Summary Basis of Decision for Cymbalta ™
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:
CymbaltaTM
Duloxetine hydrochloride, 30 mg and 60 mg, Delayed-release capsule, Oral
Eli Lilly Canada Inc.
Submission control no: 110028
Date issued: 2008-05-05
Health Products and Food Branch
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Health Products and Food Branch
Également disponible en français sous le titre : Sommaire des motifs de décision (SMD), PrCYMBALTA, Chlorhydrate de duloxétine, 30 mg et 60 mg, Eli Lilly Canada Inc., No de contrôle de la présentation 110028
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):
- 02301482 - 30 mg
- 02301490 - 60 mg
Therapeutic Classification:
Non-medicinal ingredients:
The 60 mg capsules also contain iron oxide yellow.
Submission type and control no:
Date of Submission:
Date of authorization:
2 Notice of decision
On November 1, 2007, Health Canada issued a Notice of Compliance to Eli Lilly Canada Inc. for the drug product, Cymbalta (duloxetine hydrochloride).
Cymbalta contains the medicinal ingredient duloxetine hydrochloride. It is indicated for the symptomatic relief of major depressive disorder (MDD), and for the management of neuropathic pain associated with diabetic peripheral neuropathy (DPN). The effectiveness of Cymbalta in the treatment of MDD is presumed to be linked to its inhibition of neuronal uptake of serotonin and norepinephrine in the central nervous system (CNS), and a resultant increase in serotonin and norepinephrine neurotransmission. The pain inhibitory action of duloxetine hydrochloride is proposed to be due to potentiation of descending inhibitory pain pathways within the CNS.
The market authorization was based on quality, non-clinical, and clinical information submitted. In four of the six clinical MDD studies, Cymbalta demonstrated statistical superiority over placebo as measured by improvement in the 17-Item Hamilton Depression Rating Scale total score; and in all three clinical DPN studies, Cymbalta was statistically significantly superior to placebo in the measurement of 24-hour average pain severity. The efficacy of Cymbalta in hospitalized patients with MDD has not been studied. The effectiveness of Cymbalta in long-term use in patients with MDD (i.e. more than 9 weeks) has not been systematically evaluated in controlled clinical studies. The physician who elects to use Cymbalta for extended periods in the treatment of depression should periodically re-evaluate the long-term usefulness of the drug for the individual patient.
Cymbalta (30 mg and 60 mg duloxetine hydrochloride) is presented in a delayed-release capsule. The recommended dose is 60 mg once daily with or without food. A lower starting dose of 30 mg may be considered for tolerability reasons in some patients, with a target dose of 60 mg/day within 1-2 weeks. Doses above 60 mg/day have not been shown to confer additional benefits. Dosing guidelines are available in the Product Monograph.
Cymbalta is contraindicated in patients with a known hypersensitivity to the drug or the other components of the product, in patients with any liver disease resulting in hepatic impairment, and in patients with severe renal impairment or end-stage renal disease. Concomitant use of Cymbalta and thioridazine is contraindicated. Cymbalta should not be used concomitantly with a monoamine oxidase inhibitor (MAOI), including linezolid, or within at least 14 days of discontinuing treatment with an MAOI. Cymbalta should not be used concomitantly with potent CYP1A2 inhibitors and some quinolone antibiotics. In clinical trials, Cymbalta was associated with an increased risk of mydriasis; therefore, its use should be avoided in patients with uncontrolled narrow-angle glaucoma.
Use of Cymbalta in patients who consume substantial amounts of alcohol may be associated with severe liver injury; therefore, Cymbalta should only be used in exceptional circumstances and with extreme caution in these patients.
The safety and efficacy of Cymbalta in paediatric patients (<18 years of age) have not been established and its use in this patient population is not indicated.
Cymbalta 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 for the use of Cymbalta 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 Cymbalta is favourable for the symptomatic relief of major depressive disorder and for the management of neuropathic pain associated with diabetic peripheral neuropathy.
