Summary Basis of Decision for Portrazza
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 Portrazza is located below.
Recent Activity for Portrazza
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.
The following table describes post-authorization activity for Portrazza, a product which contains the medicinal ingredient necitumumab. 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.
Updated: 2024-06-10
Drug Identification Number (DIN):
DIN 02462478 – 16 mg / ml necitumumab, solution, intravenous administration
Post-Authorization Activity Table (PAAT)
|
Activity/Submission Type, Control Number |
Date Submitted |
Decision and Date |
Summary of Activities |
|
DIN 02462478 cancelled pre market |
Not applicable |
Discontinuation date: 2021-07-22 |
The manufacturer notified Health Canada that sale of the drug has been discontinued pre market. Health Canada cancelled the DIN pursuant to section C.01.014.6(1)(a) of the Food and Drug Regulations. |
|
NDS # 193689 |
2016-03-29 |
Issued NOC 2017-03-16 |
NOC issued for New Drug Submission. |
Summary Basis of Decision (SBD) for Portrazza
Date SBD issued: 2017-05-16
The following information relates to the New Drug Submission for Portrazza.
Necitumumab
16 mg/mL, solution, intravenous
Drug Identification Number (DIN):
- 02462478
Eli Lilly Canada Inc.
New Drug Submission Control Number: 193689
On March 16, 2017, Health Canada issued a Notice of Compliance to Eli Lilly Canada Inc. for the drug product Portrazza.
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 Portrazza in combination with gemcitabine and cisplatin is favourable for the treatment of patients with locally advanced or metastatic squamous non-small cell lung cancer who have not received prior chemotherapy for this condition. Patients with locally advanced disease should be considered surgically incurable or incurable by virtue of ineligibility to receive curative surgery.
1 What was approved?
Portrazza (necitumumab), an antineoplastic drug, is a recombinant human monoclonal antibody of the immunoglobulin G1 class, which targets the epidermal growth factor receptor (EGFR). Portrazza in combination with gemcitabine and cisplatin was authorized for the treatment of patients with locally advanced or metastatic squamous non-small cell lung cancer who have not received prior chemotherapy for this condition. Patients with locally advanced disease should be considered surgically incurable or incurable by virtue of ineligibility to receive curative surgery.
In an exploratory analysis of patients ≥70 years of age, no apparent benefit toward improved overall survival or progression-free survival was observed. Thus, a thorough assessment should be considered regarding the benefit/risk of adding Portrazza to chemotherapy when making individual treatment decisions in patients ≥70 years of age.
The safety and effectiveness of Portrazza in children and adolescents (<18 years of age) have not been established.
Portrazza is contraindicated in patients with previous severe (Grades 3-4) hypersensitivity to necitumumab or to any other ingredient used in the formulation. Portrazza was approved for use under the conditions stated in the Portrazza Product Monograph taking into consideration the potential risks associated with the administration of this drug product.
Portrazza (16 mg/mL necitumumab) is presented as a solution. In addition to the medicinal ingredient, the solution contains citric acid anhydrous, glycine, mannitol, polysorbate 80, sodium chloride, sodium citrate dihydrate and water for injection.
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 Portrazza Product Monograph, approved by Health Canada and available through the Drug Product Database.
2 Why was Portrazza approved?
Health Canada considers that the benefit/risk profile of Portrazza in combination with gemcitabine and cisplatin is favourable for the treatment of patients with locally advanced or metastatic squamous non-small cell lung cancer (NSCLC) who have not received prior chemotherapy for this condition. Patients with locally advanced disease should be considered surgically incurable or incurable by virtue of ineligibility to receive curative surgery.
