Summary Basis of Decision for Catena ®
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:
Catena®
Idebenone, 150 mg, Tablet, Oral
Santhera Pharmaceuticals (Switzerland) Ltd.
Submission control no: 117672
Date issued: 2009-03-06
Foreword
Health Canada's Summary Basis of Decision (SBD) documents outline the scientific and regulatory considerations that factor into Health Canada regulatory decisions related to drugs and medical devices. SBDs are written in technical language for stakeholders interested in product-specific Health Canada decisions, and are a direct reflection of observations detailed within the evaluation reports. As such, SBDs are intended to complement and not duplicate information provided within the Product Monograph.
Readers are encouraged to consult the 'Reader's Guide to the Summary Basis of Decision - Drugs' to assist with interpretation of terms and acronyms referred to herein. In addition, a brief overview of the drug submission review process is provided in the Fact Sheet entitled 'How Drugs are Reviewed in Canada'. This Fact Sheet describes the factors considered by Health Canada during the review and authorization process of a drug submission. Readers should also consult the 'Summary Basis of Decision Initiative - Frequently Asked Questions' document.
The SBD reflects the information available to Health Canada regulators at the time a decision has been rendered. Subsequent submissions reviewed for additional uses will not be captured under Phase I of the SBD implementation strategy. For up-to-date information on a particular product, readers should refer to the most recent Product Monograph for a product. Health Canada provides information related to post-market warnings or advisories as a result of adverse events (AE).
For further information on a particular product, readers may also access websites of other regulatory jurisdictions. The information received in support of a Canadian drug submission may not be identical to that received by other jurisdictions.
Other Policies and Guidance
Readers should consult the Health Canada website for other drug policies and guidance documents. In particular, readers may wish to refer to the 'Management of Drug Submissions Guidance'.
1 Product and submission information
Brand name:
Manufacturer/sponsor:
Medicinal ingredient:
International non-proprietary Name:
Strength:
Dosage form:
Route of administration:
Drug identification number(DIN):
- 02314150
Therapeutic Classification:
Non-medicinal ingredients:
Submission type and control no:
Date of Submission:
Date of authorization:
2 Notice of decision
On July 23, 2008, Health Canada issued a Notice of Compliance under the Notice of Compliance with Conditions (NOC/c) Policy to Santhera Pharmaceuticals (Switzerland) Ltd. for the drug product Catena® (idebenone). The product was authorized under the NOC/c Policy on the basis of the promising nature of the clinical evidence, and the need for a confirmatory study to verify its clinical benefit. Patients should be advised of the fact that the market authorization was issued with conditions.
Catena® contains the medicinal ingredient idebenone, which is a synthetic short-chain analogue of Coenzyme Q10, a component of mitochondrial respiratory chain. Although, the exact mechanism of action of Catena® is unknown, it is thought to facilitate ATP production.
Catena® is indicated for use in patients with Friedreich's Ataxia, where it may be useful for the symptomatic management of this disease. The clinical trial data supporting this conditional approval was based on patients ranging in age between 9 to 18 years.
Friedreich's Ataxia is a rare and devastating hereditary disease that is associated with progressive degeneration of nerves and heart disease. Patients with Friedreich's Ataxia produce abnormally low ATP and experience slurred speech, walking abnormalities, and loss of sensation and reflexes. There is currently no approved treatment for Friedreich's Ataxia in Canada.
The market authorization was based on quality, non-clinical, and clinical information submitted. A six month placebo-controlled study in Friedreich's Ataxia patients was conducted to determine the safety and efficacy of various doses of Catena®. This study was conducted in forty eight (n=48) patients between 9 and 18 years of age. Adverse events were generally mild. One patient experienced low white blood cell count at month-6 of the trial, which returned to normal after the use of Catena® was discontinued. The therapeutic benefit observed in this study is promising, Catena® demonstrated an acceptable safety and tolerability profile based on the results of this trial, as well as non-clinical, and post-marketing data. Continuing safety monitoring will be ongoing, as required within the framework of the NOC/c Policy.
Catena® (150 mg idebenone) is presented in tablet form, should be administered orally with food, and should not be broken or chewed. Catena should be administered at the recommended starting dose, adjusted according to the patient's body weight. This dose may be increased to the higher dose if required. Dosing guidelines are available in the Product Monograph.