3 Scientific and Regulatory Basis for Decision
A New Drug Submission (NDS) for Cymbalta (duloxetine hydrochloride) with an indication for major depressive disorder (MDD) was filed with Health Canada in January 2002 (Control No. 075750). The Quality review was completed in June 2003 and the Clinical review was completed in January 2004, at which time a Notice of Non-compliance (NON) was issued. The main concern expressed by Health Canada in the NON letter was the hepatic safety of duloxetine hydrochloride. The sponsor submitted a complete response in July 2004, addressing all concerns raised in the NON. Following review of the NON response, labelling negotiations were initiated; however, Health Canada continued to express safety concerns which resulted in the cancellation of the submission by the sponsor in March, 2005. Following extensive consultation with Health Canada, the sponsor submitted, in November 2006, the current NDS (Control No. 110028) addressing the outstanding safety concerns related to MDD and included data supporting an additional indication for the management of pain associated with diabetic peripheral neuropathy (DPN). A Notice of Compliance (NOC) was issued on November 1, 2007.
3.1 Quality Basis for Decision
3.1.1 Drug Substance (Medicinal Ingredient)
General Information
Duloxetine hydrochloride, the medicinal ingredient of Cymbalta is an antidepressant/analgesic. The effectiveness of duloxetine hydrochloride in the treatment of MDD is thought to be linked to its inhibition of neuronal uptake of serotonin and norepinephrine in the central nervous system (CNS), and a resultant increase in serotonin and norepinephrine neurotransmission. The pain inhibitory action of duloxetine hydrochloride is believed to be a result of potentiation of descending inhibitory pain pathways within the CNS.
Manufacturing Process and Process Controls
Duloxetine hydrochloride is manufactured via a multi-step synthesis. Each step of the manufacturing process is considered to be controlled within acceptable limits:
- The sponsor has provided information on the quality and controls for all materials used in the manufacture of the drug substance.
- The drug substance specifications are found to be satisfactory. Impurity limits meet ICH requirements.
- The processing steps have been evaluated and the appropriate ranges for process parameters have been established.
Characterization
The structure of duloxetine hydrochloride is considered to be adequately elucidated.
Impurities and degradation products arising from manufacturing and/or storage were reported and characterized. These products were found to be within ICH established limits and/or were qualified from batch analysis and therefore, are considered to be acceptable.
Control of Drug Substance
Copies of the analytical methods and, where appropriate, validation reports are considered satisfactory for all analytical procedures used for release and stability testing of duloxetine hydrochloride.
The drug substance packaging is considered acceptable.
Stability
Based on the long-term and accelerated stability data submitted, the proposed retest period for the drug substance is supported and considered to be satisfactory.
3.1.2 Drug Product
escription and Composition
Cymbalta (duloxetine hydrochloride) delayed-release capsules are available in 30 mg and 60 mg strengths.
- The 30 mg capsule has an opaque white body and opaque blue cap, and is imprinted with '30 mg' on the body and '9543' on the cap.
- The 60 mg capsule has an opaque green body and opaque blue cap, and is imprinted with '60 mg' on the body and '9542' on the cap.
Each capsule contains enteric-coated pellets of duloxetine hydrochloride equivalent to 30 mg or 60 mg of duloxetine that are designed to prevent degradation of the drug in the acidic environment of the stomach.
Non-medicinal ingredients include FD&C Blue No.2, gelatin, hydroxypropyl methylcellulose, hydroxypropyl methylcellulose acetate succinate, sodium lauryl sulfate, sucrose, sugar spheres, talc, titanium dioxide, and triethyl citrate. The 60 mg capsules also contain yellow iron oxide.
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 duloxetine hydrochloride with the excipients is demonstrated by the stability data presented on the proposed commercial formulation.
Pharmaceutical Development
Changes to the manufacturing process and formulation made throughout the pharmaceutical development are considered acceptable upon review.
Manufacturing Process and Process Controls
The method of manufacturing is considered acceptable and the process is considered adequately controlled within justified limits.
