Summary Basis of Decision for Unituxin

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 Unituxin is located below.

Recent Activity for Unituxin

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 Unituxin, a product which contains the medicinal ingredient dinutuximab. 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: 2024-03-01

Drug Identification Number (DIN):

DIN 02483076 - 3.5 mg/mL, dinutuximab, solution, intravenous administration

Post-Authorization Activity Table (PAAT)

Activity/Submission Type, Control Number

Date Submitted

Decision and Date

Summary of Activities

NC # 273680

2023-03-27

Issued NOL 2023-06-05

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change in the drug product release or shelf‐life specifications. The submission was reviewed and considered acceptable, and an NOL was issued.

NC # 268952

2022-10-21

Cancellation Letter Received 2023-01-23

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change to reference standard qualification protocol. A number of issues were identified with the submission during review. The submission was cancelled by the sponsor.

NC # 256806

2021-09-17

Issued NOL 2021-11-05

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for changes affecting the quality control testing of the drug substance (release and stability). The submission was considered acceptable, and an NOL was issued.

NC # 250063

2021-02-26

Issued NOL 2021-06-03

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for changes affecting the quality control testing of the drug substance (release and stability). The submission was considered acceptable, and an NOL was issued.

NC # 245137

2020-10-09

Issued NOL 2021-01-22

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change in the primary container closure systems for the storage and shipment of the drug substance and a change in the supplier for a primary container closure component. The submission was reviewed and considered acceptable, and an NOL was issued.

NC # 241663

2020-04-17

2020-07-17

Issued NOL 2020-09-29

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for changes affecting the quality control testing of the drug substance (release and stability). The submission was reviewed and considered acceptable, and an NOL was issued.

NC # 235718

2020-01-31

Issued NOL 2020-03-31

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change in the drug substance release or shelf-life specifications. The submission was reviewed and considered acceptable, and an NOL was issued.

NC # 230377

2019-08-02

Issued NOL 2019-09-04

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for changes in the controls (in-process tests and/or acceptance criteria) applied during the drug product manufacturing process or on intermediates. The submission was reviewed and considered acceptable, and an NOL was issued.

Drug product (DIN 02483076) market notification

Not applicable

Date of first sale: 2019-05-01

The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.

NC # 224407

2019-02-12

Issued NOL 2019-04-03

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for changes affecting the quality control testing of the drug substance and drug product (release and stability). The submission was reviewed and considered acceptable, and an NOL was issued.

NDS # 212066

2017-12-14

Issued NOC 2018-11-28

NOC issued for New Drug Submission.

Summary Basis of Decision (SBD) for Unituxin

Date SBD issued: 2019-05-06

The following information relates to the New Drug Submission for Unituxin.

Dinutuximab

Drug Identification Number (DIN):

  • DIN 02483076 - 3.5 mg/mL, solution, intravenous administration

United Therapeutics Corporation

New Drug Submission Control Number: 212066

 

On November 28, 2018, Health Canada issued a Notice of Compliance to United Therapeutics Corporation for the drug product Unituxin.

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 Unituxin, in combination with granulocyte-macrophage colony-stimulating factor (GM-CSF), interleukin-2 (IL-2), and 13-cis-retinoic acid (RA), is favourable for the treatment of high-risk neuroblastoma in pediatric patients who achieve at least a partial response to prior first-line multi-agent, multimodality therapy.

 

1 What was approved?

 

Unituxin is an antineoplastic drug. It is indicated, in combination with granulocyte-macrophage colony-stimulating factor (GM-CSF), interleukin-2 (IL-2), and 13-cis-retinoic acid (RA), for the treatment of high-risk neuroblastoma in pediatric patients who achieve at least a partial response to prior first-line multi-agent, multimodality therapy.

The safety and effectiveness of Unituxin in geriatric patients have not been established.

Unituxin is contraindicated in patients with a history of anaphylaxis to dinutuximab (the medicinal ingredient in Unituxin), IL-2, GM-CSF, RA, or any excipients in the medicinal product.

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

Unituxin (3.5 mg/mL, dinutuximab) is presented as a solution. In addition to the medicinal ingredient, the solution contains histidine (20 mM), hydrochloric acid (to adjust pH), polysorbate 20 (0.05%), sodium chloride (150 mM), 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 Unituxin Product Monograph, approved by Health Canada and available through the Drug Product Database.

