Summary Basis of Decision for Onbrez Breezhaler

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
Onbrez Breezhaler

Indacaterol (as indacaterol maleate), 75 mcg, Capsule, Inhalation

Novartis Pharmaceuticals Canada Inc.

Submission control no: 143984

Date issued: 2012-07-11

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:

Onbrez Breezhaler

Manufacturer/sponsor:

Novartis Pharmaceuticals Canada Inc.

Medicinal ingredient:

Indacaterol (as indacaterol maleate)

International non-proprietary Name:

Indacaterol

Strength:

75 mcg

Dosage form:

Capsule

Route of administration:

Inhalation

Drug identification number(DIN):

  • 02376938

Therapeutic Classification:

Long-acting beta2-agonist

Non-medicinal ingredients:

Gelatin (capsule shell), lactose monohydrate

Submission type and control no:

New Drug Submission, Control Number 143984

Date of Submission:

2010-12-22

Date of authorization:

2011-12-06
2 Notice of decision

On December 6, 2011, Health Canada issued a Notice of Compliance to Novartis Pharmaceuticals Canada Inc. for the drug product Onbrez Breezhaler.

Onbrez Breezhaler contains the medicinal ingredient, indacaterol maleate, which is a selective long-acting beta2-adrenergic agonist.

Onbrez Breezhaler is indicated for long-term, once-daily, maintenance bronchodilator treatment of airflow obstruction in patients with chronic obstructive pulmonary disease (COPD), including chronic bronchitis and emphysema.

Onbrez Breezhaler is not indicated for the relief of acute deterioration of COPD and it is not indicated for asthma use. The safety and effectiveness of Onbrez Breezhaler in asthma have not been established.

When inhaled, indacaterol acts locally in the lung as a bronchodilator. The pharmacological effects of beta2-adrenergic agonists, including indacaterol, are at least in part attributable to stimulation of intracellular adenyl cyclase, the enzyme that catalyzes the conversion of adenosine triphosphate (ATP) to cyclic-3', 5'-adenosine monophosphate (cAMP). Increased cAMP levels cause relaxation of bronchial smooth muscle and help open up the airways, which allows for easier transfer of air in and out of the body, thereby reducing symptoms, such as wheezing and shortness of breath.

The market authorization of Onbrez Breezhaler was based on quality, non-clinical, and clinical information submitted. Three dose ranging studies and one dosing regimen study were conducted to select the indacaterol doses for further clinical development. The safety and efficacy of Onbrez Breezhaler were studied in 21 Phase III controlled clinical studies in over 13,500 patients, where indacaterol was used at doses of 75 mcg, 150 mcg, 300 mcg and 600 mcg. The approved dose of 75 mcg once daily (q.d.) was studied in two pivotal 12-week, multicentre, randomized, double-blind, placebo-controlled, parallel-group studies. These two studies enrolled 641 male and female patients with moderate to severe COPD who were 40 years or older and had a history of smoking. The primary efficacy endpoint for both studies was 24-hour post-dose trough forced expiratory volume in one second (FEV1) following 12 weeks of treatment. Secondary efficacy variables included other spirometry end-points, rescue medication use, transition dyspnoea index (TDI), and the St. George's Respiratory Questionnaire (SGRQ).

Results from both studies showed that Onbrez Breezhaler 75 mcg led to a significantly greater 24-hour post-dose trough FEV1 compared to placebo at 12 weeks. Additional spirometry variables and other secondary measures also demonstrated significant improvements compared to placebo. In addition, patients treated with 75 mcg Onbrez Breezhaler showed an improvement in the TDI focal score and the SGRQ total score. These patients had an increase in the percentage of 'days able to perform usual daily activities', and used less daily rescue medication during the study compared to patients treated with placebo. The results from these pivotal studies were supported by the efficacy results obtained with the 150 mcg and 300 mcg doses of indacaterol; however, no additional clinical benefit from using the higher doses was shown.

The safety of indacaterol has been studied at doses of 75 mcg, 150 mcg, 300 mcg, and 600 mcg q.d. The COPD safety population consisted of 449 patients who received 75 mcg; 2,611 patients who received 150 mcg; 1,157 patients who received 300 mcg; and 547 patients who received 600 mcg up to 12 months of inhalation. The safety profile of indacaterol was similar to that of other long-acting beta agonists. The most common adverse drug reactions at the recommended dose of 75 mcg of Onbrez Breezhaler q.d. were cough; nasopharyngitis; headache; nausea and oropharyngeal pain; muscle spasms; and viral upper respiratory tract infection. Post-inhalation cough, which was not associated with COPD exacerbations, bronchospasm, or decrease in FEV1 was also observed.

Onbrez Breezhaler (75 mcg, indacaterol maleate, powder for inhalation,) is presented as a capsule and should be used with the Onbrez Breezhaler inhalation device only. The Onbrez Breezhaler inhalation device should not be used with any other capsules. Further dosing guidelines are available in the Product Monograph.

