Summary Basis of Decision for Sunvepra

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

Summary Basis of Decision (SBD) documents provide information related to the original authorization of a product. The SBD for Sunvepra is located below.

Recent Activity for Sunvepra

SBDs written for eligible drugs 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. PAATs will be updated regularly with post-authorization activity throughout the product's life cycle.

Post-Authorization Activity Table (PAAT) for Sunvepra

Updated:

2020-10-09

The following table describes post-authorization activity for Sunvepra, a product which contains the medicinal ingredient asunaprevir. 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 that are found in PAATs.

For additional information about the drug submission process, refer to the Management of Drug Submissions Guidance.

Drug Identification Number (DIN):

  • DIN 02452294 - 100 mg, asunaprevir, capsule, oral

Post-Authorization Activity Table (PAAT)

Activity/submission type, control numberDate submittedDecision and dateSummary of activities
New safety review started by Health CanadaNot applicableStarted between
2019-02-01
Health Canada started a safety review for Sunvepra between 2019-02-01 and 2019-02-28.
New safety review started by Health CanadaNot applicableStarted between
2018-12-01
Health Canada started a safety review for Sunvepra between 2018-12-01 and 2018-12-31.
DIN 02452294 cancelled Post-marketNot applicableDiscontinuation date:
2017-10-16
The manufacturer notified Health Canada that sale of the drug has been discontinued post-market. Health Canada cancelled the DIN pursuant to section C.01.014.6(1)(a) of the Food and Drug Regulations.
Summary Safety Review postedNot applicablePosted
2017-04-27
Summary Safety Review for direct-acting antivirals (DAAs) posted.
NC # 1994232016-10-20Issued NOL
2017-01-27
Submission filed as a Level II (90 day) Notifiable Change (Risk Management Change) update the PM with new safety information. As a result of the NC, modifications were made to the Serious Warnings and Precautions Box, Warnings and Precautions, and Dosage and Administration 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.
Information UpdateNot applicablePosted
2016-12-01
Information Update posted, containing important safety information for the general public, healthcare professionals and hospitals.
Summary Safety Review postedNot applicablePosted
2016-12-01
Summary Safety Review for direct-acting antivirals (DAAs) posted.
Drug product (DIN 02452294) market notificationNot applicableDate of first sale:
2016-04-22
The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.
NDS # 1726172014-05-16Issued NOC
2016-03-09
Notice of Compliance issued for New Drug Submission.
Summary Basis of Decision (SBD) for Sunvepra

Date SBD issued: 2016-04-25

The following information relates to the new drug submission for Sunvepra.

Asunaprevir, 100 mg , capsule, oral

Drug Identification Number (DIN):

  • 02452294

Bristol-Myers Squibb Canada

New Drug Submission Control Number: 172617

On March 9, 2016, Health Canada issued a Notice of Compliance to Bristol-Myers Squibb Canada for the drug product, Sunvepra.

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 Sunvepra is favourable when used in combination with other agents for the treatment of chronic hepatitis C (CHC) in adult patients with hepatitis C virus (HCV) genotypes 1 or 4 and compensated liver disease, including cirrhosis.

1 What was approved?

Sunvepra (asunaprevir) was authorized to be used in combination with other agents for the treatment of chronic hepatitis C (CHC) in adult patients with hepatitis C virus (HCV) genotypes 1 or 4 and compensated liver disease, including cirrhosis.

Sunvepra is an antiviral agent; a selective inhibitor of the HCV non structural protein 3/4A (NS3/4A) protease and subsequent viral ribonucleic acid (RNA) replication with genotype 1 and 4 coverage.

The following points should be considered when initiating treatment with Sunvepra:

  • Treatment with Sunvepra should be initiated and monitored by a physician experienced in the treatment of CHC.
  • Sunvepra must not be administered as monotherapy.
  • Treatment regimen is dependent on viral genotype and subtype.
  • Sunvepra has not been studied in patients who have previously failed therapy with a treatment regimen that includes asunaprevir or other HCV protease inhibitors.

No overall differences in safety or effectiveness were observed in patients <65 and patients ≥65.

The safety and efficacy of Sunvepra have not been studied in pediatric patients (<18 years of age).

Sunvepra is contraindicated for patients who are hypersensitive to this drug or to any ingredient in the formulation or component of the container.