 

2 Why was Unituxin approved?

 

Health Canada considers that the benefit-risk profile of Unituxin, in combination with granulocyte-macrophage colony-stimulating factor (GM-CSF), interleukin-2 (IL-2), and 13-cis-retinoic acid (RA), is favourable for the treatment of high-risk neuroblastoma in pediatric patients who achieve at least a partial response to prior first-line multi-agent, multimodality therapy.

Neuroblastoma is a rare tumour of the sympathetic nervous system. It accounts for approximately 7% of malignancies in children younger than 15 years of age. The majority of patients (approximately 90%) are diagnosed by five years of age. According to the Canadian Cancer Society (CCS), approximately 380 children in the age group of 0 to 14 years were diagnosed with neuroblastoma in Canada in the period from 2009 to 2013 (about 76 new cases per year). Patients diagnosed at age over 18 months, with metastatic disease, MYCN oncogene amplification, diploid deoxyribonucleic acid (DNA), or unfavourable tumour histology, are considered to have high-risk disease. Approximately 40% of patients with neuroblastoma present with high-risk disease. Thus, about 30 new cases of high-risk neuroblastoma per year are diagnosed in Canada (CCS, 2009-2013 data).

Current standard treatment for patients with high-risk neuroblastoma is aggressive and includes dose-intensive chemotherapy, surgery, and radiotherapy. After completion of induction therapy, patients undergo consolidation therapy involving myeloablative therapy followed by autologous stem cell transplantation and post-consolidation therapy with RA. Despite this aggressive treatment, many patients relapse and long-term survival rates remain lower than 40%.

A surface glycopeptide expressed abundantly on neuroblastoma cells, disialoganglioside (GD2), has been utilized as a target for neuroblastoma immunotherapy. Dinutuximab, the medicinal ingredient in Unituxin, is a monoclonal antibody that reacts specifically with GD2 and induces cell lysis of GD2-expressing cells through antibody-dependent cell-mediated cytotoxicity (ADCC) and complement-dependent cytotoxicity. As an immunotherapy, dinutuximab has been evaluated in the treatment of neuroblastoma in several clinical trials conducted with dinutuximab administered alone, in combination with GM-CSF, or in combination with both GM-CSF and IL-2. These two cytokines were added to the dinutuximab treatment regimen as both were shown to enhance the ADCC mediated by dinutuximab therapy.

Unituxin, in combination with GM-CSF, IL-2, and RA (hereafter referred to as immunotherapy plus RA), has been shown to be efficacious in the treatment of pediatric patients with high-risk neuroblastoma who had achieved at least a partial response after induction therapy and radiation therapy prior to autologous stem cell transplantation. The market authorization of Unituxin was primarily based on safety and efficacy data derived from one pivotal, randomized, open-label, multicentre trial, DIV-NB-301 (ANBL0032). The results of the pivotal trial demonstrated statistically significant and clinically meaningful improvement in the event-free survival (the primary efficacy endpoint) and overall survival (the key secondary efficacy endpoint) in patients receiving immunotherapy plus RA compared to RA alone. In the confirmatory analysis, the hazard ratio (95% confidence interval) for event-free survival was 0.59 (0.39, 0.89) (p = 0.0124). The follow-up analysis resulted in a hazard ratio for overall survival of 0.60 (0.37, 0.96) (p = 0.0351). The pivotal study results were supported by comparable data from two single-arm supportive studies: a non-randomized extension cohort of the immunotherapy plus RA regimen, referred to as study DIV-NB-302 (ANBL0032), and a supportive safety study DIV-NB-303 (ANBL0931).

The large majority (94%) of patients receiving the immunotherapy plus RA regimen experienced at least one adverse event of grade 3 or higher severity compared to 60% of patients receiving RA alone. The most common adverse events in the immunotherapy plus RA group compared to the RA alone group included lymphopenia (48.6% vs. 11.7%), thrombocytopenia (34.1% vs. 10.8%), fever (37.0% vs. 2.7%), anemia (28.3% vs. 10.8%), neutropenia (28.3% vs. 7.2%), hypokalemia (31.2% vs. 1.8%), abdominal pain (28.3% vs. 7.2%), drug hypersensitivity (25.4% vs. 0.9%), increased alanine aminotransferase (21.0% vs. 2.7%), hyponatremia (21.7% vs. 1.8%), and capillary leak syndrome (21.7% vs. 0%). In addition to drug hypersensitivity and capillary leak syndrome, other attributable adverse events of special interest experienced at grade 3 or higher severity included hypotension (14.5% vs. 0%), urticaria (11.6% vs. 0%), anaphylactic reactions (25% vs. 0.9%), and peripheral neuropathy (5.8% vs. 0.9%). The highest frequency of grade 3 or higher toxicity in patients receiving immunotherapy plus RA occurred in course 2 and 4, when IL-2 was administered with dinutuximab.