Catena® is contraindicated in patients who are hypersensitive to idebenone or to any ingredient in the formulation or component of the container, who have moderate or severe hepatic impairment, and/or who have severe renal impairment. Patients should have a normal complete blood cell count prior to the use of Catena®, and should be monitored after initiating therapy or increasing the dose. Liver function tests should be administered after initiating therapy with Catena® and/or dose increase. Catena® should be administered under the conditions stated in the Product Monograph taking into consideration the potential risks associated with the administration of this drug product. Detailed conditions of use for Catena® are described in the Product Monograph.
Based on the Health Canada review of data on quality, safety, and effectiveness, Health Canada considers that the benefit/risk profile of Catena® is favourable for use in the symptomatic management of patients with Friedreich's Ataxia.
3 Scientific and Regulatory Basis for Decision
3.1 Quality Basis for Decision
3.1.1 Drug Substance (Medicinal Ingredient)
General Information
Catena® contains the medicinal ingredient idebenone, which is a synthetic short-chain analogue of Coenzyme Q10, a component of mitochondrial respiratory chain. Although, the exact mechanism of action of Catena® is unknown, it is thought to facilitate adenosine triphosphate (ATP) production. Catena® is indicated for use in patients with Friedreich's Ataxia (FRDA), where it may be useful for the symptomatic management of this disease. Patients with FRDA produce abnormally low levels of ATP and experience slurred speech, walking abnormalities, and loss of sensation and reflexes. There is currently no approved treatment for FRDA in Canada.
Manufacturing Process and Process Controls
In-process controls performed during manufacture were reviewed and are considered acceptable. The specifications for the raw materials used in manufacturing the drug substance are also considered satisfactory.
Characterization
The structure of idebenone is considered to be adequately elucidated and the representative spectra have been provided. Physical and chemical properties have been described and are found to be satisfactory.
Control of Drug Substance
The drug substance specifications and analytical methods used for quality control of idebenone are considered acceptable.
Stability
Based on the long-term stability data submitted, the proposed shelf-life for the drug substance is supported and considered to be satisfactory.
3.1.2 Drug Product
Description and Composition
Catena® (idebenone) tablets are orange, round, biconvex, film-coated tablets containing 150 mg idebenone. The tablets are engraved with “150” on one side and with the Santhera logo on the other side.
Each tablet contains the following non-medicinal ingredients: croscarmellose sodium lactose monohydrate, magnesium stearate, microcrystalline cellulose, polyethylene glycol 3350, polyvinyl alcohol, povidone K25, silicon dioxide, talc, titanium dioxide (CI 77891), FD&C yellow Number 6 aluminium lake (CI 15985). Catena® is supplied in high density polyethylene bottles containing 90, 180, 270 and 450 tablets.
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 idebenone with the excipients is demonstrated by the stability data presented on the proposed commercial formulation.
Pharmaceutical Development
Pharmaceutical development data, including development of the container closure system, are considered acceptable. Data provided in this section include composition of Catena®, rationale for choice of formulation, manufacturing process including packaging, information on batches used in in vitro studies for characterization, and discussion on the effect of formulation change on the safety and/or efficacy of Catena®. Studies which justified the type and proposed concentration of excipients to be used in the drug product were also reviewed and are considered to be acceptable.
Manufacturing Process and Process Controls
The validated process is capable of consistently generating product that meets release specifications.
Control of Drug Product
The validation process is considered to be complete. Validation reports were submitted for in-process and release testing of the drug product, and no anomalies were present. The results for all of the batches were within the proposed specification limits.
Stability
Based on the long-term stability data submitted, the proposed 24-month shelf-life at 15-30°C for Catena® is considered acceptable.
3.1.3 Facilities and Equipment
The design, operations, and controls of the facility and equipment that are involved in the production are considered suitable for the activities and products manufactured.
3.1.4 Adventitious Agents Safety Evaluation
Not applicable. The excipients used in the drug product formulation are not from animal or human origin.
3.1.5 Conclusion
The Chemistry and Manufacturing information submitted for Catena® has demonstrated that the drug substance and drug product can be consistently manufactured to meet the approved specifications. Proper development and validation studies were conducted, and adequate controls are in place for the commercial processes.