Onbrez Breezhaler is contraindicated in patients with hypersensitivity to indacaterol maleate or to any other components of the product.

Onbrez Breezhaler is not indicated for the treatment of asthma.

Onbrez Breezhaler 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 Onbrez Breezhaler are described in the Product Monograph.

Based on the review of data on quality, safety, and efficacy, Health Canada considers that the benefit/risk profile of Onbrez Breezhaler powder for inhalation 75 mcg is favourable for the indication of chronic obstructive pulmonary disease (COPD), including chronic bronchitis and emphysema.

3 Scientific and Regulatory Basis for Decision

This New Drug Submission (NDS) control number 143984 is a re-file of the original NDS 127743 which received a Notice of Non-compliance (NON) on January 13, 2010. Issues raised by Health Canada in the NON required additional studies to be conducted. Given it was not possible for the sponsor to provide a complete response to the NON within the required time frame specified in Health Canada's Guideline Management of Drug Submissions (90 days) because the requested clinical data could not be generated, the sponsor chose to withdraw the NDS without prejudice to a subsequent re-filing. The sponsor re-filed the submission on December 22, 2010 and provided responses to key points raised in the NON, in addition to the submission of new clinical studies to support the approval of two doses of Onbrez Breezhaler, 75 mcg and 150 mcg once daily via inhalation for the long-term, once-daily, maintenance bronchodilator treatment of airflow obstruction in patients with chronic obstructive pulmonary disease (COPD), including chronic bronchitis and emphysema. The data provided with the re-filed submission (NDS 143984) was reviewed; in addition, review reports from the United States Food and Drug Administration (FDA) and European Medicines Agency (EMA) were consulted under the provisions of the Draft Guidance Document: The Use of Foreign Reviews by Health Canada. The overall risk-benefit assessment supported the approval of the 75 mcg dose of Onbrez Breezhaler for the proposed indication; however, the approval of the higher dose of 150 mcg was not supported at this time. 

Based on the Health Canada review of data on quality, safety, and effectiveness, Health Canada considers that the benefit/risk profile of 75 mcg Onbrez Breezhaler (indacaterol maleate, inhalation powder), is favourable for the long-term, once-daily, maintenance bronchodilator treatment of airflow obstruction in patients with chronic obstructive pulmonary disease (COPD), including chronic bronchitis and emphysema. A Notice of Compliance (NOC) was subsequently issued for Onbrez Breezhaler for the 75 mcg strength on December 6, 2011.

3.1 Quality Basis for Decision

3.1.1 Drug Substance (Medicinal Ingredient)

General Information

Indacaterol, supplied as indacaterol maleate, is the medicinal ingredient of Onbrez Breezhaler. Indacaterol is a long-acting beta2-agonist intended for long-term maintenance treatment of COPD. When inhaled, indacaterol acts locally in the lung as a bronchodilator. The mechanism of action of beta2-adrenoceptor agonists, including indacaterol, is at least in part attributable to stimulation of intracellular adenyl cyclase, the enzyme that catalyzes the conversion of adenosine triphosphate (ATP) to cyclic-3', 5'-adenosine monophosphate (cAMP). Increased cAMP levels cause relaxation of bronchial smooth muscle and help open up the airways, which allows for easier transfer of air in and out of the body, thereby reducing symptoms, such as wheezing and shortness of breath.

Manufacturing Process and Process Controls

Indacterol maleate is the active ingredient. Indacaterol maleate is manufactured by a multi-step process. In-process controls performed during manufacture were reviewed and are considered acceptable. The drug substance specifications were found to be satisfactory.

Characterization

The structure of indacaterol maleate has been adequately elucidated. Physical and chemical properties have been described and were found to be satisfactory.

Impurities arising from manufacturing were reported and characterized. These products were found to be within International Conference on Harmonisation (ICH) limits and therefore are considered acceptable.

Control of Drug Substance

The drug substance specifications and analytical methods used for quality control of indacaterol maleate are considered acceptable.

The levels of product- and process-related impurities were adequately monitored throughout the manufacturing process. Results from in-process controls indicated that the impurities of the drug substance were appropriately qualified and adequately controlled. The levels of impurities reported for the drug substance were found to be within the established limits.

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

The drug substance packaging is considered acceptable.

Stability

Based on the long-term, real-time, and accelerated stability data submitted, the proposed retest period for the drug substance was supported and is considered satisfactory.

3.1.2 Drug Product

Onbrez Breezhaler is supplied as a white, or very slightly grayish or very slightly yellowish powder, which is enclosed in a colourless hard gelatin capsule and ready for single-dose inhalation. Each capsule contains 97 mcg indacaterol maleate, which corresponds to75 mcg indacaterol base and lactose monohydrate.

The capsules are printed with a black product code "IDL 75" above a black bar on one side of the capsule and a bird symbol printed on the other side. Onbrez Breezhaler is provided in blister strips which contain 10 capsules each. Three blister strips (total of 30 capsules) are packaged in a carton along with the inclusion of one Onbrez Breezhaler inhalation device.