A Serious Warnings and Precautions box was included in the Unituxin Product Monograph to highlight the risk of serious and potentially life-threatening infusion reactions and the risk of neurotoxicity (i.e., severe neuropathic pain, severe peripheral sensory neuropathy, and severe peripheral motor neuropathy). Required premedication and hydration prior to each Unituxin infusion, guidelines for pain management and infusion reactions, and dose modifications and/or discontinuation strategies for severe adverse reactions are also included in the Unituxin Product Monograph.

A Risk Management Plan (RMP) for Unituxin was submitted by United Therapeutics Corporation to Health Canada. Following revisions, 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. In addition, the sponsor was requested to provide educational material for healthcare professionals and patients.

The submitted inner and outer labels, package insert and Patient Medication Information section of the Unituxin Product Monograph meet the necessary regulatory labelling, plain language, and design element requirements.

A Look-alike Sound-alike brand name assessment was performed and the proposed name Unituxin was accepted.

Overall, the therapeutic benefits of Unituxin, in combination with GM-CSF, IL-2, and RA, are considered to outweigh the risks for the target patient population, when administered in specialized clinical setting where intense monitoring and supportive care are provided by highly trained and experienced health professionals. Appropriate warnings and precautions are in place in the Unituxin 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 Unituxin?

 

Submission Milestones: Unituxin

Submission Milestone Date
Submission filed: 2017-12-14
Screening  
Screening Acceptance Letter issued: 2018-02-01
Review  
On-Site Evaluation: 2018-10-15 - 2018-10-19
Quality Evaluation complete: 2018-11-19
Clinical/Medical Evaluation complete: 2018-11-23
Review of Risk Management Plan complete: 2018-10-01
Labelling Review complete, including Look-alike Sound-alike brand name assessment: 2018-11-27
Notice of Compliance issued by Director General, Biologics and Genetic Therapies Directorate: 2018-11-28

 

The Canadian regulatory decision on the non-clinical and clinical review of Unituxin was based on a critical assessment of the data package submitted to Health Canada. The foreign reviews completed by the European Medicines Agency (EMA) and the United States Food and Drug Administration (FDA) were used as added references.

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?

 

As part of the marketing authorization for Unituxin, Health Canada requested several activities to be addressed post-market. In addition to requirements outlined in the Food and Drugs Act and Regulations, activities include (but are not limited to) providing educational materials for healthcare professionals and patients.

 

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

Dinutuximab, the medicinal ingredient of Unituxin, is a chimeric human/mouse monoclonal antibody against disialoganglioside (GD2), a glycolipid expressed on neuroblastoma cells and normal cells of neuroectodermal origin, including the central nervous system and peripheral nerves. Dinutuximab binds to cell surface GD2 and induces cell lysis of GD2-expressing cells through antibody-dependent cell-mediated cytotoxicity and complement-dependent cytotoxicity.

Clinical Pharmacokinetic Comparability Study and Pharmacokinetics

Study DIV-NB-201 was a randomized, open-label, two-sequence crossover trial that evaluated the pharmacokinetic comparability, safety, and tolerability of dinutuximab manufactured by the United States National Cancer Institute (NCI) and dinutuximab manufactured by United Therapeutics Corporation. The study involved 28 pediatric patients with high-risk neuroblastoma.

The criteria for bioequivalence were met when examined with the statistical routines employed by Health Canada, in contrast to the outcome of the analysis provided by the sponsor. Based on the Health Canada-employed methods, the two products were considered pharmacokinetically comparable and no concerns were identified during the product quality review.

The sponsor also chose to include a population pharmacokinetic approach for characterization of the pharmacokinetic profile of dinutuximab in study DIV-NB-201 and in a cross-study population pharmacokinetic study, but both analyses were not considered in the final decision regarding this drug. The pharmacokinetic parameters of dinutuximab obtained by a non-compartmental analysis are included in the Unituxin Product Monograph.

