Summary Basis of Decision for Inspra ™/MC

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
InspraTM/MC

Eplerenone, 25 mg and 50 mg, Tablet, Oral

Pfizer Canada Inc.

Submission control no: 120440

Date issued: 2009-07-30

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:

InspraTM/MC

Manufacturer/sponsor:

Pfizer Canada Inc.

Medicinal ingredient:

Eplerenone

International non-proprietary Name:

Eplerenone

Strength:

25 mg and 50 mg

Dosage form:

Tablet

Route of administration:

Oral

Drug identification number(DIN):

  • 02323052 - 25 mg
  • 02323060 - 50 mg

Therapeutic Classification:

Aldosterone Antagonist

Non-medicinal ingredients:

Lactose, microcrystalline cellulose, croscarmellose sodium, hypromellose, sodium lauryl sulfate, talc, magnesium stearate, titanium dioxide, polyethylene glycol, polysorbate 80, iron oxide yellow, and iron oxide red.

Submission type and control no:

New Drug Submission,
Control Number:120440

Date of Submission:

2008-03-03

Date of authorization:

2009-02-26

TM/MC Pfizer Caribe Limited
Pfizer Canada Inc., Licensee/licencié

2 Notice of decision

On February 26, 2009, Health Canada issued a Notice of Compliance to Pfizer Canada Inc. for the drug product, Inspra.

Inspra contains the medicinal ingredient eplerenone which is an aldosterone antagonist.

Inspra is indicated as an adjunct to standard therapy to reduce the risk of mortality following myocardial infarction in clinically stable patients who have evidence of heart failure and left ventricular systolic dysfunction (ejection fraction ≤40%).

Inspra acts as a competitive and selective blocker of aldosterone mainly at mineralocorticoid receptor sites in various tissues throughout the body. It is believed that Inspra inhibits aldosterone-induced cardiac hypertrophy and fibrosis which can occur following a myocardial infarction.

The market authorization was based on quality, non-clinical, and clinical information submitted. The efficacy and safety of Inspra were mainly evaluated in a multinational, multicentre, double-blind study in 6,632 patients with clinical signs of heart failure and left ventricular dysfunction. Patients, if clinically stable, were randomized to Inspra or placebo 3 to14 days after an acute myocardial infarction. Inspra significantly reduced all-cause mortality compared to placebo. The effect on mortality was mainly due to a decrease in cardiovascular mortality.

Inspra (25 mg and 50 mg eplerenone) is presented as tablets. Treatment should be initiated in clinically stable patients at 25 mg once daily and titrated to the target dose of 50 mg once daily preferably within 4 weeks as tolerated by the patient. Serum potassium should be measured before initiating Inspra therapy and should be monitored within the first week after the first dose or after increasing the dose, and be measured periodically thereafter. Inspra should not be administered to patients that have an initial serum potassium of >5.0 mmol/L, serum creatinine >221 μmol/L and/or creatinine clearance <50 mL/min. Dosing guidelines are available in the Product Monograph.

Inspra is contraindicated in all patients with the following conditions:

  • hypersensitivity to Inspra or any component of this medication;
  • clinically significant hyperkalemia;
  • severe hepatic impairment (Child-Pugh Class C);
  • serum potassium >5.0 mmol/L at initiation;
  • moderate to severe renal impairment (creatinine clearance <50 mL/min);
  • serum creatinine >221 μmol/L;
  • concomitant use with potassium-sparing diuretics, potassium supplements or strong Cytochrome P450 (CYP) 3A4 inhibitors such as ketoconazole, itraconazole, nefazodone, telithromycin, clarithromycin, ritonavir, and nelfinavir.

Inspra 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 Inspra are described in the Product Monograph.

Based on the Health Canada review of data on quality, safety, and efficacy, Health Canada considers that the benefit/risk profile of Inspra is favourable as an adjunct to standard therapy, to reduce the risk of mortality following myocardial infarction, in clinically stable patients who have evidence of heart failure and left ventricular systolic dysfunction (ejection fraction ≤40%).

3 Scientific and Regulatory Basis for Decision

3.1 Quality Basis for Decision

3.1.1 Drug Substance (Medicinal Ingredient)

General Information

Eplerenone, the medicinal ingredient of Inspra, is an aldosterone antagonist. Eplerenone blocks the binding of aldosterone at mineralocorticoid receptor sites in various tissues throughout the body. It is believed that Inspra inhibits aldosterone-induced cardiac hypertrophy and fibrosis which can occur following a myocardial infarction (MI).