3.2 Non-Clinical Basis for Decision
3.2.1 Pharmacodynamics
Primary Pharmacodynamics
The mode of action of idebenone is potentially two-fold. First, a series of studies using in vitro mitochondrial preparations from heart and brain tissue demonstrated that idebenone mediates the transfer of electrons between complex I, II and III in the mitochondrial electron transport chain thereby reconstituting the generation of ATP under pathological conditions. Second, idebenone was shown to protect against oxidative cell damage. Idebenone protected cells derived from FRDA patients from endogenous oxidative stress resulting in increased cell survival. In a mouse model of FRDA, idebenone given orally reduced disease-specific changes in cardiac tissue histopathology and function and also prolonged the life expectancy in these animals slightly, but significantly. Idebenone was also able to protect mitochondrial function in homogenates of human heart tissue. While the idebenone concentrations tested in the various in vitro studies were generally much higher than the human plasma at maximum concentration (Cmax) after a high dose, idebenone was effective in in vivo models and therefore collectively, these studies provide a plausible mode of action for idebenone in the treatment of FRDA.
Secondary Pharmacodynamics:
In a series of secondary pharmacodynamic studies not directly related to treatment of FRDA, idebenone prevented vascular lesions associated with hypertension, ameliorated neurologic and energy deficits after experimental stroke, prevented cytotoxic and vasogenic cerebral edema, prolonged survival after anoxia/hypoxia, and improved cerebral ischemia-induced memory impairment. Idebenone at high concentrations also increased red blood cell deformability, possibly by increasing ATP levels, which may be the reason for reduced hemolysis and longer lifespan seen for red blood cells from hypertensive rats. Importantly there were no safety concerns identified in the secondary pharmacodynamic studies.
Safety Pharmacology
No significant safety concerns were identified in the safety pharmacology studies. No effects were seen on either the central or somatic nervous systems apart from a slight decrease in body temperature of rats given 300 mg/kg, orally. Idebenone had no effect on intestinal transport in mice or gastric secretion in rats. Inhibitory and spasmolytic effects in smooth muscle preparations were observed at high concentrations in vitro. Idebenone significantly inhibited the tail currents of the hERG channel with a concentration far above the expected therapeutic plasma concentration. There were no idebenone-related effects in electrocardiograms from dogs in the repeat-dose toxicology studies.
3.2.2 Pharmacokinetics
Absorption
Idebenone demonstrated dose-dependent absorption and rapid first-pass metabolism in all species tested. In dogs, absorption appeared to plateau between 100 and 500 mg/kg and was greater in recently fed animals.
Distribution
In vitro protein binding at concentrations from 1 to 1000 ng/mL was high, averaging 98.5% in human, 98.3% in dog, and 98.0% in rat plasma. Rats were given idebenone at oral doses of 10 and 300 mg/kg/day for 7 days. After multiple dosing, idebenone concentrations in most tissues were slightly increased over the single dose and attained steady-state within 4-7 days, with the highest concentrations in intestine, stomach, kidney, and liver. No significant amounts of parent drug or drug-derived materials accumulated in the rats during repeated dosing. Idebenone was detected in fetal plasma and tissues, indicating that the activity crossed the placenta. A relatively low concentration of idebenone was detected in rat milk. The maximum brain concentration of parent idebenone was approximately 5% of that in plasma and the concentration of metabolites was much lower.
Metabolism
Metabolic activity consists of a progressive oxidative shortening of the side chain of parent idebenone leading successively to the metabolites. Parent idebenone and all of the shorter-chain metabolites are also glucuronidated or sulfatated resulting in conjugated forms of idebenone as well as the metabolites. The metabolites were present at much higher concentrations (>99%) than the parent idebenone (<1%) in plasma, and conjugates of the parent and metabolites were at higher levels than the non-conjugated forms. The same spectrum of metabolites was seen in humans, rats, and dogs, thus justifying the use of rats and dogs in the non-clinical safety assessment of idebenone.