While no specific studies have been conducted to evaluate the effect of sex, age, race, or organ impairment on dinutuximab pharmacokinetics, no apparent differences were observed on visual examination of the data in the studies conducted.

Immunogenicity

In clinical studies of pediatric patients treated with dinutuximab, anti-dinutuximab antibodies (also referred to as human anti-chimeric antibodies, HACA) were detected in 68 of 414 (16%) patients, and neutralizing antibodies were detected in 38 (56%) of those patients. The occurrence of neutralizing antibodies had no apparent impact on safety or efficacy based on a comparison of patients with and without detectable neutralizing antibodies. However, the small sample size precluded a determination of the clinical impact of the neutralizing antibodies. In addition, no marked differences in immunogenicity were observed in the comparative Study DIV-NB-201 (see Clinical Pharmacokinetic Comparability Study and Pharmacokinetics) between dinutuximab, manufactured by the United States National Cancer Institute (NCI) and dinutuximab, manufactured by United Therapeutics Corporation.

The clinical pharmacology data support the use of Unituxin for the recommended indication.

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

Clinical Efficacy

The clinical efficacy of Unituxin, in combination with granulocyte-macrophage colony-stimulating factor (GM-CSF), interleukin-2 (IL-2), and 13-cis-retinoic acid (RA), in the treatment of high-risk neuroblastoma was demonstrated in the pivotal study DIV-NB-301 (ANBL0032). Additional efficacy data were derived from the supportive study DIV-NB-302 (ANBL0032).

Pivotal Study - DIV-NB-301 (ANBL0032)

The pivotal study, DIV-NB-301 (ANBL0032), was a Phase III, multicentre, open-label, randomized clinical trial in pediatric patients with high-risk neuroblastoma who were randomized in a 1:1 ratio to receive Unituxin, GM-CSF, IL-2, and RA (hereafter referred to as immunotherapy plus RA) or RA alone.

Eligible patients must have completed intensive induction chemotherapy followed by autologous stem cell transplantation and radiation therapy. They must have achieved a partial response, very good partial response, or complete response according to the International Neuroblastoma Response Criteria at the pre-autologous stem cell transplantation evaluation prior to enrollment in the study. Patient enrollment and randomization took place between Day 50 and Day 77 post-autologous stem cell transplantation.

Patients randomized to the immunotherapy plus RA arm (number of patients [n] = 113) received up to five cycles of Unituxin in combination with GM-CSF or IL-2 plus RA, followed by one cycle of RA alone. Patients randomized to the RA arm (n = 113) received six cycles of RA.

Although eligible for enrollment in the study, patients with biopsy-confirmed residual disease following autologous stem cell transplantation were ineligible for randomization. These patients (n = 25) were non-randomly assigned to treatment in the immunotherapy and RA group and were excluded from the primary analysis, but included in the safety analysis (see Clinical Safety).

The primary efficacy endpoint of the study was investigator-assessed event-free survival, defined as the time from randomization to the first occurrence of relapse, progressive disease, secondary malignancy, or death. The secondary efficacy endpoints included overall survival, tumour response, minimal residual disease, event-free survival and overall survival in the subgroup of high-risk International Neuroblastoma Staging System (INSS) Stage 4 neuroblastoma patients, and event-free survival and overall survival within other subgroups broken out by several baseline prognostic factors.

Planned interim analyses were carried out every six months starting after 20% of the planned events had occurred. To adjust for effects of repeated testing, statistical boundaries were set for the hazard ratio at each interim analysis.

At a pre-planned interim analysis for event-free survival, and subsequently, overall survival, the Data Safety Monitoring Committee recommended early cessation of randomization on the basis of shown superiority of immunotherapy plus RA over RA alone with regard to the event-free survival endpoint. This interim analysis was designated as the primary analysis. Subsequent analysis was conducted six months after the primary analysis (referred to as a confirmatory analysis) and three years after the confirmatory analysis (referred to as a follow-up analysis). Hazard ratios for immunotherapy plus RA arm versus RA alone arm were calculated for event-free survival and overall survival at each analysis point, using multivariate analysis to take into account prognostic variables that may have affected treatment outcomes. The hazard ratios (95% confidence interval [CI]) for event-free survival and overall survival in the primary analysis were 0.52 (0.33, 0.82) (p = 0.0046) and 0.59 (0.33, 1.05) (p = 0.0704), respectively. In the confirmatory analysis, the hazard ratio for event-free survival was 0.59 (0.39, 0.89) (p = 0.0124) and the hazard ratio for overall survival was 0.58 (0.34, 1.00) (p = 0.0501). The follow-up analysis resulted in a hazard ratio for event-free survival of 0.66 (0.44, 0.98) (p = 0.0378) and a hazard ratio for overall survival of 0.60 (0.37, 0.96) (p = 0.0351). The Kaplan-Meier curves of both endpoints at each point of analysis for the immunotherapy plus RA and the RA alone separated between three and six months post-randomization and remained separated to the data cut-off dates. Consistent separation of Kaplan-Meier curves implies real treatment differences.