When Sunvepra is used in combination with Daklinza, peginterferon alfa, and ribavirin, the contraindications applicable to those agents are applicable to the combination regimen. Refer to the respective Product Monographs for a list of contraindications.

The combination of Sunvepra with Daklinza, peginterferon alfa, and ribavirin is contraindicated in women who are pregnant or may become pregnant and men whose female partners are pregnant, may be pregnant or plan to become pregnant because of the risks of birth defects and fetal death associated with ribavirin.

Sunvepra is contraindicated in patients with moderate or severe hepatic impairment (Child-Pugh B or C, score 7 or greater) and patients with decompensated liver disease.

Sunvepra is contraindicated in combination with drugs that are:

  • Dependent on the cytochrome P450 (CYP) enzyme 2D6 (CYP2D6) for clearance and for which elevated plasma concentrations are associated with serious ventricular arrhythmias and sudden death.
  • Moderate or strong inducers and inhibitors of CYP3A.
  • Strong inhibitors of organic anion transporting polypeptide (OATP) 1B1 or 2B1.

Sunvepra was approved for use under the conditions stated in the Sunvepra Product Monograph taking into consideration the potential risks associated with the administration of this drug product.

Sunvepra (100 mg asunaprevir) is presented as a capsule. In addition to the medicinal ingredient, the capsule contains butylated hydroxytoluene, glycerol monocaprylocaprate type 1, medium-chain triglycerides, and polysorbate 80. The capsule shell contains gelatin, glycerin, sorbital sorbitan solution, 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 Sunvepra Product Monograph, approved by Health Canada and available through the Drug Product Database.

2 Why was Sunvepra approved?

Health Canada considers that the benefit/risk profile of Sunvepra is favourable when used in combination with other agents for the treatment of chronic hepatitis C (CHC) genotypes 1 or 4 for adult patients with compensated liver disease, including cirrhosis.

Hepatitis C is an infectious liver disease caused by hepatitis C virus (HCV). The primary objective of HCV therapy is to eliminate the virus, a process referred to as a sustained virological response (SVR). Once achieved, an SVR is considered to be a cure of the HCV infection.

Hepatitis C virus causes liver inflammation and often leads to serious complications such as cirrhosis, liver failure, and liver cancer. Hepatitis C is the leading cause for liver transplantation in North America. In Canada, approximately 300,000 people are estimated to be infected with HCV.

In combination therapy, Sunvepra has been shown to be efficacious for the treatment of CHC in adult patients with HCV genotypes 1 or 4, and compensated liver disease, including cirrhosis. The efficacy and safety of Sunvepra in combination with Daklinza as an all-oral regimen were evaluated in HCV genotype 1b infected patients with compensated liver disease in a pivotal, Phase III, open-label study, HALLMARK DUAL. The efficacy and safety of Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin were evaluated in patients with HCV genotype 1 or 4 infection in a pivotal, Phase III open-label study, HALLMARK QUAD. Sustained virologic response (SVR, the primary endpoint) in both clinical studies was defined as hepatitis C virus ribonucleic acid (HCV RNA) below the lower limit of quantification (LLOQ) at post-treatment Week 12 (SVR at Week 12 [SVR12]).

Efficacy results from HALLMARK DUAL support the use of Sunvepra in combination with Daklinza in chronic HCV genotype 1b (GT-1b) patients with and without compensated cirrhosis. The dual therapy was effective in treatment naïve patients (90.6% SVR12); prior non responders who had little or no response to peginterferon alfa and ribavirin (82.4% SVR12); and to interferon intolerant/ineligible patients who had limited treatment options (82.6% SVR12). The main potential benefit of this regimen is that it is peginterferon alfa and ribavirin free, and that it provides another treatment option. This dual therapy option is for GT1b patients only and the treatment duration is for 24 weeks compared to the newer peginterferon alfa and ribavirin free therapies which are administered for 12-24 weeks depending on the patient population. Data from the dual therapy demonstrated similar SVR at Week 12 (SVR12) rates across various baseline factors including males and females, patients ≥65 and <65 years of age, patients with and without cirrhosis, patients with baseline HCV RNA ≥800,000 IU/mL and <800,000 IU/mL, and patients with interleukin 28B (IL28B) CC and non-CC genotypes. Patients showed high rates of treatment adherence (≥95.0%) over a 24-week treatment period indicative of a well-tolerated regimen with low pill-burden and ease of administration.