Combination doublet chemotherapy is currently standard therapy for patients with locally advanced and metastatic NSCLC. Such doublets include gemcitabine, vinorelbine, paclitaxel, or docetaxel in combination with either cisplatin or carboplatin for patients with squamous cell tumours and pemetrexed with a platinum agent for non-squamous tumour types. The median survival overall for standard doublet regimens is approximately 8.0 months while the median progression-free survival is approximately 3.6 months. Epidermal growth factor receptor (EGFR) expression is found on up to 85% of tumours of patients afflicted with NSCLC. In an effort to capitalize on the high frequency of EGFR expression and to improve the outcome for such patients, monoclonal antibodies have been developed against EGFR. Portrazza (necitumumab) is a recombinant human monoclonal antibody of the immunoglobulin G1 class, which targets EGFR.
Portrazza has been shown to be efficacious in patients with stage IV squamous NSCLC, who had received no prior anticancer therapy for metastatic disease. The market authorization was based on a Phase III, global, multicentre, open-label, two-arm, randomized study (SQUIRE) conducted in 1,093 patients.
The benefit/risk assessment concluded that Portrazza plus gemcitabine and cisplatin chemotherapy was associated with a statistically significant improvement in overall survival, progression-free survival, and time-to-treatment failure but not in objective-response rate or quality-of-life assessments. The clinical improvement in overall survival was small (median improvement was 1.6 months) and support from improvements in secondary endpoints was limited, with questionable clinically meaningful improvements of 0.2 months for progression-free survival and 0.7 months for time-to-treatment failure. Only a small portion of the overall survival improvement coincided with progression-free clinical status.
The adverse events that were expected with this class of drugs were higher in groups that received Portrazza as part of their therapy compared to control groups in the randomized studies. These adverse events included skin rashes, electrolyte imbalances including hypomagnesemia, hypocalcemia, and hypokalemia (as well as combinations of these imbalances), and thromboembolic events (TEs). Comparing the results of the pivotal SQUIRE study with those of the supportive INSPIRE study (see Supportive Studies for clinical efficacy), for the Portrazza-containing arm, the incidences of any TEs and venous TEs were slightly higher in the INSPIRE study while the incidence of arterial TEs was slightly higher in the SQUIRE study (see Clinical Safety). Of note is the lack of evidence of benefit from Portrazza and the higher incidence (≥3%) of venous TEs, including pulmonary embolism, in patients ≥70 years of age compared to patients <70 years of age. While the overall benefit/risk assessment shows a small positive benefit/risk ratio for Portrazza, the uncertainty about the efficacy and safety in the elderly warrants special warnings and precautions regarding administration of this combination therapy to patients ≥70 years of age. The following warnings have been included in a Serious Warnings and Precautions box in the Product Monograph for Portrazza: increased frequency of cardiorespiratory arrest or sudden death, increased risk of venous or arterial thromboembolic events, and increased risk of electrolyte disorders (magnesium, calcium, potassium, and/or phosphate).
Eli Lilly Canada Inc. submitted a Risk Management Plan (RMP) for Portrazza. Health Canada communicated a number of concerns to the sponsor. After reviewing the sponsor's reply, the RMP was considered 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.
A Look-alike Sound-alike brand name assessment was performed and the proposed name Portrazza has been deemed acceptable.
Overall, the therapeutic benefits seen in the pivotal study are positive and the benefits of Portrazza therapy are considered to outweigh the potential risks. Portrazza 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 Portrazza 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 Portrazza?
Submission Milestones: Portrazza
| Submission Milestone | Date |
|---|---|
| Pre-submission meeting: | 2016-03-02 |
| Submission filed: | 2016-03-29 |
| Screening | |
| Screening Acceptance Letter issued: | 2016-05-20 |
| Review | |
| On-Site Evaluation: | |
| Review of Risk Management Plan complete: | 2017-01-13 |
| Look-alike Sound-alike brand name assessment complete: | 2017-03-01 |
| Quality Evaluation complete: | 2017-03-15 |
| Clinical Evaluation complete: | 2017-03-15 |
| Labelling Review complete | 2017-03-15 |
| Notice of Compliance issued by Director General, Biologics and Genetic Therapies Directorate: | 2017-03-16 |
The Canadian regulatory decision on the quality, non-clinical, and clinical review of Portrazza was based on a critical assessment of the Canadian data package. The foreign reviews completed by the European Medicines Agency (EMA) and 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.