Manufacturing Process and Process Controls

Eplerenone 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.
  • The processing steps have been evaluated and the appropriate ranges for process parameters have been established.
Characterization

The structure of eplerenone has been adequately elucidated and the representative spectra have been provided.

Impurities and degradation products arising from manufacturing and/or storage were reported and characterized. The proposed limits are considered adequately qualified (within International Conference on Harmonisation (ICH) limits and/or qualified from toxicological studies). Control of the impurities and degradation products is therefore considered acceptable.

Control of Drug Substance

Copies of the analytical methods and, where appropriate, validation reports were provided and are considered satisfactory for all analytical procedures used for release and stability testing of eplerenone.

Batch analysis results were reviewed and all results comply with the specifications and demonstrate consistent quality of the batches produced.

The drug substance packaging is considered acceptable.

Stability

Based on the long-term and accelerated stability data submitted, the proposed re-test period and storage conditions for the drug substance were supported and are considered to be satisfactory.

3.1.2 Drug Product

Composition and Description

Inspra tablets contain either 25 mg or 50 mg of eplerenone as the medicinal ingredient. The non-medicinal ingredients are lactose, microcrystalline cellulose, croscarmellose sodium, hypromellose, sodium lauryl sulfate, talc, magnesium stearate, titanium dioxide, polyethylene glycol, polysorbate 80, iron oxide yellow, and iron oxide red. 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 eplerenone with the excipients is demonstrated by the stability data presented in the proposed commercial formulation.

Both strengths are yellow, diamond-shaped, biconvex, film-coated tablets. The tablet strengths are identified by the following markings:

  • 25 mg tablet: "Pfizer" on one side of the tablet and "NSR" over "25" on the other side of the tablet.
  • 50 mg tablet: "Pfizer" on one side of the tablet and "NSR" over "50" on the other side of the tablet.

Both strengths are packaged in unit dose blister packages of 30 tablets.

Pharmaceutical Development

The pharmaceutical development is considered acceptable upon review.

Manufacturing Process and Process Controls

The manufacturing process is acceptable and the process is adequately controlled within justified limits.

The validated process is capable of consistently generating product that meets release specifications.

Control of Drug Product

Inspra is tested to verify that its identity, appearance, content uniformity, assay, dissolution, particle size, and levels of degradation products, drug-related impurities, and microbiological impurities are within acceptance criteria.

Copies of the analytical methods and, where appropriate, validation reports were provided and are considered satisfactory for all analytical procedures used for release and stability testing of Inspra.

Data from final batch analyses were reviewed and are considered to be acceptable according to the specifications of the drug product.

Stability

Based on the long-term, stress, and accelerated stability data submitted, the proposed 36-month shelf-life for Inspra is considered acceptable when the product is packaged in the proposed blister packaging and stored at 15-30°C.

3.1.3 Facilities and Equipment

The design, operations, and controls of the facility and equipment that are involved in the production of Inspra 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 Inspra 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

In vitro and in vivo studies showed that eplerenone was a selective aldosterone blocker. Eplerenone had an affinity for mineralocorticoid receptors, and had no measurable activity on estrogen, progesterone, and glucocorticoid receptors.

Eplerenone attenuated left ventricular (LV) remodelling and preserved cardiac function in animal models of heart failure (HF) produced by both ischemic and nonischemic etiologies. Functional improvements were associated with significant increases in capillary density and a reduction in myocardial gelatinase activity. The positive aspects of eplerenone on the HF models were seen in the absence of significant, if any, haemodynamic effects.

Eplerenone lowered blood pressure in Dahl salt-sensitive rats, stroke-prone spontaneously hypertensive rats, aldosterone/salt hypertensive rats, and in rats with hypertension induced by overstimulation of mineralocorticoid receptors by glucocorticoids.

Eplerenone produced cardioprotective effects in animal models of hypertension in part by attenuating proinflammatory molecule expression in the heart and by reducing subsequent vascular and myocardial injury.

The safety pharmacology testing of eplerenone in rats, mice, dogs, pigs, rabbits, and guinea pigs demonstrated no toxicologically significant cardiovascular, cardiopulmonary or central nervous system toxicities either in vivo or in vitro. The testing done revealed no significant pharmacological effects that would predict potential safety issues in clinical testing.