Control of Drug Product
Cymbalta is tested to verify that the identity, appearance, content uniformity, dissolution, and levels of degradation products and impurities are within acceptance criteria. The test specifications and analytical methods are considered acceptable; the shelf-life and release limits, for individual and total degradation products, are within acceptable limits.
Copies of the analytical methods and, where appropriate, validation reports are considered satisfactory for all analytical procedures used for release and stability testing of Cymbalta.
Data from final batch analyses were reviewed and are considered to be acceptable according to the specifications of the drug product.
Although impurities and degradation products arising from manufacturing and/or storage were reported and characterized, these were found to be within ICH established limits and/or were qualified from batch analysis and therefore, are considered to be acceptable.
Stability
Based on the real-time, long-term, and accelerated stability data submitted, the proposed 24-month shelf-life at 15-30°C for Cymbalta 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.
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
The gelatin in the capsule shell is of animal origin. A letter of attestation confirming that the material is not from a BSE/TSE-affected country/area has been provided for this product indicating that it is considered to be safe for human use.
Granular Activated Carbon used as a decolourizing reagent is derived from charcoal of bovine bones. TSE Certificates of Suitability were provided for both the gelatin and carbon.
3.1.5 Conclusion
The Chemistry and Manufacturing information submitted for Cymbalta 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
An in vitro study showed that duloxetine hydrochloride has a molecular binding profile of a dual serotonin and norepinephrine re-uptake inhibitor. The selective binding resulted in inhibition of the re-uptake pumps for both serotonin and norepinephrine.
Animal neurochemical and behavioural studies with duloxetine showed an enhancement of both serotonin and norepinephrine neurotransmission in the CNS. Duloxetine hydrochloride also normalized pain thresholds in several non-clinical models of neuropathic and inflammatory pain, and reduced pain behaviour in a model of persistent pain. In the animal studies, increased extracellular levels of dopamine were observed in the prefrontal cortex, along with increased levels of serotonin and norepinephrine.
3.2.2 Pharmacokinetics
Absorption
After oral administration, duloxetine hydrochloride was well absorbed in mice, rats, and dogs.
Distribution
Duloxetine hydrochloride was not widely distributed into the tissues of rats. The highest concentrations were found in the liver, kidney, lung, and gastrointestinal tract. Low concentrations were found in the brain. Duloxetine hydrochloride crossed the placenta and was excreted into the milk of lactating rats. Duloxetine hydrochloride was highly bound to plasma proteins.
Metabolism
In mice, rats, and dogs, duloxetine hydrochloride was extensively metabolized into numerous metabolites, >90% of the oral dose was transformed. Duloxetine hydrochloride was primarily metabolized in the liver and the major metabolic pathways involved several oxidations, especially in the naphthyl ring followed by conjugation.
Excretion
After oral administration, the elimination half-life of duloxetine hydrochloride was 1.5 hours and 4 hours, in rats and dogs, respectively.
After administration of radiolabelled duloxetine hydrochloride, the major route of elimination in mice, rats, and dogs was via the feces (46-77%) with 14-43% of the radioactivity appearing in the urine.
3.2.3 Toxicology
Duloxetine hydrochloride was evaluated in a variety of toxicology studies in laboratory animals and in vitro test systems. Studies included: single-dose toxicity in mice, rats, and dogs; repeat-dose toxicity in mice, rats, and dogs; in vitro and in vivo genotoxicity; reproductive and developmental toxicity in rats and rabbits; and carcinogenic potential in rats and mice.
Single-Dose Toxicity
In general, the single-dose toxicological findings were related to central nervous system effects. These were predictable based on the known pharmacology of a serotonin and norepinephrine re-uptake inhibitor (SNRI).