- 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, 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
Necitumumab, the medicinal ingredient of Portrazza, is a recombinant human immunoglobulin G1 monoclonal antibody that binds with high affinity and specificity to the human epidermal growth factor receptor (EGFR) and blocks the ligand binding site, blocking activation by all known ligands and inhibiting relevant biological effects in vitro. Studies demonstrate that Portrazza inhibits EGFR-dependent tumour cell proliferation, and can exert cytotoxic effect in tumour cells through antibody-dependent cell-mediated cytotoxicity.
The appropriate clinical dosage regimen was sought on the basis of safety and pharmacokinetic (PK) data from two Phase I dose-escalation studies. However, a non-validated bioanalytical method was used in the measurement of necitumumab concentrations, and the maximum tolerated dose was based on very limited safety data. Other studies, using the validated bioanalytical method, evaluated alternative dosing schedules. Population pharmacokinetic/pharmacodynamic modelling (including data from the Phase III studies SQUIRE and INSPIRE) supported that the selected clinical dose regimen of 800 mg given on days 1 and 8 of each 3-week cycle is the appropriate dose and regimen in terms of minimizing toxicity while maintaining efficacy.
After an initial peak, the concentration with time of necitumumab can be approximated with a biphasic decline. Data for a Population PK (POPPK) analysis was obtained from 5 clinical trials (including the Phase III studies SQUIRE and INSPIRE). The inter-patient variability was moderate to high for primary parameters. Necitumumab exhibits concentration-dependent clearance, possibly through target mediated drug distribution. The POPPK model confirmed that the time to reach steady state was approximately 100 days. Simulation of the clinical dosing regimen was associated with a minimum plasma concentration that was 5-fold greater than that expected for a therapeutic effect in the tissue compartment. In addition, the estimate of the half-life of necitumumab using the POPPK analysis was approximately double that obtained from the non-compartmental analysis. However, the higher POPPK estimate may have been influenced by drug accumulation over multiple doses. The choice of the current dosing regimen in the pivotal study appears to have been based on clinical factors (for example [e.g.], dose limiting toxicities) with limited PK data.
Across all clinical studies, a total of 1,056 patients had immunogenicity data reported. Based on the 861 patients who had both baseline and post-treatment samples for analysis, the rate of detection of anti-necitumumab antibodies (ADA) was low (8.6% of patients were post-treatment ADA-positive). Treatment-emergent ADAs were detected in 4.0% (34/861) of patients, and neutralizing antibodies were detected in 1.5% (13/861) of patients post-exposure to Portrazza. No analysis of treatment-emergent adverse events (TEAEs) in ADA-positive patients compared to TEAEs in ADA-negative patients was conducted. Based on data from the clinical studies SQUIRE and INSPIRE, no relationship was found between the presence of ADA and the incidence of infusion-related reactions.
Drug-drug interactions were examined in 35 patients with advanced solid malignancies who received necitumumab in combination with gemcitabine and cisplatin. The systemic drug exposure (geometric mean dose-normalized area under the curve [AUC]) of gemcitabine when given in the combination was increased by 18% and the maximum plasma concentration increased by 66% compared to administration of gemcitabine alone. However, the pharmacokinetics of cisplatin were unaltered when co-administered with necitumumab, and the pharmacokinetics of necitumumab were not affected when co-administered with gemcitabine and cisplatin.
The impact of necitumumab treatment on the QT/QTc interval was examined in 75 patients with advanced solid tumours. Patients were treated with necitumumab 800 mg once a week over a 6-week cycle. The study demonstrated lack of effect on QTc interval based on the criteria defined in International Council for Harmonisation (ICH) guidelines ICH E14. However, TEAEs of QTc prolongation were reported in one third of patients. QTc prolongation may be caused by electrolyte disturbances which are a known side effect of cytotoxic drugs and EGFR monoclonal antibodies.
Overall, the clinical pharmacological data support the use of Portrazza for the specified indication.
For further details, please refer to the Portrazza Product Monograph, approved by Health Canada and available through the Drug Product Database.