3.2.2 Pharmacokinetics

Absorption

Eplerenone was well absorbed after oral administration. Absorption did not appear to be carrier mediated or modulated by P-glycoprotein in any of the animal species. There was increased drug exposure in female rats compared to male rats due to greater CYP3A metabolism of eplerenone in male rats. No gender-related differences were observed in the other species tested.

Distribution

Radiolabelled eplerenone was widely distributed to the tissues with the majority of the radioactivity found in the organs responsible for absorption and elimination (gut and kidney), after oral administration. Eplerenone crossed the placenta in rats and rabbits, and was excreted in milk of lactating rats.

Eplerenone had relatively low plasma protein binding in all species tested.

Metabolism

Eplerenone was extensively metabolized in vivo in all of the animal species tested. In vitro metabolism studies showed that eplerenone was metabolized primarily by the CYP3A isoforms, specifically CYP3A4 in humans. Only potent inhibitors of CYP3A4 are expected to inhibit eplerenone metabolism in humans. The major human eplerenone metabolites were pharmacologically inactive at the expected plasma concentrations following therapeutic doses of eplerenone.

Excretion

Radiolabelled eplerenone was eliminated rapidly and completely following oral or intravenous (IV) administration. The majority of the radioactive dose was excreted in urine and faeces within 48 hours. After IV and oral administration to mice, rats, and dogs, the primary route of excretion was faecal, whereas in the rabbit, the primary route of elimination was urinary.

3.2.3 Toxicology

Single-Dose Toxicity

Eplerenone demonstrated a low level of acute toxicity in mice, rats, and dogs.

Repeat-Dose Toxicity

Rats treated orally with eplerenone subchronically or chronically had an increased incidence of chronic progressive nephropathy, a common spontaneous rat disease that does not have a human counterpart. This finding is considered to be irrelevant as a human hazard.

Male dogs treated orally with eplerenone subchronically or chronically had prostate atrophy due to competitive binding with androgen receptors at drug exposures that were 7-fold higher than the expected exposure at the human therapeutic dosage (50 mg per day). The no-observable-adverse-effect-level (NOAEL) for prostate atrophy was 5 mg/kg/day. The drug exposure in the male dog at the NOAEL was approximately 3-fold higher than the human therapeutic exposure. Female dogs had a NOAEL of 100 mg/kg/day, which provided an exposure 26-fold higher than the human therapeutic exposure.

Genotoxicity

Eplerenone did not show genotoxic potential in any of the in vitro and in vivo genotoxicity studies performed.

Carcinogenicity

In a 6-month carcinogenicity bioassay in heterozygous p53 knock-out mice, there were no neoplasms or other proliferative lesions attributable to the administration of eplerenone.

In a 2-year rat carcinogenicity bioassay, there was an increased incidence of benign thyroid follicular cell adenomas and kidney tubular cell adenomas. However, the rat thyroid and kidney effects were related to mechanisms irrelevant to human heath. Overall, eplerenone does not represent a carcinogenic risk to humans.

Reproductive and Developmental Toxicity

Eplerenone did not adversely affect fertility in female rats in a study that complied with ICH guidelines with an upper limit dosage of 1000 mg/kg/day. Male rats treated for 10 weeks at the highest dosage had decreased seminal vesicle size and the untreated females impregnated by these males had slightly increased pre-implantation loss. The NOAEL for this effect was 300 mg/kg/day, which provided a drug exposure 10-fold higher than the human therapeutic exposure for free eplerenone at steady-state.

Eplerenone did not cause foetal anomalies or other developmental abnormalities in the well-designed embryo-foetal development studies in rats and rabbits at dosages that either achieved maternal toxicity (rabbits at 300 mg/kg/day) or complied with ICH guidelines for an upper limit dosage (rats at 1000 mg/kg/day). At the NOAEL, the exposure multiple in rabbits was 11-fold at 100 mg/kg/day and in rats it was 20 to 40-fold (depending on the day of measurement) at 300 mg/kg/day.

The administration of eplerenone did not result in any pre- or post-natal developmental concerns in first generation (F1) rats that were exposed to eplerenone in utero and via the mother's milk.

3.2.4 Conclusion

The non-clinical studies for this drug submission are considered suitable. The non-clinical safety pharmacology program for eplerenone supports its safe use in humans as described in the proposed labelling. Also, Inspra has been marketed for at least 6 years in the United States and Europe, and no safety signals have emerged since that time. The post-marketing observation for such a time period supersedes those made in the non-clinical studies. Overall, it is concluded that there is sufficient data to predict the safe use of Inspra for the proposed indication.