Repeat-Dose Toxicity
In the repeat-dose toxicology studies, the target organ in all species tested was the liver. Effects included hepatocellular microsomal enzyme induction with corresponding increased liver weights and centrilobular hepatic hypertrophy and vacuolation, as well as centrilobular fatty changes and phospholipidosis. Effects in female mice only included hepatocellular adenomas and carcinomas (considered secondary to enzyme the non-clinical species, effects were primarily metabolic with related morphologic changes and phospholipidosis. There was no overt hepatic injury or cholestasis observed. Furthermore, treatment-related transaminase elevations indicative of hepatocellular toxicity did not occur in the non-clinical studies.
Reproductive and Developmental Toxicity
Duloxetine hydrochloride had no effect on male rat fertility. Effects on female rat fertility and developmental delay occurred only at maternally toxic doses. Results of studies in developing rats and rabbits indicated that duloxetine hydrochloride would not be expected to represent a developmental hazard.
Mutagenicity
Duloxetine hydrochloride was not mutagenic when tested at appropriate doses in a battery of genotoxicity tests that included all relevant positive controls.
Carcinogencity
Duloxetine hydrochloride demonstrated no carcinogenic potential in a two-year rat study. In female mice that received five times the maximum recommended human dose, there was an increased incidence of hepatocellular adenomas and carcinomas, but these were considered to be secondary to hepatic enzyme induction with associated centrilobular hypertrophy and vacuolation. The relevance of this mouse data in humans is unknown.
3.2.4 Conclusion
Duloxetine hydrochloride has been shown to be a serotonin and norepinephrine re-uptake inhibitor. The appropriate non-clinical studies were performed and the toxicity database is considered adequate. The toxicity findings were consistent with the pharmacological effects of duloxetine hydrochloride. Duloxetine hydrochloride was associated with hepatic effects in the non-clinical studies, however there was no apparent hepatic injury or cholestasis observed. The non-clinical pharmacology and toxicology studies support the use of Cymbalta for the proposed indication.
3.3 Clinical basis for decision
3.3.1 Pharmacodynamics
Duloxetine hydrochloride was shown to be a selective serotonin and norepinephrine re-uptake inhibitor in various models. It increased extracellular concentrations of both norepinephrine and serotonin within the CNS, thereby contributing to the descending pain inhibitory pathway and alleviating persistent pain. In healthy subjects, duloxetine hydrochloride significantly interfered with the serotonin re-uptake process as demonstrated by marked decreases in blood serotonin concentration, but showed no clear effect on the norepinephrine re-uptake, as measured by the tyramine stressor test. In additional clinical studies, duloxetine hydrochloride decreased 5-hydroxytryptamine concentrations in the blood and decreased the urinary excretion of norepinephrine and its metabolites, consistent with the blockage of serotonin and norepinephrine uptake processes, respectively. Duloxetine hydrochloride did not appear to have significant affinity for a variety of other receptors such as dopaminergic, cholinergic, adrenergic, or histaminergic type.
3.3.2 Pharmacokinetics
Absorption
In humans, duloxetine hydrochloride is well absorbed, with its maximal plasma concentrations (Cmax) occurring 6 hours post-dose. Although food does not affect the Cmax of duloxetine, it delays the time to reach peak concentration from 6 to 10 hours. Duloxetine plasma exposure increases in proportion to dose for doses up to 60 mg twice a day. Steady-state plasma concentrations are typically achieved after 3 days of dosing. There is no clinically important difference in the pharmacokinetic parameters of morning and evening doses.
Distribution
Duloxetine hydrochloride was highly bound (>90%) to plasma proteins. The mean volume of distribution was 1640 L. Plasma protein binding of duloxetine is not affected by renal or hepatic impairment.
Metabolism
Duloxetine hydrochloride is extensively metabolized in the liver by two cytochrome P450 enzymes, primarily by CYP1A2 and to a lesser extent CYP2D6. The two major circulating metabolites are not pharmacologically active.
Excretion
The elimination half-life of duloxetine hydrochloride was 8-17 hours (mean: 12 hours). Apparent plasma clearance of duloxetine does not differ between once daily and twice daily dosing. The majority of metabolites were excreted in the urine (72%) and feces (~19%).
Special Populations
Gender and Age
Mean duloxetine exposure were higher in female patients compared to males.