A subgroup of intention-to-treat population with high-risk INSS Stage 4 neuroblastoma patients was also analyzed for event-free survival and overall survival. For event-free survival, Kaplan-Meier curves in the primary and confirmatory analyses showed statistically significant differences favouring immunotherapy plus RA over RA alone. For overall survival, the curves in each analysis remained separated but these differences were not statistically significant.

Supportive Study - DIV-NB-302 (ANBL0032)

Study DIV-NB-302 (ANBL0032) was an extension of the immunotherapy plus RA arm of study DIV-NB-301 (ANBL0032). The patient accrual continued solely into the immunotherapy plus RA arm once the randomization was terminated at the recommendation of the Data Safety and Monitoring Committee for reasons of improved efficacy over the RA alone arm. Eight hundred and thirty-eight patients were enrolled, 787 of whom received at least one dose of immunotherapy plus RA. The population accrued into this study was fundamentally similar to that accrued into the immunotherapy plus RA arm during randomization phase, with a few changes implemented through protocol amendments. The treatment regimen was the same except for some amended changes such as a narrowing of the acceptable range of infusion times. The primary endpoint remained event-free survival and the main secondary endpoint for the intention-to-treat population was overall survival. These endpoints were also determined for the subgroup of patients with INSS Stage 4 disease (n = 371). Since the study did not have a comparator group against which the treatment outcomes could be compared, only informal comparisons were made with the results in immunotherapy plus RA arm of the pivotal trial.

The two-year event-free survival (95% confidence interval) of 66% (62%, 70%) compared favourably with that of the immunotherapy plus RA arm in study DIV-NB-301 (ANBL0032) (two-year event-free survival, confirmatory analysis: 65.5% [56.1%, 75.2%]). The two-year overall survival was 83.3% (80%, 86.5%) in study DIV-NB-302 (ANBL0032), compared to 85.4% (78.2%, 92.6%) in that arm in the confirmatory analysis of study DIV-NB-301 (ANBL0032). In both studies, the Kaplan-Meier curves for both endpoints for immunotherapy plus RA-treated patients were very similar.

Indication

The New Drug Submission for Unituxin was filed by the sponsor with the following indication:

  • Unituxin (dinutuximab) is indicated for the treatment of high-risk neuroblastoma in pediatric patients, when used in combination with cytokines, as part of a multimodality therapy.

To ensure safe and effective use of the product, Health Canada revised the proposed indication to reflect the treatment regimen used and the target patient population studied in the pivotal clinical trial. Accordingly, Health Canada approved the following indication:

  • Unituxin (dinutuximab) is indicated, in combination with granulocyte-macrophage colony-stimulating factor (GM-CSF), interleukin-2 (IL-2), and 13-cis-retinoic acid (RA), for the treatment of high-risk neuroblastoma in pediatric patients who achieve at least a partial response to prior first-line multi-agent, multimodality therapy.

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

Clinical Safety

The safety of Unituxin, in combination with granulocyte-macrophage colony-stimulating factor (GM-CSF), interleukin-2 (IL-2), and 13-cis-retinoic acid (RA), in the treatment of high-risk neuroblastoma was evaluated in the pivotal study DIV-NB-301 (ANBL0032) (described in the Clinical Efficacy section) and two supportive studies, DIV-NB-302 (ANBL0032) and DIV-NB-303 (ANBL0931).

The safety population of the pivotal study DIV-NB-301 (ANBL0032) included 249 treated patients. Of these, 138 patients received immunotherapy plus RA (113 randomized patients and 25 non-randomized patients with biopsy-confirmed residual disease following autologous stem cell transplantation) and 111 patients received RA alone. All patients in the safety population were analyzed according to the treatment received. As per the protocol of the Children's Oncology Group (COG), sites were required to report only grade 3 or higher-grade adverse events, although as least one grade 1 or 2 adverse event was reported in 169 and 181 patients, respectively.

