is considered to be safe for human use.
Related Drug Products
| Product name | DIN | Company name | Active ingredient(s) & strength |
|---|---|---|---|
| COTELLIC | 02452340 | HOFFMANN-LA ROCHE LIMITED | COBIMETINIB (COBIMETINIB FUMARATE) 20 MG |