Clinical Efficacy
The clinical efficacy of Portrazza was primarily evaluated in a Phase III global, multicentre, open-label, two-arm, randomized study (SQUIRE) conducted in 1,093 patients with stage IV (American Joint Committee on Cancer Version 7) squamous non-small cell lung cancer (NSCLC), including patients with Eastern Cooperative Oncology Group Performance Status 2 (ECOG PS2), who had received no prior anticancer therapy for metastatic disease. Patients were randomized to receive Portrazza at 800 mg plus chemotherapy consisting of gemcitabine at 1,250 mg/m2 and cisplatin at 75 mg/m2 (Portrazza plus gemcitabine-cisplatin arm), or gemcitabine and cisplatin chemotherapy alone (control arm). Stratification factors were ECOG PS (0, 1 vs. 2) and geographic region (North America, Europe, and Australia vs. South America, South Africa, and India vs. Eastern Asia). Portrazza and gemcitabine were administered on Days 1 and 8 of each 3-week treatment cycle, and cisplatin was administered on Day 1 of each 3-week treatment cycle. There was no premedication for Portrazza mandated by the study. Pre-emptive treatment for skin reactions were not permitted prior to the beginning of the second treatment cycle. Patients received a maximum of six cycles of chemotherapy in each arm. Patients in the Portrazza plus gemcitabine-cisplatin arm who had no progression continued to receive single-agent Portrazza until disease progression or unacceptable toxicity. The primary efficacy endpoint was overall survival (OS) and the main secondary efficacy endpoints included progression-free survival (PFS), objective response rate (ORR), and disease control rate (DCR). Patients underwent a radiographic assessment of disease status every six weeks, until radiographic documentation of progressive disease (PD). The primary outcome OS and the primary analysis was conducted with the intent-to-treat population of 545 patients in the Portrazza plus gemcitabine-cisplatin arm and 548 patients in the control arm.
The primary endpoint of OS improved among patients in the Portrazza plus gemcitabine-cisplatin arm compared with those in the control arm. Median OS was 11.5 months (95% confidence interval [CI]: 10.4, 12.6) in the Portrazza plus gemcitabine-cisplatin arm and 9.9 months (95% CI: 8.9, 11.1) in the control arm, a small improvement in median survival of 1.6 months. The associated hazard ratio (HR) was 0.84 (0.74, 0.96), with an estimated reduction in the risk of death of 15.8%. These results are statistically significant (p = 0.012). The Kaplan-Meier survival curves showed an early separation in favour of the Portrazza plus gemcitabine-cisplatin arm and the separation, albeit small, was maintained over the duration of the study follow-up. Therapy with Portrazza plus gemcitabine and cisplatin was also associated with a 4.9% improvement in one-year survival and a 3.4% improvement in 2-year survival. Pre-specified sensitivity analyses supported these results, and pre-specified subgroup analyses of OS generally favoured the patients treated with Portrazza, except for patients ≥70 years of age for whom there was no difference in OS between treatment groups.
The primary analysis of PFS showed a very slight improvement in median PFS of 0.2 months in favour of Portrazza-treated patients (5.7 months vs. 5.5 months). This result reached statistical significance (HR 0.85, [0.74, 0.98]; p = 0.02, associated with an estimated risk reduction of 14.9%). In addition, the observed clinical benefit was very small and the Kaplan-Meier curves showed a very small separation before 11 months of follow-up, after which time the curves came together. There was also a very small gain of 0.7 months in the median time to treatment failure among those treated in the Portrazza plus gemcitabine-cisplatin arm (4.3 months vs. 3.6 months) which was statistically significant (HR = 0.84; p = 0.006). A marginal improvement in ORR of 2.4% favouring the addition of Portrazza was not statistically significant (p = 0.4). Health status assessments used the self-administered Lung Cancer Symptom Scale (LCSS) and the European Quality of Life-5 Dimensions (EQ-5D). Overall, Portrazza in combination with gemcitabine and cisplatin was not associated with a compelling improvement or deterioration in health-related quality of life in these patients.