In HALLMARK QUAD, the dosing regimen of Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin was tested in genotype 1 and genotype 4 populations of prior non-responders (partial and null responders). High SVR12 rates were achieved with genotype 1 (93.2%) and genotype 4 (100%) patients. The high rate in genotype 4 patients was similar to the results observed with the sofosbuvir/peginterferon alfa/ribavirin regimen (96%) in treatment naïve patients with HCV genotype 4.

The safety profile of the Sunvepra in combination with Daklinza dosing regimen was consistent among various subgroups, including cirrhotics and noncirrhotics. Similarly, the safety profile for the first 12 weeks of treatment was consistent in treatment-naive patients who received Sunvepra plus Daklinza or placebo control.

The safety profile of the Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin dosing regimen was generally consistent with the safety profile of peginterferon alfa/ribavirin. It had a benefit/risk profile similar to that of peginterferon alfa/ribavirin therapy.

Sunvepra was associated with several drug-drug interactions some of which have led to contraindications; specifically drugs dependent on cytochrome P450 (CYP) enzyme CYP2D6 for clearance, moderate or strong inducers and inhibitors of CYP3A, and strong inhibitors of organic anion transporting polypeptide (OATP) 1B1 or 2B1.

Most on-treatment adverse events (AEs) were mild to moderate in intensity, and the rate of AEs leading to discontinuation of study therapy was low at 3.1%, with the most frequent reason being increases in hepatic transaminases not associated with evidence of ongoing hepatic decompensation. The event of greatest concern was the potential for hepatotoxicity.

Elevations in alanine aminotransferase (ALT) or aspartate aminotransferase (AST) levels were identified as a potential safety concern from the Sunvepra Phase II and Phase III studies, and cases of potential drug induced liver injury have been reported in patients treated with Sunvepra-containing regimens. Considering the reversibility of the transaminase elevations, the ability to monitor for any increases clinically, and that physicians experienced in treating HCV patients are able to manage and understand these ALT/AST elevations, these treatment-emergent elevations can be safely managed in the patient population. The potential of hepatoxicity has been included in a Serious Warnings and Precautions box in the Sunvepra Product Monograph. Instructions on monitoring liver enzymes to address this potential safety issue are also included in the Product Monograph.

A Risk Management Plan (RMP) for Sunvepra was submitted by Bristol-Myers Squibb Canada to Health Canada. Upon review, the RMP was considered to be acceptable. 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.

On June 24, 2015, the sponsor was issued a Notice of Non-Compliance (NON) for Sunvepra. The issue in the NON was identified in the review of the chemistry and manufacturing information. The sponsor submitted a response to the NON and all of the concerns that led to the NON were satisfactorily addressed.

Overall, the therapeutic benefits seen in the pivotal studies are positive and the benefits of Sunvepra in combination therapy are considered to outweigh the potential risks. Sunvepra has an acceptable safety profile based on the non-clinical data and clinical studies. The identified safety issues can be managed through labelling, and adequate monitoring. Appropriate warnings and precautions are in place in the Sunvepra Product Monograph to address the identified safety concerns.

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 Sunvepra?

A New Drug Submission (NDS) for Sunvepra was filed with Health Canada on May 16, 2014. Due to an issue identified in the review of the chemistry and manufacturing information, a Notice of Non-Compliance (NON) was issued for Sunvepra on June 24, 2015. The issue in the NON was based on concern with a genotoxic impurity, potentially present in the drug substance and drug product. The sponsor submitted a response to the NON and all of the concerns that led to the NON were satisfactorily addressed. The reviews were completed and the submission was found to be in compliance with the Food and Drugs Act and Regulations. A Notice of Compliance was issued on March 9, 2016.

Submission Milestones: Sunvepra

Submission MilestoneDate
Submission filed:2014-05-16
Screening 1
Screening Deficiency Notice issued:2014-07-15
Review 1
Quality Evaluation complete:2015-06-12
Clinical Evaluation complete:2015-08-07
Notice of Non-Compliance (NON) issued by Director General, Therapeutic Products Directorate2015-06-24
Response filed:2015-09-22
Screening 2
Screening Acceptance Letter issued:2015-10-15
Review 2
Quality Evaluation complete:2016-02-11
Clinical Evaluation complete:2016-03-08
Labelling Review complete:2016-02-18
Notice of Compliance issued by Director General, Therapeutic Products Directorate:2016-03-09

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?