3.3 Clinical basis for decision

3.3.1 Pharmacodynamics

At doses as low as 25 mg once a day (QD), eplerenone was pharmacologically active as an antagonist of aldosterone. This was demonstrated by mean percent increases from baseline in plasma renin (total and active) and serum aldosterone, across the clinical studies. The eplerenone-related increases in active and total plasma renin, and serum aldosterone were consistent with the blockade of aldosterone at the mineralocorticoid receptor and the compensatory feedback activation of the renin-angiotensin-aldosterone system (RAAS). Eplerenone increased the activity of RAAS hormones, and the magnitude of the effects of eplerenone on blood pressure and RAAS hormones were dose-dependent. Additionally, the pharmacodynamic effects of eplerenone lasted more than 24 hours, thus permitting effective once-daily dosing.

3.3.2 Pharmacokinetics

Absorption

Eplerenone was rapidly absorbed after oral administration. The time to reach the maximum plasma concentration was <2 hours in an empty stomach. The absolute bioavailability was approximately 70%. At doses ranging from 10-100 mg/day administered as single or multiple doses, the drug exposure parameters were fairly proportional to the dose but less than proportional at doses from 100-300 mg/day. Food, including a high-fat meal, did not significantly affect absorption. Bioequivalence studies were reviewed for the purpose of confirming statements made in the proposed Product Monograph with respect to the nature of the pharmacokinetics (PK) of Inspra in the 25-100 mg dose range and the food effect.

Significant accumulation with repeat-dosing was not observed. A one-compartment model with first-order kinetics adequately characterized the PK of eplerenone when administered orally in healthy subjects, patients with HF, and hypertensive patients.

Distribution

At eplerenone plasma concentrations of 0.02-1.0 μg/mL, which is within the expected therapeutic range for doses of 25-50 mg/day, eplerenone binding to plasma proteins was approximately 50% and the binding was mainly to alpha 1-acid glycoproteins. Eplerenone did not bind to red blood cells. The volume of distribution was 43-90 L.

Metabolism

Eplerenone is extensively metabolized by the liver (<5% was excreted unchanged in the urine and faeces). Eplerenone is primarily metabolized by the CYP isozyme, CYP3A4. None of the metabolites were pharmacologically active at the relevant concentrations.

Excretion

The kidney was the major route of elimination. Approximately 67% of the dose was excreted as metabolites in urine and the rest was eliminated in the faeces. The elimination half-life of eplerenone was 4-6 hours and the plasma clearance was approximately 10 L/hour.

Drug Interactions

Clinical studies confirmed that coadministration of potent CYP3A4 inhibitors significantly increased total plasma exposure of eplerenone. The concomitant use of strong inhibitors of CYP3A4 such as ketoconazole or clarithromycin are therefore contraindicated. Weaker CYP3A4 inhibitors (for example, erythromycin, amiodarone, fluconazole) may be co-administered with an eplerenone dose no greater than 25 mg if potassium levels are monitored very closely.

An interaction is possible with non-steroidal anti-inflammatory drugs (NSAIDs) particularly in patients with impaired renal function and concomitant treatment with angiotensin converting enzyme (ACE) inhibitors or angiotensin receptor blockers (ARBs) Both of these products reduce aldosterone plasma concentration. It is known that in such patients, potassium-sparing diuretics can exacerbate potential hyperkalaemia.

Special Populations

Hepatic Impairment: In single- and multiple-dose studies administering eplerenone 400 mg QD (once a day), patients with moderate hepatic impairment (Child-Pugh Class B) had significantly higher (42%) drug exposure (AUC) levels and a 30% lower clearance (CL/F) compared to healthy subjects. The maximum plasma concentrations (Cmax) and time to reach the maximum plasma concentrations were similar. The dose of 400 mg QD is 8-fold greater than the recommended therapeutic dose. No dose adjustment is required for patients with moderate hepatic impairment. Patients with severe hepatic impairment have not been studied. Therefore, Inspra is not recommended in these patients.

Renal Impairment: In single- and multiple-dose studies administering eplerenone 100 mg QD, there were no statistically significant differences between any of the renal impairment groups and their matched-normal groups for AUC, Cmax, or CL/F. Among the subjects with mild, moderate and severe renal impairment, changes in CL/F and AUC increased with increased degree of renal impairment; however, none of the observed changes were statistically significant.