Compared to younger adults, elderly patients had increased levels of drug exposure and the half-life of the drug was longer in elderly females (vs middle-aged females). These differences in drug exposure did not appear to be clinically significant. Therefore, dosage adjustment based on gender or age is not necessary. Greater sensitivity may occur in older individuals as the elderly routinely take other concomitant medications and the likelihood of drug interactions would be greater. Safety and efficacy of duloxetine in pediatric patients have not been established.
Hepatic Impairment
Cymbalta is contraindicated in patients with any liver disease resulting in hepatic impairment. A pharmacokinetic study showed that single non-therapeutic dose of 20 mg duloxetine in six cirrhotic patients with moderate liver impairment (Child-Pugh Class B) had a mean plasma duloxetine clearance approximately 15% that of age- and gender-matched healthy subjects, with a 5-fold increase in mean exposure, and a half-life approximately 3-times longer.
Renal Impairment
Compared to subjects with normal renal function, duloxetine Cmax and drug exposure (AUC) values were approximately 2-fold higher in patients with end stage renal disease receiving chronic intermittent hemodialysis. Thus, Cymbalta is not recommended for patients with severe renal impairment.
Patients with Substantial Alcohol Use
Use of duloxetine in patients who consume substantial amounts of alcohol may be associated with severe liver injury. Cymbalta should only be used in exceptional circumstances and with extreme caution in these patients.
Drug Interactions
Duloxetine hydrochloride is predominantly metabolized by CYP1A2 and to a lesser extent by CYP2D6. Duloxetine should not be used concomitantly with potent inhibitors of CYP1A2 enzyme.
Duloxetine is a moderate inhibitor of the enzyme CYP2D6 and caution should be used when it is co-administered with drugs that are metabolized by CYP2D6.
Potential drug interactions are included in the Cymbalta Product Monograph.
3.3.3 Clinical Efficacy
Clinical studies were submitted for the evaluation of efficacy in major depressive disorder (MDD) and for pain associated with diabetic peripheral neuropathy (DPN).
MDD Studies
The efficacy of Cymbalta in MDD was studied in six randomized, double-blind, placebo-controlled, fixed-dose studies in adult outpatients (range:18 to 83 years, mean: 41 years) meeting the Diagnostic and Statistical Manual of Mental Disorders (DSM-IV) criteria for MDD, with a 17-Item Hamilton Depression Rating Scale (HAMD-17) ≥15 and a Clinical Global Impression Severity Score ≥4 at study entry. The studies were 8 or 9 weeks in duration; two of the studies had a 26-week continuation phase. Doses tested were 20 mg, 40 mg and 60 mg, all twice daily (BID) and 60 mg once daily (QD). The primary efficacy endpoint was the HAMD-17 total score. The secondary efficacy endpoints included: HAMD-17 Depressed Mood Item, the HAMD-17 Core and Anxiety subscales; Global Impression Scales (Patient Global Impressions (PGI) Improvement and CGI-Severity); and the Quality of Life in Depression scale.
In four of the six studies, Cymbalta demonstrated statistical superiority over placebo as measured by improvement in the HAMD-17 total score. The secondary efficacy endpoints were supportive of the primary efficacy endpoints. In comparison with placebo, Cymbalta at doses of 60 mg QD, and both 40 mg and 60 mg BID, produced a significantly higher rate of response and remission as defined respectively by ≥50% decrease in the HAMD-17 total score and a total endpoint HAMD-17 score of ≤7. There was no evidence that doses greater than 60 mg QD of Cymbalta conferred any additional benefit.