Excretion
Idebenone excretion studies were conducted in rats and dogs. Rats were given idebenone orally at 10 and 300 g/kg/day for 7 days and after the 7th dose, excretion was via urine and feces (70.2% and 31.1% respectively) and no accumulation of idebenone was observed. Dogs were given idebenone orally at a dose of 3 mg/kg and intravenously (IV) at a dose of 3 mg/kg. Idebenone was almost entirely excreted via urine and feces. After oral administration, 97.26% of the idebenone dose was excreted of which 59.62% was in the urine and 36.33% in the feces. After IV administration, 88.58% of the idebenone dose was excreted of which 56.77% was in the urine and 28.12% in the feces.
Drug-Drug Interaction
Idebenone inhibited major cytochrome P450 (CYP) isoforms with IC50 values of 0.81 to 3.5 µg/mL, although plasma therapeutic levels are much lower (Cmax=23.6 ng/mL) suggesting this is unlikely to be clinically relevant for humans. Furthermore, the CYP inhibition assay was conducted with microsomes incubated in a protein-free buffer. Since idebenone is highly bound to plasma proteins, the free concentration in plasma would be <1 ng/mL or approximately three-folds lower than the lowest IC50.
3.2.3 Toxicology
Single-Dose Toxicity
Idebenone has a very low order of acute oral toxicity in mice and rats (LD50≥10,000 mg/kg). LD50 values for the main metabolite were lower, but it would still be considered to have a low order of acute toxicity.
Repeat-Dose Toxicity
A 13-week repeat-dose toxicity study was conducted in mice where idebenone was administered orally at doses of 0, 210, 640, 1280, and 2000 mg/kg. There were no mortalities in this study. The no observable adverse effect level (NOAEL) was 640 mg/kg/day. There was a noticeable decrease in food intake at Week 1 in all idebenone groups. At the 2000 mg/kg/day dose, there were decreases in white blood cell counts in females and decreases in heart and adrenal gland weights in males. Also, at the 2000 mg/kg/day dose, the mice experienced focal necrosis of the liver, extra-medullary haematopoiesis, white pulp atrophy of spleen and tubular basophilia (all mild), and tubular casts in kidney.
The repeat-dose toxicity studies in rats ranged from 7 days to 52 weeks in duration and idebenone doses ranged from 0-2500 mg/kg/day. The only significant effect with repeat-dose oral administration was the development of forestomach lesions, a rodent-specific phenomenon in mice and rats at high doses of 100-2500 mg/kg/day due to direct irritation. Due to the severity of gastrointestinal lesions, the NOAEL was 500 mg/kg/day.
The repeat-dose toxicity studies in dogs ranged from 1 week to 52 weeks in duration and idebenone doses ranged from 0-1250 mg/kg. No systemic toxicity was identified in dogs in which the only effects were gastrointestinal disturbances such as loose feces, diarrhea, and emesis which were considered to reflect direct irritation to the gastrointestinal tract. The NOAEL was considered to be 500 mg/kg/day.
Genotoxicity & Mutagenicity
Idebenone was not mutagenic in multiple bacterial assays at concentrations up to 5000 µg per plate with and without metabolic activation. Furthermore it was not clastogenic in two in vivo mouse micronucleus studies at doses up to 5000 mg/kg and two other studies conducted at doses up to 2000 mg/kg which resulted in plasma concentrations up to 175 ng/mL (>7 x human Cmax) after 2000 mg/kg. Idebenone was also negative in a rat chromosome aberration study at doses up to 2500 mg/kg and did not elicit unscheduled DNA synthesis in rats given up to 2500 mg/kg. However, idebenone was clearly clastogenic in human lymphocytes in vitro at high concentrations (≥7.5 µg/mL) and equivocal at high concentrations in a mouse lymphoma assay.
Three studies were conducted to qualify Impurity A. A blended lot containing 0.68% Impurity A was used in a bacterial mutagenicity study, an in vivo mouse micronucleus assay, and a 28-day repeated dose study in rats. The results were consistent with the previous studies and the genetic toxicity studies were negative. Therefore, Impurity A can be considered qualified at the proposed level of 0.5% consistent with International Conference on Harmonisation (ICH) guidance.