The main analysis for safety was part of the confirmatory analysis (herein referred to as confirmatory safety analysis), conducted 6 months after the close of randomization. In this analysis, the most commonly reported adverse events in the immunotherapy plus RA group included: pyrexia (70%), platelet disorder (65%), lymphopenia (62%), drug hypersensitivity (59%), hypotension (58%), hyponatremia (56%), increased alanine aminotransferase (54%), abdominal pain (54%), low hemoglobin (49%), vomiting (44%), diarrhea (42%), and hypokalemia (42%). The proportions of patients experiencing grade 3, 4, and 5 toxicity in the immunotherapy plus RA group were 93%, 49%, and 1%, respectively (compared to 55%, 22%, and 1%, respectively, in the RA alone group). The incidence of grade 3 or higher-grade toxicities attributable to study therapy overall was 92.8% in the immunotherapy plus RA group and 36.9% in the RA alone group. Specific types of such adverse events in the immunotherapy plus RA arm that exceeded 19% included lymphopenia (48.6%), thrombocytopenia (34.1%), fever (37%), anemia (28.3%), granulocytopenia (28.3%), hypokalemia (31.2%), abdominal pain (28.3%), drug hypersensitivity (25.4%), elevated alanine aminotransferase (21%), hyponatremia (21.7%), capillary leak syndrome (21.7%), and pain (19.6%).

Initially, adverse events of special interest, also called targeted toxicities, included drug hypersensitivity, capillary leak syndrome, and peripheral neuropathy. This list was expanded in the follow-up safety analysis to include hypotension, urticaria, anaphylactic reactions, dyspnea, cytokine release syndrome, and acute respiratory distress syndrome. These adverse events were reported regardless of grade. In the follow-up safety analysis of the immunotherapy plus RA arm, adverse events that were attributable to study therapy included hypotension reported in 50% of patients, hypersensitivity (53.4%), urticaria (39.2%), capillary leak syndrome (38.5%), and anaphylactic reactions (25%). Only 4.1% of these patients experienced cytokine release syndrome and/or dyspnea and no patients experienced acute respiratory distress syndrome. The higher incidences of targeted toxicities occurred during course 2 and 4 when IL-2 was given. The proportion of patients reporting capillary leak syndrome and/or anaphylactic reactions was nearly twofold greater in courses 2 and 4 compared to other courses. According to the confirmatory safety analysis, only six deaths occurred in the first 30 days after the last study therapy: four in the immunotherapy plus RA arm and two in the RA alone arm. All except two deaths were due to progressive disease. One patient in the immunotherapy plus RA arm died from therapy-related causes. This death was due to capillary leak syndrome secondary to an overdose of IL-2 evoked by a medication error. The second death, which occurred in the RA alone arm, was attributed to hypoxia of unknown origin.

The follow-up safety analysis was performed three and a half years after patient randomization was terminated and three years after the confirmatory safety analysis. Results of this analysis were very similar to those in the confirmatory safety analysis. The proportion of grade 3, 4, and 5 toxicities were 93%, 49%, and 1% in the immunotherapy plus RA group versus 59%, 23%, and 1%, respectively, in the RA alone group.

Overall, the addition of Unituxin, GM-CSF, and IL-2 to RA therapy was associated with a substantial increase in the number and severity of reported adverse events as compared to therapy with RA alone. Adverse events tended to be more prevalent and more severe during IL-2 courses as compared to GM-CSF courses. Given the fact that only six subjects discontinued study therapy due to an adverse event during this study and given that only one death could be directly attributable to study therapy with immunotherapy plus RA, this regimen appears tolerable for most subjects when administered in specialized clinical setting by highly trained and experienced healthcare providers.

Supportive Studies - DIV-NB-302 (ANBL0032) and DIV-NB-303 (ANBL0931)

Study DIV-NB-302 (ANBL0032) was a non-randomized extension of the immunotherapy plus RA arm of the pivotal study DIV-NB-301 (ANBL0032). It involved continuation of patient accrual solely into the immunotherapy plus RA arm once randomization was terminated at the recommendation of the Data Safety and Monitoring Committee for reasons of improved efficacy over the RA alone arm (see Clinical Efficacy).