DPN Studies
The efficacy of Cymbalta in the treatment of neuropathic pain associated with Diabetic Peripheral Neuropathy (DPN) was studied in three placebo-controlled, fixed-dose trials of 12 weeks in duration in adult outpatients (age range: 20-84 years, mean: 61 years), having neuropathic pain associated with DPN for at least 6 months. Patients had to have a baseline pain score of ≥4 on the 11-point Likert scale at study entry. Patients meeting diagnostic criteria for major depression were excluded. Patients treated with Cymbalta were also permitted to have most other therapies, including non-medicinal treatments but antidepressants, anticonvulsants, and antipsychotics were excluded. The primary efficacy endpoint was the weekly mean of the 24-hour average pain intensity/severity scores based on the 11-point Likert scale. Secondary endpoints included response/responder rates (% of patients who achieved ≥30% reduction in mean pain score at the end of the study vs baseline), 24-hour worst pain scores, night pain scores, and Patient's Global Impression of Improvement scores.
In all three studies, Cymbalta 60 mg QD and 60 mg BID were statistically significantly superior in the primary efficacy endpoint when compared to placebo. The effects were apparent after one week of treatment and lasted throughout the 12-week period of each study. In all three studies, Cymbalta 60 mg QD and 60 mg BID demonstrated statistically significantly better responder rates compared to placebo (63-70% vs. 42-47%). Most secondary efficacy endpoints were also positive. The Cymbalta dose of 20 mg QD is non-therapeutic.
3.3.4 Clinical Safety
The clinical safety database included data from the short-term controlled studies referred to in Section 3.3.3 Clinical Efficacy, as well as data from longer-term or extension studies (two MDD 6-month extension studies, a one-year open-label MDD study, and five DPN extension studies ranging from 24-52 weeks in duration) and the most recent Periodic Safety Update Report (PSUR), dated August 2007, which included all clinical trial and post-market safety data to date.
MDD Studies
Approximately 10% of the 1139 MDD patients who received Cymbalta in the short-term placebo-controlled studies discontinued treatment due to an adverse event (AE), compared with 4% of the 777 patients receiving placebo. Nausea (Cymbalta 1.4%, placebo 0.1%) was the only common AE reported as reason for discontinuation and was considered to be drug-related (i.e., discontinuation in at least 1% of the Cymbalta-treated patients and at a rate of at least twice that of placebo). The most commonly observed AEs (an incidence 5% or greater and at least twice the incidence in placebo patients) in Cymbalta-treated MDD patients were: nausea, dry mouth, constipation, decreased appetite, fatigue, somnolence, and increased sweating.
Of a total of 2418 patients in the MDD clinical studies, 993 Cymbalta-treated patients were exposed for at least 180 days and 445 Cymbalta-treated patients were exposed for at least one year. The safety profile of Cymbalta in the longer-term open-label studies appeared similar to that seen in the controlled studies.
DPN Studies
Approximately 12% of the 800 DPN patients who received Cymbalta in the DPN placebo-controlled studies discontinued treatment due to an adverse event, compared with 5% of the 339 patients that received placebo. Nausea (Cymbalta 3.0%, placebo 0.3%), dizziness (Cymbalta 1.1%, placebo 0.3%), and somnolence (Cymbalta 1.2%, placebo 0%) were the common AEs reported as reasons for discontinuation and mostly considered to be drug-related. The most commonly observed AEs in Cymbalta-treated DPN patients were: nausea, constipation, dry mouth, vomiting, fatigue, decreased appetite, somnolence, erectile dysfunction, and sweating. The 60 mg BID dose was not as well-tolerated and was associated with a higher frequency of non-serious AEs.
The safety profile of Cymbalta in the longer-term open-label studies appeared to be similar to that seen in the controlled studies, with one exception: in the one-year study, three patients treated with 60 mg BID experienced hyperglycemia vs. none in the group that received routine care. Of a total of 1429 patients in the DPN clinical studies, 881 had ≥ 6 months of exposure to Cymbalta, and 515 had >12 months of exposure.
MDD and DPN Studies
Discontinuation symptoms have been systematically evaluated in all Cymbalta studies. Following abrupt or tapered discontinuation in MDD and DPN placebo-controlled clinical trials, the following symptoms occurred at a rate ≥ 1% and at a significantly higher rate in Cymbalta-treated patients compared with those discontinuing from placebo: dizziness, nausea, headache, paresthesia, vomiting, irritability, nightmare, fatigue, insomnia, diarrhea, anxiety, sweating, and vertigo. These are consistent with AEs following discontinuation of other serotonin-norepinephrine re-uptake inhibitors (SNRIs) and selective serotonin reuptake inhibitors (SSRIs).