Supportive Studies
Three additional studies provided efficacy information:
- Study JFCK: A single cohort, open-label Phase II study (JFCK) of gemcitabine and cisplatin plus Portrazza as first-line therapy in patients with squamous NSCLC gave support for the efficacy of Portrazza in this combination.
- Study JFCL: A randomized, multicentre, open-label, Phase II study of paclitaxel-carboplatin chemotherapy plus necitumumab vs. paclitaxel-carboplatin chemotherapy alone in the first-line treatment of patients with Stage IV squamous NSCLC.
- INSPIRE Study: A randomized, multicentre, open-label Phase III study of pemetrexed-cisplatin chemotherapy plus necitumumab vs. pemetrexed-cisplatin chemotherapy alone in the first-line treatment of patients with Stage IV non-squamous NSCLC.
In Study JFCK, the ORR was 42.6% (all partial responses), while the median OS was 11.7 months, and the median PFS was 5.6 months. However, there was no evidence of treatment benefit in the supportive randomized study INSPIRE using Portrazza plus pemetrexed/cisplatin vs. the doublet alone, in patients with non-squamous NSCLC. In the randomized Phase II Study JFCL, the necitumumab plus paclitaxel-carboplatin combination resulted in an increased ORR suggesting an add-on effect over paclitaxel-carboplatin alone, for patients with squamous NSCLC; however, when tested, this result was not statistically significant.
Indication
The sponsor, Eli Lilly Canada, proposed the following indication:
- Portrazza (necitumumab) is indicated, in combination with gemcitabine and cisplatin, for the treatment of patients with locally advanced or metastatic squamous non-small cell lung cancer who have not received prior chemotherapy for this condition.
Given that the pivotal Phase III study population consisted of patients with stage IV NSCLC, Health Canada recommended the following indication:
- Portrazza (necitumumab) is indicated, in combination with gemcitabine and cisplatin, for first-line treatment of patients with locally advanced or metastatic squamous non-small cell lung cancer. Patients with locally advanced disease should be considered surgically incurable or incurable by virtue of ineligibility to receive curative surgery.
The recommended dose of Portrazza is 800 mg as a fixed dose intravenous infusion, combined with gemcitabine and cisplatin, on Day 1 and Day 8 of every 21 day cycle.
For more information, refer to the Portrazza Product Monograph, approved by Health Canada and available through the Drug Product Database.
Clinical Safety
The clinical safety of Portrazza was primarily based on data from the SQUIRE study (see the Clinical Efficacy section), a Phase III, global, multicentre, two-arm, randomized, open-label study comparing Portrazza plus gemcitabine and cisplatin to gemcitabine and cisplatin alone in patients with squamous NSCLC. All patients had ECOG PS 0-2. Supportive studies (including INSPIRE, JFCL, and JFCK) provided additional safety data to establish the safety profile.
The safety population in the Phase III study SQUIRE consisted of 538 patients in the Portrazza plus gemcitabine-cisplatin arm and 541 patients in the gemcitabine-cisplatin control arm. The most frequently reported TEAEs of any grade that occurred in >5% of patients in the Portrazza plus gemcitabine-cisplatin arm were skin-related disorders or related events. A marked increase in any grade of TEAEs in the Portrazza plus gemcitabine-cisplatin arm compared to the control arm occurred as hypomagnesemia (29.6% vs. 15.2%) and weight loss (13.4% vs. 6.3%). Of the grade ≥3 TEAEs occurring in this group, those that were experienced as grade ≥3 more commonly in the Portrazza plus gemcitabine-cisplatin arm compared to the control arm were skin rash (3.7% vs 0.2%), hypomagnesemia (8.7% vs. 1.1%), vomiting (2.6% vs. 0.9%), and hypokalemia (3.0% vs. 1.5%). Grade ≥3 hypocalcemia developed in 1.5% of the patients in the Portrazza plus gemcitabine-cisplatin arm and only 0.4% in the control arm. A shift in magnesium levels during the study from grade 0-2 at baseline to grade 3-4 occurred in 17.8% of the patients in the Portrazza plus gemcitabine-cisplatin arm compared to 6.9% in the control arm. Similarly, the shift from grade 0-2 to grade 3-4 hypocalcemia occurred in 5.9% of the patients in the Portrazza plus gemcitabine-cisplatin arm and only 2.3% in the control arm. Further data on toxicities related to Portrazza can be found in the Adverse Reactions section of the Portrazza Product Monograph.