Requirements for post-market commitments are outlined in the Food and Drugs Act and Regulations.

6 What other information is available about drugs?

Up to date information on drug products can be found at the following links:

 

7 What was the scientific rationale for Health Canada's decision?
7.1 Clinical basis for decision

Clinical Pharmacology

Asunaprevir, the active ingredient in Sunvepra, is an inhibitor of the hepatitis C virus (HCV) non structural protein 3/4A (NS3/4A) serine protease complex. This NS3/4A enzyme complex is responsible for processing the HCV polyprotein to yield mature viral proteins required for viral replication. Asunaprevir is most active against NS3/4A protease complexes representing the HCV genotype 1 (GT-1).

Various formulations were used in the Phase I and II studies. A hard gel capsule was used in the early Phase I clinical pharmacology studies and a film coated tablet in the later Phase I and Phase II clinical pharmacology studies. Both had low bioavailability and the pharmacokinetics were strongly influenced by food. To improve oral bioavailability and alleviate the food effect, a soft gel capsule was developed for the Phase III studies. Clinical biopharmaceutical studies were submitted and successfully bridged the various formulations from Phase I/II to the Phase III soft gel capsule (and final market formulation).

Elevations in alanine aminotransferase (ALT) and aspartate aminotransferase (AST) levels were observed in the Phase II and III clinical studies of Sunvepra-containing regimens. Frequencies of ALT/AST elevations were also higher in studies of Sunvepra in combination with Daklinza conducted in Japan than in global studies of this regimen. In a supporting study (HALLMARK NIPPON) conducted in Japan, 7% of patients had ALT >5 times the upper limit of normal (ULN) while 2% of patients in the global study HALLMARK DUAL had ALT >5 times ULN. The potential for hepatotoxicity is stated in a Serious Warnings and Precautions box in the Sunvepra Product Monograph.

In a dedicated hepatic impairment study, patients with moderate and severe hepatic impairment had considerably increased systemic exposure to asunaprevir, the medicinal ingredient of Sunvepra. Sunvepra is contraindicated for patients with moderate or severe hepatic impairment (Child-Pugh B or C, score =7) and patients with decompensated liver disease. Mild hepatic impairment had no apparent effect on exposure.

Sunvepra was associated with several drug-drug interactions some of which have led to contraindications; specifically drugs dependent on cytochrome P450 (CYP) enzyme CYP2D6 for clearance, moderate or strong inducers and inhibitors of CYP3A, and strong inhibitors of organic anion transporting polypeptide (OATP) 1B1 or 2B1. Possible drug drug interactions are discussed in the Sunvepra Product Monograph.

Overall, the clinical pharmacological data support the use of Sunvepra for the specified indication.

For further details, please refer to the Sunvepra Product Monograph, approved by Health Canada and available through the Drug Product Database.

Clinical Efficacy

The efficacy and safety of Sunvepra in combination with Daklinza as an all-oral regimen were evaluated in two Phase III studies with genotype 1b (GT-1b) patients only; the pivotal study HALLMARK DUAL (number of patients [n] = 747) and a supporting study HALLMARK NIPPON (n = 222). The efficacy and safety of Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin were evaluated in the Phase III HALLMARK QUAD study (n = 398) in genotype 1(GT-1) and genotype 4 (GT-4) patients. In all studies, the primary endpoint was the sustained virologic response (SVR) defined as hepatitis C virus ribonucleic acid (HCV RNA) levels below the lower limit of quantification (LLOQ) at post-treatment Week 12 (SVR12).

Sunvepra in Combination with Daklinza for the Treatment of Patients with Hepatitis C Virus Genotype 1b

HALLMARK DUAL (Study AI447028) was a pivotal, global, open-label study that included patients with chronic HCV GT-1b infection and compensated liver disease who were treatment naïve, null or partial responders to peginterferon alfa and ribavirin, or who were intolerant of or ineligible to receive interferon-based therapy. The study design also included a deferred treatment design for patients in the treatment-naïve cohort. That is, patients in the treatment- naïve cohort were randomized 2:1 to receive Sunvepra 100 mg twice daily (bid) plus Daklinza 60 mg once daily (qd) for 24 weeks or placebo for 12 weeks (the placebo group were rolled over into another study and offered treatment with Sunvepra plus Daklinza for 24 weeks). The purpose of the deferred treatment design was to collect comparative safety data rather than to compare virologic response between study groups; as it was expected that no patients will respond virologically while receiving placebo.