Carcinogenicity
In the two mouse and two rat carcinogenicity studies, there was no clear evidence of systemic toxicity or carcinogenicity. A treatment-related low incidence of squamous and basal cell tumours of the forestomach at 500 and 1000 mg/kg in rats was attributed to the direct irritation caused by idebenone. In the supplementary rat carcinogenicity study, the incidence of benign interstitial cell adenoma of the testis was within published reference ranges. There were no treatment-related non-neoplastic findings, such as increased hyperplasia, and no increase in interstitial cell testicular tumors in rats or in mice.
A potentially treatment-related neoplastic finding in the four carcinogenicity studies was a small increase in uterine smooth muscle tumors in mice. The incidences were slightly above the conducting laboratory's historical range. The original report states that the uterine tumors were not treatment-related based on an absence of statistical significance and lack of dose dependency for the separate benign and malignant incidences. However, assuming a continuity of tumor progression and combining the benign and malignant smooth muscle tumors, the incidence would be dose dependent and likely statistically significant. Furthermore given that the doses were closely spaced and exposure in females was less than dose proportional, dose dependency in tumor incidence would not necessarily be expected. The mean parent idebenone levels in plasma were approximately 3-, 5-, and 10-times higher than the expected human plasma concentrations at the low, mid, and high dose, respectively. Uterine tumor incidences did not increase in rats at doses up to 1000 mg/kg/day. While a relationship to idebenone is uncertain, the increased incidence of uterine tumors in mice should be recognized.
Reproductive and Developmental Toxicity
Idebenone was devoid of reproductive or developmental toxicity in the usual series of fertility (male and female rats), embryo-fetal development (female rats and rabbits) and peri- and post-natal (female rats) studies.
Immunogenicity
Idebenone was not immunogenic in the 4-week immunogenicity studies conducted in mice and guinea pigs.
3.2.4 Conclusion
The primary pharmacodynamic characterization has provided a plausible mode of action based on improving mitochondrial respiration and ATP formation. Secondary pharmacodynamic studies, safety pharmacology, long-term toxicity and carcinogenicity studies, mutagenicity, reproductive and developmental toxicity studies did not identify any specific safety concerns for the use of oral idebenone in FRDA.
3.3 Clinical basis for decision
3.3.1 Pharmacodynamics
Catena® (idebenone) is a synthetic short-chain analogue of Coenzyme Q10. Structurally idebenone is related to ubiquinone, a component of the respiratory chain. Idebenone is believed to act by facilitating an increase in the production of ATP. Additionally idebenone may act as an antioxidant by scavenging free radicals and decreasing lipid peroxidation. However, the exact mechanism of action of this product remains unknown.
3.3.2 Pharmacokinetics
Absorption
After oral administration, idebenone is rapidly absorbed. Maximum plasma concentrations of parent idebenone are reached within one hour. Proportional increases in plasma concentrations of parent idebenone are observed for doses from 150 mg to 1050 mg. Steady-state was reached after two days with twice a day treatment. Repeated dosing does not result in accumulation of the compound or of its metabolites.
Distribution
Idebenone is on average 96% bound to plasma protein. Non-clinical data show that debenone is distributed widely in all tissues with relatively high concentrations in the gut, liver and kidney. Idebenone enters the brain with a significant amount localized in mitochondria.
Metabolism
Biotransformation occurs by means of oxidative shortening of the side chain and by reduction of the quinone ring followed by conjugation to glucuronides and sulphates. Idebenone shows a high first-pass metabolism which results in conjugated idebenone and Phase I metabolites as well as their corresponding Phase II metabolites (glucuronides and sulphates). The main metabolites in plasma are conjugated idebenone.
The major metabolising enzyme of idebenone has not been determined, but the major elimination pathway is likely through conjugation. Inhibitors and inducers of CYP2C19, CYP1A2 and CYP3A4 may affect the metabolism of idebenone. The clinical relevance is unknown.
Excretion
Idebenone and its metabolites were primarily eliminated via urine. After a single oral dose of 750 mg idebenone, 58% of drug-derived material was measured in the urine.
Special Populations
No clinical studies have been conducted for the use of Catena® in pregnant women, nursing women, pediatric population (<8 years of age), geriatric population (>65 years of age), and patients with blood cell deficiencies.
In patients with impaired hepatic function (liver cirrhosis) plasma exposure of the inactive metabolites, conjugated idebenone and conjugated QS10 approximately doubled. Caution should be exercised when prescribing to patients with mild hepatic impairment. Catena® is contraindicated in moderate and/or severe hepatic impairment.