Risk of high-grade thromboembolic events (TEs) is associated with biologics in this class. The incidence of high-grade (Grade ≥3) TEs in the Portrazza plus gemcitabine-cisplatin arms of both the pivotal study, SQUIRE, and supporting study, INSPIRE, (8.9% and 10.2%, respectively) exceeded those that were reported in a meta-analysis of the Phase III cetuximab studies (7.4%). The Grade ≥3 TE rates for the Portrazza plus pemetrexed-cisplatin arm vs. the control arm in the INSPIRE study were 10.2% and 7.0%, respectively. The Grade ≥3 TE rates in SQUIRE were somewhat less in the Portrazza plus gemcitabine-cisplatin arm (8.9%) vs. in the control arm (4.6%). In SQUIRE, Grade ≥3 venous thromboembolic events (VTEs) occurred in 5.0% of the patients in the Portrazza plus gemcitabine-cisplatin arm and 2.6% of the patients in the control arm, with one fatal VTE in each arm. This compares to 7.6% Grade ≥3 VTEs in the Portrazza plus gemcitabine-cisplatin arm in INSPIRE (with three deaths or 1% attributed to pulmonary TEs and 3.5% (including 4 deaths or 1% attributable to pulmonary TEs) in the control arm. However, in SQUIRE, the Grade ≥3 arterial TE incidence was higher, with 3.9% of patients (0.4% fatality rate) experiencing events in the Portrazza plus gemcitabine-cisplatin arm compared to 2.0% (fatal in 0.2%) in the control arm. The analogous Grade ≥3 arterial TE rates in INSPIRE were 2.6% vs. 3.5%, respectively.
There was a higher rate of sudden death or a potential association of death with TE in the INSPIRE study. In the SQUIRE study, unexplained death or sudden death occurred in 1.9% and 0.4% of patients in the Portrazza plus gemcitabine-cisplatin arm and control arm, respectively. When cases clearly associated with progressive disease were removed from these groups on review of the narratives of these cases, 1% vs. 0.2% of unexplained cases remained in the respective treatment arms. Comparing fatalities associated with severe infection in the Portrazza plus gemcitabine-cisplatin arm vs. the control arm, upper respiratory tract bacterial infection and pneumonia occurred together in 1.1% vs. 0.6% while sepsis occurred in 0% vs. 0.4%, respectively.
Appropriate warnings and precautions are in place in the approved Portrazza Product Monograph to address the identified safety concerns.
The following warnings have been included in a Serious Warnings and Precautions box in the Product Monograph for Portrazza: increased frequency of cardiorespiratory arrest or sudden death, increased risk of venous or arterial thromboembolic events, and increased risk of electrolyte disorders (magnesium, calcium, potassium, and/or phosphate).
For more information, refer to the Portrazza Product Monograph, approved by Health Canada and available through the Drug Product Database.
Supportive Studies
As with the efficacy data, Studies JFCK, JFCL, and INSPIRE provided supportive safety data.