HALLMARK NIPPON (Study AI447026) was a supportive open-label study that included Japanese patients with chronic HCV GT-1b infection and compensated liver disease who were non-responders (null or partial responders) to interferon alfa or beta and ribavirin, or who were intolerant of or ineligible to receive interferon-based therapy.

In the HALLMARK DUAL study, a high proportion of patients infected with GT-1b responded to the Sunvepra in combination with Daklinza therapy. With respect to the primary endpoint, the SVR12 rates were as follows: 90.6% SVR12 in treatment-naïve patients, 82.4 % SVR12 in prior non-responders (partial or null responders), and 82.6% SVR12 in interferon intolerant/ineligible patients. Similar high SVR12 rates were also reported for the supporting NIPPON study. Overall, these results indicated that the dual therapy (Sunvepra in combination with Daklinza) was an effective, oral, peginterferon alfa- and ribavirin-free treatment regimen for the indicated populations of treatment-naïve, prior non-responders, and interferon intolerant/ineligible patients. Overall, the Sunvepra in combination with Daklinza therapy demonstrated high and comparable SVR12 rates across all subgroups of baseline host factors including age (<65 and ≥65 years), gender, cirrhosis status, interleukin (IL)-28B polymorphism, prior treatment history (prior null or partial responders to HCV therapy, or interferon/ribavirin-based therapy intolerant/ineligible) and patients with varying degree of viral load, for example (e.g.) a viral load of <800,000 IU/mLor >800,000 IU/mL. Based on available long-term follow-up data, patients who achieved SVR12 following treatment with Sunvepra in combination with Daklinza continued to achieve long-term efficacy. The dual therapy provides another treatment option for certain patient populations.

Sunvepra in Combination with Daklinza, Peginterferon Alfa, and Ribavirin for the Treatment of Patients with Hepatitis C Virus Genotype 1 or 4

HALLMARK QUAD (Study AI447029) was a pivotal, global, single-arm, open-label study that included adults with compensated liver disease who were partial or null responders to therapy with peginterferon alfa 2a or 2b and ribavirin.

In the HALLMARK QUAD study, Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin was shown to be an effective treatment regimen with demonstrated high SVR12 rates of 93%-100% in difficult to treat GT-1 and GT-4 interferon-tolerant patients who were prior-non-responders (null or partial responders) to prior peginterferon alfa and ribavirin treatment. The SVR12 rates were consistently high across all subgroups of host factors (including age, gender, cirrhosis status, IL-28B polymorphism, prior null or partial response to HCV therapy) and viral factors (such as viral load). The SVR12 rates achieved with Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin therapy in GT-1 prior partial responders and prior null responders was 93-94%.

Indication

The proposed indication for Sunvepra at the time of filing was as follows:

“Sunvepra (asunaprevir) is a hepatitis C virus (HCV) NS3/4A protease inhibitor indicated for the treatment of chronic HCV infection in adults with compensated liver disease (including cirrhosis) in combination with:

  • Daklinza (daclatasvir), an NS5A replication complex inhibitor, for patients with HCV genotype 1b infection;
  • Daklinza, peginterferon alfa, and ribavirin for patients with HCV genotype 1 or 4 infection.

The following points should be considered when initiating treatment with Sunvepra:

  • Sunvepra must not be administered as monotherapy.
  • Treatment regimen is dependent on viral genotype.
  • Sunvepra has not been studied in patients who have previously failed therapy with a treatment regimen that includes Sunvepra or other HCV protease inhibitors.”

Minor revisions were made to the original proposed indication to simplify the wording and specify the genotypes that Sunvepra is indicated for. The revised recommended indication is as follows:

“Sunvepra (asunaprevir) is indicated in combination with other agents for the treatment of chronic hepatitis C (CHC) in adult patients with hepatitis C virus (HCV) genotypes 1 or 4 and compensated liver disease, including cirrhosis.