Age and Gender: In single- and multiple-dose studies administering eplerenone 100 mg QD, at steady-state PK, the Cmax and AUC were 22% and 45% greater, respectively, for elderly subjects (≥65 years) compared to younger subjects (18-45 years). Both the elderly and the young excreted <8% of the administered dose in urine as unchanged total eplerenone. No significant differences were found in steady-state PK parameters of eplerenone between females and males.

3.3.3 Clinical Efficacy

The efficacy and safety of Inspra were evaluated in the eplerenone post-acute myocardial infarction heart failure efficacy and survival study (EPHESUS). EPHESUS was a double-blind, randomized, placebo-controlled, multinational, multicentre study in patients (n=6,632) clinically stable 3-14 days after an acute MI with LV dysfunction and either diabetes or clinical evidence of HF. Patients with HF of valvular or congenital etiology, patients with unstable post-infarct angina, and patients with a serum potassium >5.0 mmol/L or serum creatinine >221 μmol/L were excluded. Patients were allowed to receive standard post-MI drug therapy and to undergo revascularization by angioplasty or coronary artery bypass graft surgery. Patients who received Inspra (eplerenone) were given an initial dose of 25 mg QD, titrated to the target dose of 50 mg QD after 4 weeks if their serum potassium was <5.0 mmol/L. The mean dose of Inspra was 43 mg/day. Patients also received standard care including ACE inhibitors, beta-blockers, aspirin, nitrates, diuretics, or 3-hydroxy-3-methyl-glutaryl-coenzyme A (HMG-CoA) reductase inhibitors. Patients were followed for an average of 16 months (range: 0-33 months).

The co-primary endpoints for EPHESUS were (a) the time to death from any cause, and (b) the time to first occurrence of either cardiovascular (CV) mortality (defined as sudden cardiac death or death due to progression of HF, stroke, or other CV causes) or CV hospitalization (defined as hospitalization for progression of HF, ventricular arrhythmias, acute MI, or stroke).

Inspra significantly reduced all-cause mortality compared to placebo. For the first primary endpoint (time to death from any cause), there were 478 deaths in the Inspra group (14.4%) compared to 554 deaths in the placebo group (16.7%). An increase in survival and decrease in mortality was seen with the use of Inspra, not only in the general population enrolled but also in the main subgroups analyzed (males and females, age groups, regions, race, New York Heart Association (NYHA) classification, Killip classification, diabetic and non-diabetic patients, history or no history of hypertension at baseline, blood pressure levels, at all baseline serum potassium levels except >5 mmol/L, and in patients receiving anti-hypertensive medications at baseline). Statistical significance was not seen in all subgroups. It was noted that a decrease in sudden death was the main contributor to a decrease in mortality (one third of the deaths from any cause were due to sudden death). There was also a significant reduction in CV deaths (largely due to decrease in sudden death) and CV hospitalizations (largely due to a decrease in the risk and number of episodes of HF).

3.3.4 Clinical Safety

The study results for the evaluation of clinical safety were primarily taken from the study EPHESUS. Compared to the placebo group, the Inspra group had a statistically significantly greater number of patients that experienced serious hyperkalaemia ≥6 mmol/L [5.5 versus (vs.) 3.9%]; increased creatinine (2.4 vs. 1.5%); increased blood urea nitrogen (1.6 vs. 1.0%); postural hypotension (0.7 vs. 0.3%); gastrointestinal reflux, pancreatitis, sepsis, and hypothyroidism (0.5 vs. 0.2% each); arterial leg thrombosis (0.4 vs. <0.1%); varicose veins (0.3 vs. <0.1%), and ketosis (0.3 vs. <0.1%). The most common treatment-emergent adverse events (AEs, >2.0%) were related to the condition of the patients and these AEs were seen with the same or greater frequency in the placebo-treated patients: HF, unstable angina, non-cardiac chest pain, MI, dyspnoea and coughing, as well as dizziness which may or may not be related to the patient condition.

Serious adverse events (SAEs) that were associated significantly more with Inspra compared to placebo included: dehydration (0.5 vs. 0.2%), arterial leg thrombosis (0.3 vs. <0.1), increased creatinine (0.3 vs. <0.1%), and pyelonephritis (0.2 vs. 0.0%).

The percentage of patients that discontinued medication due to an AE was not significantly different in the two groups. The most common reason was hyperkalaemia in the Inspra group (0.7%) and HF in the placebo group (0.8%).