Safety Topics of Interest
Hepatic Toxicity
Cymbalta increases the risk of elevation of serum aminotransferase levels, which led to trial discontinuation in 0.3% of duloxetine-treated patients. The median time to detection of such elevations in patients was approximately 2 months. In these patients, these were usually transient and self-limiting with continued use, or resolved upon discontinuation of Cymbalta. In the full cohort of placebo-controlled studies in any indication, elevation of alanine aminotransferase (ALT) >3 times the upper limit of normal occurred in 1.1% (75/6871) of Cymbalta-treated patients compared to 0.3% (13/5036) of placebo-treated patients. In placebo-controlled studies using a fixed-dose design, there was evidence of a dose-response relationship for ALT and aspartate aminotransferase (AST) elevation of >3 times the upper limit of normal and >5 times the upper limit of normal, respectively.
Post-marketing reports indicate that severe elevations of liver enzymes (>10 times the upper limit of normal) or liver injury with a cholestatic or mixed pattern have been rarely reported, in some cases, associated with excessive alcohol use or pre-existing liver disease. Because it is possible that duloxetine and alcohol may interact to cause liver injury or that duloxetine may aggrevate pre-existing liver disease, Cymbalta should ordinarily not be prescribed to patients with substantial alcohol use and should not be used in patients with any liver disease resulting in hepatic impairment. Furthermore, this drug should be used with caution in patients treated with other drugs associated with hepatic injury. Warnings regarding the possible liver-related effects of Cymbalta have been included in the Cymbalta Product Monograph.
Glucose Regulation
Data from DPN trials indicate that duloxetine treatment worsens glycemic control in some diabetic patients. In the 12-week acute treatment phase of these studies, Cymbalta was associated with a small increase in mean fasting blood glucose as compared to placebo. In the extension phase of these studies (up to 52 weeks), mean fasting blood glucose increased by 0.67 mmol/L (12 mg/dL) in the Cymbalta group and decreased by 0.64 mmol/L (11.5 mg/dL) in the routine care group. This difference was statistically significant. HbA1c increased by 0.5% in the Cymbalta group and by 0.2% in the routine care groups.
Bleeding
Of a total of 619 bleeding cases in the clinical studies (all indications), 33 cases were considered serious. Of these, 7 were coded as gastrointestinal bleeding. In the MDD clinical studies, duloxetine-treated patients had a significantly higher incidence of adverse events "possibly" indicative of bleeding vs. patients that received placebo (most common AE: contusion). Patients in DPN trials reported the highest percentage of cases "possibly" indicative of bleeding (5%) but the majority of the cases appeared to be due to injection site bruising or contusion and similar to placebo rates.
The post-marketing database (up to August 2007) contains a total of 246 adverse reactions possibly related to bleeding with at least 39 considered serious. The cumulative number of cases categorized under the cluster of Gastrointestinal Bleeding was 114 with 17 cases listed in the most recent PSUR (dated August 2007). Where the indication was stated, over 50% of the patients were taking Cymbalta for MDD and about 3% for pain associated with DPN.
While a causal relationship to Cymbalta is unclear, impaired platelet aggregation may result from platelet serotonin depletion and contribute to bleeding occurrences. Thus, caution is advised in patients taking anticoagulants and/or medicinal products known to affect platelet function (e.g. non-steroidal anti-inflammatorr drugs and ASA), and in patients with known tendency for bleeding or those with predisposing conditions. The Product Monograph for Cymbalta contains warnings with regards to abnormal bleeding including references to gastrointestinal bleeding and hematochezia.