The safety profile of Portrazza was consistent across the supportive studies. Electrolyte deficiencies were common TEAEs in all of the studies. Hypomagnesemia was the most common of these disorders, with the incidence ranging from 24.5% to 34.4% (all grades) in three NSCLC studies. Hypocalcemia and hypokalemia were also more common in regimens containing Portrazza compared to controls and occasionally these electrolyte deficiencies occurred concurrently, requiring increased clinical vigilance for signs of clinical consequences. Hypersensitivity/infusion-related reactions were of low frequency, varying from 2.0% to 6.8% across the supportive studies. These reactions were generally manageable. Hematological toxicity was somewhat more common, with an increase in grade 3/4 neutropenia when Portrazza was added to doublet chemotherapy (e.g., 30.2% vs. 23.6% in the randomized Phase II JFCL study). Similarly, grade ≥3 infections were more commonly associated with the use of Portrazza (e.g., 11.5% vs. 5.4% in the INSPIRE study and 17.9% vs. 12.7% in the JFCL study), including neutropenic sepsis and respiratory failure (2.0% vs. 0.3% for the former and 1.0% vs. 0.3% for the latter in the INSPIRE study).
Fatal cardiac events and sudden death occurred infrequently but were more frequent with therapy including Portrazza, particularly in the INSPIRE study (2.3% vs. 0.6%).
The data from the supportive studies support the SQUIRE pivotal study in highlighting the delicate balance between a small survival advantage associated with therapy containing Portrazza and the increased risks of some formidable adverse events.
7.2 Non-Clinical Basis for Decision
Non-clinical studies in xenograft tumour models indicated that treatment with necitumumab, the medicinal ingredient of Portrazza, results in tumour growth inhibition in the setting of NSCLC (lung adenocarcinoma and squamous carcinoma of the lung), colorectal cancer, and other tumour types.
The toxicity of necitumumab was evaluated in 5- and 26-week repeat-dose studies in cynomolgus monkeys. There were no significant drug-related findings following dosing for 5 weeks at doses as high as 40 mg/kg. In the 26-week study, monkeys were treated at dose levels of 0, 6, 19, or 60 mg/kg weekly for 26 weeks. Following 26 weeks of dosing, a no-observed-adverse-effect level (NOAEL) was not established, as skin toxicity was observed at all dose levels with dose-dependent severity and time of onset. Skin effects were described as hyperplastic dermatitis which was presented as rash, erythema, and scaling macroscopically and epidermal hyperplasia, hyperkeratosis and lymphocytic interface inflammation microscopically. This type of skin lesion is characteristic of many EGFR inhibitors. Exposure levels in the 5-week repeat-dose monkey study were similar to the median clinically efficacious exposure level, while exposure in the 26-week monkey study exceeded the clinically efficacious exposure level by approximately 2-fold. Overall, the toxicology data suggest that patients can be exposed to therapeutically effective necitumumab concentrations while only experiencing monitorable and clinically manageable skin effects.
The results of the non-clinical studies as well as the potential risks to humans have been included in the Portrazza Product Monograph. In view of the intended use of Portrazza, there are no pharmacological/toxicological issues within this submission which preclude authorization of the product.
For more information, refer to the Portrazza Product Monograph, approved by Health Canada and available through the Drug Product Database.
7.3 Quality Basis for Decision
Portrazza (necitumumab) is a recombinant human immunoglobulin G1 kappa monoclonal antibody that specifically binds to the ligand binding site of the human epidermal growth factor receptor (EGFR). Necitumumab blocks the binding of EGFR to its ligands, induces EGFR internalization and degradation, and mediates antibody-dependent cellular cytotoxicity in EGFR-expressing cells. Necitumumab is formulated in a citrate-buffered solution containing 10 mM sodium citrate, 40 mM sodium chloride, 133 mM glycine, 50 mM mannitol, and 0.01% (w/v) polysorbate 80; pH 6.0. The finished product is diluted in 0.9% sodium chloride solution (normal saline) prior to administration.
Characterization of the Drug Substance
The drug substance, necitumumab, has been thoroughly characterized using contemporary methods and this supports the choice of analytical methods selected for the control of the drug substance. The characterization data confirms that the intended purity and activity of necitumumab is consistently achieved.
Impurities and degradation products arising from manufacturing and/or storage were reported and characterized. These products were found to be within established limits and are considered to be acceptable.