In patients with moderately impaired renal function, plasma exposure of inactive metabolites increased by approximately 50%. No information on the plasma levels of parent idebenone is available. Caution should be exercised when prescribing to patients with mild to moderate renal impairment.
3.3.3 Clinical Efficacy
The NICOSIA study was a 6-month, randomized, double-blind, parallel-group, placebo-controlled study conducted in 48 patients, with Friedreich's Ataxia (FRDA), aged from 9 to 18 years of age. The low number of patients in the study reflects the difficulty in recruiting patients with FRDA; a rare disease that is considered as an orphan disease worldwide. There were three idebenone treatment groups: low dose (n=12), mid dose (n=13), and high dose (n=12) of idebenone (up to 2250 mg/day), and the placebo group. Efficacy evaluations were done at baseline and after 6 months of treatment. The primary endpoint was the biochemical marker, 8OH2'dG (a measure of oxidative stress). Secondary endpoints were measures of neurological function such as International Cooperative Ataxia Rating Scale (ICARS) and FARS (Friedreich's Ataxia Rating Scale), both validated scales in FRDA, activities of daily living, as well as anatomical and functional cardiac parameters.
The primary efficacy endpoint in the idebenone groups was not statistically significantly better than placebo. The secondary efficacy endpoints on the ICARS were promising, showing an improvement in the mid and high dose idebenone groups as compared to placebo. Data on another secondary endpoint, Activities of Daily Living, also indicated an improvement for idebenone-treated patients compared to the placebo group.
3.3.4 Clinical Safety
The majority of adverse events (AEs) in the FRDA studies were reported as mild. The most common AEs were gastrointestinal disorders. In the NICOSIA study, there was a confirmed case of low white blood cell count, which normalized upon planned discontinuation of idebenone at Month 6. Regular haematological monitoring is recommended. The Product Monograph provides instructions to order a Complete Blood Count (CBC) prior to the start of the idebenone treatment, one month after initiation of therapy or idebenone dose increase, and every three months thereafter.
Patients in all treatment groups experienced elevated haemoglobin and hematocrit values with idebenone treatment arms indicating a higher frequency of reporting with slightly higher numbers in idebenone arms vs placebo. Higher than normal values for both haemoglobin and hematocrit were reported more frequently in the mid-dose group. However, these findings did not appear to be dose-dependent.
A few reported values for sodium, potassium, calcium, magnesium, aspartate aminotransferase, alanine transaminase, and creatine kinase were outside of the normal range (mostly above the upper limit of normal) without clear dose-dependent trends.
There were several cases of elevated alkaline phosphatase values, also without a clear dose-dependent trend. The incidence was quite high across all treatment arms (approx. 76% in the combined idebenone arms versus approx. 73% in the placebo arm). Although blood chemistry data in the NICOSIA study did not indicate any safety issues, increased levels in liver function tests have been reported in the post-marketing use of Catena®. The Product Monograph informs the reader of these findings and recommends blood-monitoring of liver function.
Long-Term Safety and Post-Marketing Data
Long-term safety data as well as post-marketing data for patients with FRDA are very limited. With the worldwide exposure of approximately 400,000 patient-years in other indications such as “treatment of cognitive disorders”, a total of 57 unlisted serious adverse drug reactions have been reported. Of these, 23 patients experienced blood cell abnormalities with 17 cases involving decreases in red blood cell, white blood cell or platelet counts. There were two fatal cases of aplastic anemia. Nine patients experienced serious liver function test abnormalities and four other patients had renal laboratory abnormalities or renal failure. Three patients had serious AEs of convulsion, hypercholesterolemia or hypertiglyceridemia, delirium, and mental confusion/somnolence.
3.3.5 Outstanding Issues
The proposed NOC/c commitments were finalized between Health Canada and the sponsor on June 9, 2008. The NOC/c was issued to the sponsor, Santhera Pharmaceuticals, on July 23, 2008. Consistent with the NOC/c policy, the sponsor has agreed to submit the results of the following confirmatory study and post-market safety monitoring:
- The results of ongoing Study IONIA, protocol SNT-III-002, a six month placebo-controlled study in patients with documented diagnosis of Friedreich's Ataxia. The study should confirm the promising efficacy results of the previous study (NICOSIA), conducted in a similar patient population. This confirmatory study is expected to evaluate the safety and efficacy of Catena® under the proposed conditions of use in the management of patients with Friedreich's Ataxia.