3.4 Benefit/Risk Assessment and Recommendation
3.4.1 Benefit/risk assessment
In clinical studies, a total of 2418 patients received duloxetine for the treatment of MDD and 1429 patients received duloxetine for the treatment of DPN. In these studies, Cymbalta demonstrated efficacy for the symptomatic relief of MDD, and in the management of neuropathic pain associated with DPN. Duloxetine was on the worldwide market since August 3, 2004 and the worldwide estimated exposure was 9,894,000 patients as of the cut-off date July 31, 2007. Duloxetine was well-tolerated in patients
treated for MDD and DPN, during both short-term and long-term treatment. For the most part, the adverse reaction profile of duloxetine in MDD was similar to that seen in DPN. However, data from the DPN studies indicate that duloxetine treatment worsens glycemic control in some diabetic patients.
Liver toxicity is an area of safety concern related to Cymbalta treatment. Severe elevations of liver enzymes (>10 times the upper limit of normal) or liver injury with a cholestatic or mixed pattern have been rarely reported, in some cases, associated with pre-existing liver disease, excessive alcohol use, and concomitant use of drugs associated with hepatic injury. Cymbalta may aggravate pre-existing liver disease, may interact with alcohol, leading to liver injury.
In order to manage the risk of hepatic toxicity, the following restrictions have been incorporated into the Product Monograph:
- Cymbalta is contraindicated in patients with any liver disease resulting in hepatic impairment.
- Cymbalta should not be used concomitantly with CYP1A2 inhibitors.
- Cymbalta should be used with caution in patients treated with other drugs associated with hepatic injury.
- Cymbalta should not be prescribed to patients with substantial alcohol use, except under exceptional circumstances. Isolated cases of liver failure, including fatal cases, have been reported.
Warnings on hepatic toxicity and related AEs also appear in the Dear Health Professional Letter (DHPL) issued by the sponsor on January 28, 2008.
More than three years of post-marketing experience indicate that the frequency reporting of hepatic AEs and others AEs (hyperglycemia, bleeding, cardiovascular, etc) have remained relatively constant in terms of increased patient exposure. With proper labelling of the safety issues, the risk-benefit ratio for the use of Cymbalta in the management of MDD and of pain associated with DPN is favourable at this time.
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 Cymbalta is favourable in the treatment of the symptomatic relief of major depressive disorder and for the management of neuropathic pain associated with diabetic peripheral neuropathy. 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.
4 Submission Milestones
Submission Milestones: CymbaltaTM
| Submission Milestone | Date |
|---|---|
| Control Number 075750 - Submission filed | 2002-01-15 |
| Screening 1 | |
| Screening Deficiency Notice issued | 2002-02-22 |
| Response filed | 2002-03-11 |
| Screening Acceptance Letter issued | 2002-03-13 |
| Review | |
| Biopharmaceutics Evaluation complete | 2003-09-11 |
| Quality Evaluation complete | 2003-06-27 |
| Clinical Evaluation complete | 2004-01-06 |
| NON issued by Director General (safety issues) | 2004-01-20 |
| Response to NON filed | 2004-07-13 |
| Screening 2 | |
| Screening Acceptance Letter issued | 2004-08-25 |
| Cancellation Letter (from Sponsor) received | 2005-03-03 |
| Re-filing Consultation Meeting | 2006-08-29 |
| Control Number 110028 - Submission filed | 2006-11-23 |
| Screening 1 | |
| Screening Acceptance Letter issued | 2007-01-05 |
| Review | |
| Quality Evaluation complete | 2007-10-30 |
| Clinical Evaluation complete | 2007-10-30 |
| Labelling Review complete | 2007-10-31 |
| NOC issued by Director General | 2007-11-01 |
Related Drug Products
| Product name | DIN | Company name | Active ingredient(s) & strength |
|---|---|---|---|
| CYMBALTA | 02301482 | ELI LILLY CANADA INC | DULOXETINE (DULOXETINE HYDROCHLORIDE) 30 MG |
| CYMBALTA | 02301490 | ELI LILLY CANADA INC | DULOXETINE (DULOXETINE HYDROCHLORIDE) 60 MG |