Manufacturing Process and Process Controls of the Drug Substance and Drug Product
Necitumumab is produced in genetically engineered mammalian NS0 cells. The manufacture is based on a master and working cell bank system, where the master and working cell banks have been thoroughly characterized and tested for adventitious contaminants and endogenous viruses in accordance with International Council for Harmonisation (ICH) guidelines. Results from genetic characterization studies also demonstrated stability of these cell banks.
The manufacture of each batch of necitumumab begins with the thawing of a single vial of the working cell bank. The culture is serially scaled-up. At completion, the culture is harvested, clarified, and then transferred for further downstream processing. The downstream manufacture of necitumumab consists of a typical series of chromatography, viral inactivation, nanofiltration, and other filtration steps. Finally, the purified bulk drug substance is dispensed into single-use bags. The manufacturing process controls have been identified and applied to critical steps and intermediates during the manufacture of necitumumab, and include critical process parameters, critical in-process controls, and in-process specifications. The tests and limits for the critical process parameters and critical in-process controls have been described for each step and are supported by appropriate data.
Process validation of the necitumumab manufacturing process was performed at the commercial scale and at the proposed manufacturing site. The validation studies were conducted and described adequately, and the validation results demonstrate that the commercial-scale manufacturing process performs consistently and is capable of meeting predetermined acceptance criteria.
The manufacturing process of the drug product, Portrazza, has not changed throughout development, and is typical of commercial monoclonal antibody production. The process involves dilution of the drug substance with a formulation buffer which is identical to the drug substance formulation, sterile filtration, and finally aseptic filling into Type I glass vials stoppered with sterile stoppers, and crimp sealed. The process validation was performed using three commercial process batches covering the proposed process scale. The results demonstrate that the manufacturing process is capable of providing a finished product of consistent quality.
Operating process parameter ranges and process control acceptance criteria ensure that critical quality attributes are met. This determination of criticality was based on the risk analysis and experimental work described in the submission, in accordance with ICH Q8 and Q9. The critical process controls are sufficiently described and justified, and the results suggest that the process is in control and therefore acceptable.
Control of the Drug Substance and Drug Product
The release specifications for necitumumab were established based on the quality of the product used in toxicological and clinical testing, the stability of necitumumab, the process variability, and the variability of the analytical methods used to analyze the drug substance.
The specifications used for the release and stability of the drug product were based on the quality of Portrazza used in toxicological and clinical testing, the stability of the drug product, process variability, the variability of the analytical methods used to analyze the drug product, and ICH guidelines. These specifications were developed as part of an integrated approach to the control strategy. This commercial analytical testing strategy assures control of the finished product at release and throughout the proposed shelf life of the finished drug product. All non-compendial methods used in the release of the active substance have been satisfactorily validated, and fully justified. Compendial methods were appropriately qualified for use in assessing product quality for the necitumumab drug product.
The information provided regarding the development, manufacture, and control of the drug substance and drug product is considered satisfactory. Test results indicate consistency and uniformity of the important product quality characteristics.
Stability of the Drug Substance and Drug Product
Based on the stability data submitted, the proposed shelf life and storage conditions for the drug substance and drug product were adequately supported and are considered to be satisfactory. The proposed 24-month shelf life at 2°C to 8°C for Portrazza is considered acceptable.
The proposed packaging and components are considered acceptable.
Facilities and Equipment
The design, operations, and controls of the facilities and equipment that are involved in the production are considered suitable for the activities and products manufactured.
On-Site Evaluations (OSEs) of the facilities involved in the manufacture and testing of the necitumumab drug substance and the Portrazza drug product were not conducted as successful OSEs were recently performed for another product whose manufacturing process was similar.
Adventitious Agents Safety Evaluation
The drug substance manufacturing process incorporates adequate control measures to prevent contamination and maintain microbial control. Pre-harvest culture fluid from each lot is tested to ensure freedom from adventitious agents (bioburden, mycoplasma, and viruses). Purification steps designed to remove and/or inactivate viruses are adequately validated.
Raw materials of animal and recombinant origin used in the manufacturing process have been adequately tested to ensure freedom of adventitious agents. The excipients used in the drug product formulation are not from animal or human origin.