The following points should be considered when initiating treatment with Sunvepra:

  • Treatment with Sunvepra should be initiated and monitored by a physician experienced in the treatment of CHC.
  • Sunvepra must not be administered as monotherapy.
  • Treatment regimen is dependent on viral genotype and subtype.
  • Sunvepra has not been studied in patients who have previously failed therapy with a treatment regimen that includes asunaprevir or other HCV protease inhibitors.”
For more information, refer to the Sunvepra Product Monograph, approved by Health Canada and available through the Drug Product Database.

Clinical Safety

More than 3,000 patients have been exposed to Sunvepra (asunaprvir) in Phase I, Phase II, and Phase III studies, including 2,912 patients with HCV. In nine completed and ongoing Phase II and Phase III studies, a total of 2,159 patients with HCV have been exposed to the recommended dose of Sunvepra at 100 mg bid softgel capsule or the equivalent 200 mg bid tablet form.

The all-oral therapy of Sunvepra (100 mg bid) in combination with Daklinza (60 mg qd) had a favourable safety and tolerability profile compared to interferon/ribavirin-based therapy regimens in HCV GT-1b patients who are treatment naïve, treatment-experienced, or ineligible/intolerant to interferon/ribavirin based therapy, including patients with compensated cirrhosis and the elderly. Unlike interferon/ribavirin based regimens, clinically important adverse events (AEs) of myelosuppression (anemia, neutropenia), thrombocytopenia, depression, or influenza-like symptoms were not observed with the Sunvepra in combination with Daklinza (interferon/ribavirin free) regimen.

High rates of treatment adherence relative to peginterferon alfa and ribavirin-containing therapies and low rates of premature discontinuations due to AEs were indicative of a favourable tolerability profile of the all-oral Sunvepra in combination with Daklinza therapy. Most on treatment AEs were mild to moderate in intensity, and the rate of AEs leading to discontinuation of study therapy was low at 3.1%, with the most frequent reason being increases in hepatic transaminases. These early discontinuations were not associated with evidence of ongoing hepatic decompensation, and moreover, 16 of 19 patients who discontinued study therapy due to increased transaminases, achieved an SVR. Elevations in ALT or AST levels were previously identified as a potential safety concern from non-clinical studies and clinical data from studies with asunaprevir. The dose in the Sunvepra program was previously reduced from 600 mg bid to 200 mg bid based upon increases of ALT/AST observed at the 600 mg dose.

In the HALLMARK DUAL study (described in the Clinical Efficacy section), no clinically relevant differences were observed in the safety profile of Sunvepra in combination with Daklinza versus placebo during the first 12 weeks of treatment in treatment-naïve patients. Overall, the safety profile of the Sunvepra in combination with Daklinza regimen among cirrhotics was also observed in this data set and showed no differences from non cirrhotics.

The safety profile of Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin for the treatment of HCV infections caused by GT-1 or GT-4 in patients who failed previous interferon/ribavirin based therapy was assessed in the HALLMARK QUAD study (described in the Clinical Efficacy section). The safety profile of Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin was found to be consistent with the historical safety profile of peginterferon alfa and ribavirin alone which includes Grade 3/4 hematologic abnormalities and other AEs characteristic of peginterferon alfa/ribavirin therapy, with the exception of elevated transaminase levels as observed in other Sunvepra studies. There was no clinically meaningful difference in patients with or without cirrhosis, among patients exposed to the Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin regimen.

Potential for Hepatotoxicity

Elevations in ALT or AST levels were observed in Phase II and Phase III clinical studies of Sunvepra-containing regimens. In analyses evaluating Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin, hepatic safety events (particularly associated with increased ALT/AST levels) were reported at a higher rate as compared to placebo in combination with Daklinza, peginterferon alfa, and ribavirin. In addition, these events were reported more frequently in the Japanese studies compared to studies evaluating non-Japanese patients which included Asian subjects from Taiwan and Korea. This was more notable in the frequency of Grade 3/4 ALT or Grade 3/4 AST elevations reported in Japanese studies as compared to non-Japanese studies. The frequency of reported Grade 3/4 ALT elevations was higher in the Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin regimens, as compared to regimens without Sunvepra (that is, placebo in combination with Daklinza, peginterferon alfa, and ribavirin).