The safety profile in this single-cohort study reflected that of the immunotherapy plus RA group in the pivotal study. Similar high rates of attributable toxicities were reported in studies DIV-NB-301 (ANBL0032) and DIV-NB-302 (ANBL0032) in the immunotherapy plus RA groups, both for non-targeted and targeted toxicities. Ninety percent of patients reported at least one targeted toxicity: hypotension (67%), hypersensitivity (59%), urticaria (54%), capillary leak syndrome (47%), anaphylactic reaction (17%), dyspnea (13%), cytokine release syndrome (12%), and acute respiratory distress syndrome (2%). No new safety signals were noted. As in study DIV-NB-301 (ANBL0032), higher incidences of toxicity, particularly grade 4 hypotensive events, anaphylactic reactions, and capillary leak syndrome, were reported during courses 2 and 4 following IL-2 administration.

Study DIV-NB-303 (ANBL0931) was the second major supportive study, designed as a multicentre, single-arm study with a primary objective to better define the safety profile of the immunotherapy plus RA regimen. One hundred and four patients received at least one dose of study therapy and 77% of them completed study therapy. Among 24 patients who discontinued study therapy prematurely, 14 patients discontinued study drug due to toxicity (8 patients) or withdrawal of consent (6 patients). As in studies DIV-NB-301 (ANBL0032) and DIV-NB-302 (ANBL0032), the most common (≥25%) grade 3 or higher-grade adverse events attributable to Unituxin were pyrexia (64%), pain (39%), decreased platelet count (39%), hypokalemia (39%), decreased lymphocyte count (35%), hyponatremia (28%), hypotension (27%), and decreased neutrophil count (25%). Just over half of reported adverse events were considered related to the immunotherapy plus RA regimen. Overall, the safety profile of the Unituxin-containing regimen was similar to that observed in studies DIV-NB-301 (ANBL0032) and DIV-NB-302 (ANBL0032), except for the occurrences of nasal congestion (20%) and wheezing (15%), which were not reported in study DIV-NB-301 (ANBL0032).

A Serious Warnings and Precautions box was included in the Unituxin Product Monograph to highlight the risk of serious and potentially life-threatening infusion reactions and the risk of neurotoxicity (i.e., severe neuropathic pain, severe peripheral sensory neuropathy, and severe peripheral motor neuropathy). Required premedication and hydration prior to each Unituxin infusion, guidelines for pain management and infusion reactions, and dose modifications and/or discontinuation strategies for severe adverse reactions are also included in the Unituxin Product Monograph.

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

 

 

 

7.2 Non-Clinical Basis for Decision

 

The non-clinical development program for dinutuximab, the medicinal ingredient in Unituxin, included in vitro and in vivo studies that evaluated its binding characteristics, mechanism of action, anti-tumour activity, pharmacokinetics, tissue cross-reactivity, and toxicology. Twenty-one studies were submitted as part of the non-clinical data package.

Dinutuximab was found to bind with high affinity and specificity to disialoganglioside (GD2) antigen in neuroblastoma and melanoma cells and to induce lysis of these cells via antibody-dependent cellular cytotoxicity (ADCC) and complement-dependent cytotoxicity. Co-administration with GM-CSF or IL-2 enhanced ADCC. Administration of dinutuximab suppressed the establishment, and growth of established, xenografted human tumours in nude mice.

Relevant findings of the pivotal toxicology study in rats included liver effects (i.e., histological changes, organ weight increases, and increased concentration of hepatic enzymes) that remained at the end of the 6-week recovery period. No sex-related effects were apparent. A no-observed-adverse-effect level (NOAEL) could not be established because of liver-related changes and changes related to hematopoiesis observed in both sexes at the lowest dose tested. In the clinical DIV-NB-303 (ANBL0931) study, increased levels of aspartate aminotransferase (AST) and alanine aminotransferase (ALT) occurred in 67% and 66% of the study subjects, respectively.

Intravenous administration of dinutuximab in dogs and rats resulted in pain at the lowest doses tested. Neurotoxicity, reported as histologic changes, was observed in the repeat-dose toxicology study in juvenile cynomolgus monkeys. These results are consistent with pain, peripheral neuropathy, and transverse myelitis observed in the humans. In addition, cardiovascular effects of intravenous infusion of dinutuximab in monkeys included increased blood pressure and heart rate as well as shortening of PR and QT intervals. No effects on respiratory parameters were noted.

Reproductive or developmental studies have not been conducted.