Overall, there was a greater incidence of SAEs observed in the placebo-treated patients (51%) compared to the Inspra-treated patients (48.5%). Most of these SAEs were due to HF-related events which led to the authorization of Inspra for the management of patients with HF post-MI.

Two areas of interest associated with aldosterone antagonists are their effects on serum potassium and sex-related hormones.

Hyperkalaemia

A statistically significant greater percentage of Inspra-treated patients had elevated serum potassium levels compared to the placebo group (>5.5 mmol/L [15.6% vs. 11.2%], ≥6.0 mmol/L [5.5% vs. 3.9%], or >5.5 mmol/L on at least two consecutive occasions [3.0% vs. 1.7%]). More than 50% of the episodes of hyperkalaemia took place during the first 30 days of treatment but they also occurred sporadically throughout the 2-year period of therapy. The number of patients that permanently discontinued treatment due to hyperkalaemia were rather low (0.7% with Inspra and 0.3% with placebo).

Hyperkalaemia is more likely to occur in certain patients such as those with high serum potassium before the onset of treatment and with renal impairment. The use of certain agents may also increase the risk of hyperkalaemia. Such drugs or conditions include but are not necessarily limited to: (a) NSAIDs including cyclooxygenase-2 (COX-2) inhibitors, cyclosporine, sirolimus, diabetes, or advanced age, (b) agents which affect the RAAS, such as ACE inhibitors and ARBs which are all known to increase serum potassium levels, (c) adrenal disease, ketoconazole which all impair aldosterone metabolism, (d) aldosterone mineralocorticoid receptor blockers such as eplerenone and spironolactone, and (e) potassium-sparing diuretic.

The risk of hyperkalaemia increased with decreasing renal function for both placebo- and Inspra-treated patients but the increase was significantly larger for the latter at the lower creatinine clearance. The risk of hyperkalaemia also increased with patients >65 years of age and even more with patients >75 years of age which is probably a reflection of the decrease in renal function in these patients.

The risk of hyperkalaemia will likely be higher when Inspra is used in routine clinical practice rather than in a clinical trial where monitoring is more strict. For this reason, appropriate warnings and precautions have been incorporated in the Product Monograph and the labelling.

Sex Hormone-Related Adverse Events

The incidence rates of decreased libido, impotence, gynecomastia, female breast pain, and menstrual abnormalities were <1.0% in each treatment group (Inspra and placebo) with no statistically significant treatment differences observed.

3.4 Benefit/Risk Assessment and Recommendation

3.4.1 Benefit/Risk Assessment

In the EPHESUS study, Inspra (eplerenone) improved the rate of survival in patients with HF and/or LV dysfunction post-MI, who were already receiving standard treatment (ACE inhibitors, diuretics, beta-blockers, digoxin) for their condition.

Eplerenone has shown selectivity for mineralocorticoid receptors and much less selectivity for progesterone and androgen receptors, and therefore does not seem to cause AEs associated with sex-related hormones.

Hyperkalaemia is the major risk associated with Inspra. However, serious hyperkalaemia can be prevented by adequate monitoring of serum potassium; and avoidance of drugs, food, and food supplements which can also cause or worsen hyperkalaemia. Dosage adjustment and proper selection of patients to be treated are other ways to avoid this AE. Adequate guidelines are included in the Inspra Product Monograph.

The benefit/risk assessment is favourable for the use of Inspra to reduce mortality in patients who have LV dysfunction or clinical signs of HF following an MI. Restrictions to manage risks associated with the identified safety concerns have been incorporated into the Inspra Product Monograph.

3.4.2 Recommendation

Based on the Health Canada review of data on quality, safety and efficacy, Health Canada considers that the benefit/risk profile of Inspra is favourable as an adjunct to standard therapy to reduce the risk of mortality following myocardial infarction in clinically stable patients who have evidence of heart failure and left ventricular systolic dysfunction (ejection fraction ≤40%). 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 (NOC) pursuant to section C.08.004 of the Food and Drug Regulations.

4 Submission Milestones

Submission Milestones: InspraTM/MC

Submission MilestoneDate
Pre-submission meeting:2007-05-17
Submissionfiled:2008-03-03
Screening
Screening Acceptance Letter issued:2008-05-02
Review
Biopharmaceutics Evaluation complete:2009-02-24
Quality Evaluation complete:2009-02-26
Clinical Evaluation complete:2009-02-25
Labelling Review complete:2009-02-25
NOC issued by Director General:2009-02-26