- Additional long-term data from ongoing open extension studies or studies completed after filing this NDS, which demonstrate the duration / extent of maintenance of treatment benefit and safety of long-term treatment, should be submitted as they become available.
- Periodic Safety Update Reports (PSURs) on a semi-annual basis until two full years of marketing experience has been gained. Then, PSURs will be submitted once a year for the following two years and thereafter at 3-yearly intervals.
- During treatment of FRDA with Catena®, reports of all serious Adverse Reactions (ARs) that occur in Canada and all serious expected and unexpected ARs that occur outside of Canada, should be forwarded within 15 days to Health Canada.
- Notification and reporting on specific issues of concern as outlined in Section 6.2.4 of the Guidance for Industry, Notice of Compliance with Conditions.
- Additional information to be provided in the draft Letter of Undertaking or other regulatory actions for Catena® from any other drug regulatory authority; and a commitment to provide a revised Product Monograph as new information is made available.
3.4 Benefit/Risk Assessment and Recommendation
3.4.1 Benefit/Risk Assessment
FRDA is a rare and devastating hereditary disease with poor prognosis. Although its most prominent features are progressive neurodegenerative and cardio degenerative disorders, this disease also affects skeletal muscles, gait, confines the patient to a wheelchair, and usually causes death before 50 years of age. There is currently no approved treatment for this disease in Canada.
Catena® (idebenone) is a synthetic short-chain analogue of Coenzyme Q10, which is identified as a cell plasma membrane antioxidant. Current literature indicates that idebenone may facilitate ATP production and may also act as an antioxidant to scavenge oxygen radicals in affected cells.
There were limited but promising (dose-dependent) efficacy results from a 6-month placebo-controlled trial (NICOSIA) with trends and improvements in validated neurological scales such as ICARS. Current literature reports some positive efficacy data on the use of idebenone in the treatment of neurological degenerative symptoms of FRDA. Also, the safety database for idebenone use over the last 20 years in a variety of patient populations and at different doses indicate an acceptable safety and tolerability profile for Catena® at this time.
Safety issues and the currently known adverse reactions can be managed through labelling. Continuing safety monitoring will be ongoing, as required within the framework of the NOC/c Policy.
The benefit over risk assessment is favourable for the agreed upon indication as quoted below, pending a confirmatory trial to substantiate the benefits of the drug.
3.4.2 Recommendation
Based on the Health Canada review of data on quality, safety and effectiveness, Health Canada considers that the benefit/risk profile of Catena® is favourable for use in patients with Friedreich's Ataxia, where it may be useful for the symptomatic management of this disease.This New Drug Submission (NDS) qualifies for authorization under the Notice of Compliance with Conditions Policy. The New Drug Submission complies with the requirements of sections C.08.002 and C.08.005.1 and therefore Health Canada has granted the Notice of Compliance pursuant to section C.08.004 of the Food and Drug Regulations.
In keeping with the provisions outlined in the NOC/c Policy the sponsor had agreed to provide more data pertaining to confirmatory studies and post market safety monitoring to ensure Catena® safety and efficacy. See section 3.3.5 Outstanding Issues.
4 Submission Milestones
Submission Milestones: Catena®
Submission Milestone | Date |
---|---|
Pre-submission meeting | 2007-08-21 |
Acceptance of Advance Consideration under the Notice of Compliance with Conditions (NOC/c) Policy | 2007-08-21 |
Submission filed | 2007-10-26 |
Screening | |
Screening Acceptance Letter issued | 2007-11-22 |
Review | |
Quality Evaluation complete | 2007-11-23 |
Biopharmaceutics evaluation complete | 2008-05-20 |
Labelling review complete | 2008-06-06 |
Clinical Evaluation complete | 2008-07-18 |
Notice of Compliance with Conditions - Qualifying Notice (NOC/c-QN) issued | 2008-06-09 |
Response filed | 2008-06-26 |
Notice of Compliance (NOC) issued by Director General under the NOC/c Policy | 2008-07-23 |