The non-clinical findings are regarded as consistent with the mechanism of action of dinutuximab. The results of the non-clinical studies as well as the potential risks to humans have been included in the Unituxin Product Monograph. In view of the intended use of Unituxin, there are no pharmacological or toxicological issues within this submission which preclude authorization of the product.

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

 

 

7.3 Quality Basis for Decision

 

Characterization of the Drug Substance

Dinutuximab, the medicinal ingredient of Unituxin, is a glycosylated chimeric immunoglobulin G1 (IgG1) human/mouse monoclonal antibody, produced in a murine myeloma cell line (SP2/0 hybridoma cell line). The antibody incorporates human constant regions for the heavy chain IgG1 and the kappa light chain, along with the murine variable regions targeted specifically against human disialoganglioside (GD2). This glycolipid is expressed on neuroblastoma cells and on normal cells of neuroectodermal origin, including the central nervous system and peripheral nerves. Dinutuximab binds to cell surface GD2 and induces cell lysis of GD2-expressing cells through antibody dependent cell-mediated cytotoxicity and complement-dependent cytotoxicity.

Detailed characterization studies were performed to provide assurance that dinutuximab consistently exhibits the desired characteristic structure and biological activity.

Results from process validation studies indicate that the processing steps adequately control the levels of product- and process-related impurities. The impurities that were reported and characterized were found to be within established limits.

Manufacturing Process and Process Controls of the Drug Substance and Drug Product

The drug substance is produced by recombinant deoxyribonucleic acid (DNA) technology in a murine myeloma cell line (SP2/0 hybridoma cell line). Following harvesting, the drug substance is subjected to a series of purification and virus inactivation and removal steps. The drug substance is filled into plastic bags and stored at 2ºC to 8ºC.

The sponsor has demonstrated that the proposed drug substance manufacturing facility is capable of consistently manufacturing dinutuximab of acceptable quality.

The drug product manufacturing process takes place at the same facility where the drug substance is manufactured. The process includes mixing the formulated drug substance bulk and filtration steps. One drug substance batch is used to manufacture one drug product batch, and no pooling is permitted. Thus, a drug product batch size is dependent on the drug substance yield.

The sponsor has demonstrated that the proposed drug product manufacturing facility is capable of consistently manufacturing Unituxin of acceptable quality.

Unituxin is provided as a sterile aqueous solution containing 3.5 mg/mL dinutuximab in a total volume of 5 mL, resulting in 17.5 mg of dinutuximab per single-dose vial. It is formulated in 20 mM histidine, 150 mM NaCl, and 0.05% polysorbate 20, with pH of 6.8.

The sponsor has demonstrated the comparability of the drug product manufactured initially for most of the clinical program to the drug product manufactured for late-stage trials and proposed for marketing through a combination of physical and chemical testing, in vitro functional analysis, and comparison of the forced degradation profiles.

The manufacturing process is considered to be adequately controlled within justified limits.

All non-medicinal ingredients (excipients) found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations. The compatibility of dinutuximab with the excipients is supported by the stability data provided.

Control of the Drug Substance and Drug Product

The drug substance and drug product are tested against suitable reference standards to verify that they meet approved specifications. Analytical procedures are validated and in compliance with International Council for Harmonisation (ICH) guidelines.

Through Health Canada's lot release testing and evaluation program, three manufactured final product lots were tested using a subset of release methods. All results obtained during consistency lot testing and in-house data analyses were acceptable and within the manufacturer's specifications.

As a Schedule D (biologic) drug, Unituxin is subject to Health Canada's Lot Release Program before sale in accordance with the Health Canada's Guidance for Sponsors: Lot Release Program for Schedule D (Biologic) Drugs.

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 18-month shelf life at 2ºC to 8ºC for Unituxin is considered acceptable.

The compatibility of the drug product with the container closure system was demonstrated through compendial testing and stability studies. The container closure system met all validation test acceptance criteria.

The proposed packaging and its 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.

An on-site evaluation of the facilities involved in the manufacture and testing of the drug substance and drug product was completed by Health Canada with a satisfactory rating.

The site involved in production is compliant with Good Manufacturing Practices.

Adventitious Agents Safety Evaluation

The dinutuximab 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 microorganisms (bioburden, mycoplasma, and viruses) and appropriate limits are set. Purification process steps designed to remove and inactivate viruses are adequately validated.

Raw materials used in the manufacturing process are adequately tested to ensure freedom from adventitious agents. The excipients used in the drug product formulation are not of animal or human origin.