In patients treated with Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin, the earliest onset of Grade 3/4 ALT was within 16 days and the latest was 168 days (end of treatment). In general, the median time to reversal of these ALT abnormalities was <4 weeks.

Across the global and Japanese Phase II/III studies using Sunvepra in combination with Daklinza and studies using Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin, there were 4 cases of potential drug-induced liver injuries identified, including 3 patients treated with Sunvepra in combination with Daklinza in Phase III studies, and 1 patient treated with Sunvepra in combination with Daklinza, peginterferon alfa, and ribavirin. There were also 2 cases of potential drug-induced liver injuries among patients treated with higher doses of Sunvepra 600 mg qd in combination with peginterferon alfa and ribavirin. There was no evidence of clinical liver decompensation in any of the identified potential drug-induced liver injury cases, and laboratory abnormalities were reversible after Sunvepra was discontinued.

The Sunvepra Product Monograph was revised to include statements on monitoring of ALT and AST levels once every 2 weeks for the initial 12 weeks of treatment and every 4 weeks thereafter until completion of therapy. Any upward trend in ALT or AST levels warrants more frequent monitoring and if on-treatment elevations in ALT levels 10 times the ULN or greater occur, treatment should be discontinued immediately and not be resumed.

In addition, wording has been added to highlight that cases of potential drug-induced liver injuries have been reported and that AST/ALT elevations were more frequently reported in studies of Sunvepra in combination with Daklinza conducted in Japan than in the global study with this regimen.

Considering the reversibility of the transaminase elevations, the ability to clinically monitor for any increases, and that the physicians administering Sunvepra treatment are experienced in treating HCV patients and are able to manage and understand these ALT/AST elevations, these treatment-emergent elevations can be safely managed in the patient population. The Sunvepra Product Monograph has been adequately revised to address this potential safety issue. The potential of hepatoxicity has been included in a Serious Warnings and Precautions box in the Sunvepra Product Monograph.

For more information, refer to the Sunvepra Product Monograph, approved by Health Canada and available through the Drug Product Database.

7.2 Non-Clinical Basis for Decision

The non-clinical package submitted in support of Sunvepra (asunaprevir) was considered thorough and complete. All recommended pharmacology, pharmacokinetic and toxicology studies have been submitted and were conducted in accordance with Good Laboratory Practices and/or in compliance with International Council for Harmonisation (ICH) guidelines.

Toxicology studies demonstrated that asunaprevir was generally well-tolerated with target organs being the liver, gastrointestinal tract and adrenal gland. No specific risk of reproductive or developmental toxicity was observed aside from effects associated with general toxicity at high doses; nevertheless Sunvepra is not recommended for administration during pregnancy in humans.

The results of the non-clinical studies as well as the potential risks to humans have been included in the Sunvepra Product Monograph. In view of the intended use of Sunvepra, there are no pharmacological/toxicological issues within this submission which preclude authorization of the product. Appropriate warnings and precautionary measures are in place in the Sunvepra Product Monograph to address the identified safety concerns.

For more information, refer to the Sunvepra Product Monograph, approved by Health Canada and available through the Drug Product Database.

7.3 Quality Basis for Decision

The drug submission for Sunvepra previously received a Notice of Non-Compliance (NON). The issue in the NON was concern with a genotoxic impurity, potentially present in the drug substance and drug product. The sponsor submitted a response to the NON that included data demonstrating that this impurity is controlled during drug substance manufacture and does not occur in the drug substance or drug product due to manufacturing or degradation. All of the concerns that led to the NON were satisfactorily addressed. The drug submission was again accepted into review, and was then considered to meet the requirements of C.08.002(2)(f) of the Food and Drug Regulations, insofar as the Quality (Chemistry and Manufacturing) information was concerned.

The Chemistry and Manufacturing information submitted for Sunvepra 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 at 15-30°C and protected from light.

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 (described earlier) found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations.

There are no materials of human or animal origin used in the manufacture of asunaprevir drug substance.

The gelatin used in the manufacture of the capsule shell is extracted from bovine hide. The suppliers have provided statements attesting that their products demonstrate compliance with the Note for Guidance on Minimising the Risk of Transmitting Animal Spongiform Encephalopathy Agents via Human and Veterinary Medicinal Products (EMEA/410/01, Revision 3).