Onbrez Breezhaler 75 mcg contains the following inactive ingredients: gelatin (capsule shell) and lactose monohydrate. 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 Onbrez Breezhaler 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. The capsule formulation used in the conduct of clinical studies is identical to the proposed commercial formulation.

The inhalation device called "Concept1", used consistently in the conduct of pivotal studies and dose-range studies. Numerous studies were performed to demonstrate the suitability of this device for the proposed product. Development of this device has been shown to meet Health Canada requirements.

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

Onbrez Breezhaler is tested to verify the identity of the active ingredient, appearance (of capsules content and capsule shell), fine particle mass per capsule, uniformity of the delivered dose, amounts of water and degradation products, assay of active ingredient, content uniformity the capsules and the presence of microbial organisms are within stated acceptance criteria. The test specifications and analytical methods are considered acceptable; the shelf-life and the release limits, for individual and total degradation products are within acceptable limits.

Validation results of the analytical methods used including for the determination of indacaterol maleate and the drug-related impurities are considered acceptable.

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 real-time, long-term, and accelerated stability data submitted, the proposed 18-month shelf-life for Onbrez Breezhaler 75 mcg is considered acceptable, when the product is packaged in blister packs, stored at 15-30°C and protected from light and moisture.

The compatibility of the drug product with the container closure system was demonstrated by conducting 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 of Onbrez Breezhaler are considered suitable for the activities and products manufactured.

3.1.4 Adventitious Agents Safety Evaluation

The excipient, lactose monohydrate, is provided from a certified supplier and the milk is obtained from healthy cattle under the same conditions as milk intended for human consumption.

The gelatin contained within the capsule shell is of animal origin. Certificates of suitability confirming that the material is not from a bovine spongiform encephalopathy (BSE)/transmissible spongiform encephalopathy (TSE)-affected country has been provided from each supplier.

3.1.5 Conclusion

The Chemistry and Manufacturing information submitted for Onbrez Breezhaler 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

The Sponsor has conducted a series of in vitro and in vivo assays to characterize the pharmacology, pharmacokinetics and toxicology of indacaterol.

3.2.1 Pharmacodynamics

Pharmacodynamic studies show that indacaterol is a potent beta2-adrenoceptor agonist with high intrinsic efficacy. Indacaterol has a rapid onset and a long duration of action. A membrane interaction study suggests that the fast onset and long duration of action for indacaterol are due to its optimal lipophilic properties that allow the compound to be retained in the cellular membrane.

In addition to being a potent beta2-receptor agonist, indacaterol has lower affinities for the beta1 receptor, as well as alpha1A and alpha1D receptors.

Safety pharmacology studies conducted revealed no potential effects of indacaterol on the cardiovascular, respiratory, and central nervous systems in rodents.

3.2.2 Pharmacokinetics

Absorption

Following oral administration, indacaterol was rapidly absorbed with time to maximum plasma concentrations ranging from 0.5 to 2 hours. Oral bioavailability was 1% in mice, 0% rats, and 33% in dogs. The terminal half-life of indacaterol following intravenous administration was 5.7 hours in mice, 7.9 hours in rats, 10.9 hours in rabbits, and 20 hours in dogs.

Distribution

Plasma clearance and volume of distribution of indacaterol ranged from moderate to high. Toxicokinetic measurements indicated that exposure increased with dose, with no apparent accumulation upon multiple dosing. Administration of radiolabelled indacaterol to rats revealed drug-related radioactivity was widely distributed to most rat tissues, with the notable exception of the brain, spinal cord, and testis. The in vitro plasma protein binding of indacaterol ranged from 91% to 96%.

Metabolism

In vitro studies identified UDP-glucuronosyltransferase 1A1 (UGT1A1) and cytochrome P450 (CYP) 3A4 as the enzymes primarily responsible for the metabolism of indacaterol and classified indacaterol as a moderately permeable compound and a substrate for the efflux transporter P-glycoprotein (P-gp). In vitro enzyme inhibition studies indicated that indacaterol has negligible potential to cause metabolic interactions with medications (by inhibition or induction of cytochrome P450 enzymes, or induction of UGT1A1) at the systemic exposure levels achieved in clinical practice.

Excretion

Elimination of indacaterol was primarily through the faeces, with a major portion of the dose being recovered as unchanged parent drug. There was no indication of reactive metabolite formation. Parent drug and metabolites were transferred rapidly into the milk of lactating rats with an overall milk:plasma total radioactivity concentration ratio close to unity.

3.2.3 Toxicology

Single-Dose Toxicity

Single oral administrations of indacaterol to rats and mice at doses of 1,600 mg/kg were well tolerated. Single oral administrations of indacaterol to dogs at doses between 0.1 and 10 mg/kg were consistent with the pharmacological effect of indacaterol. Higher doses were not tolerated.

Single subcutaneous administrations of indacaterol to mice at doses of 5 mg/kg in males and 100 mg/kg in females and to rats at doses up to 100 mg/kg were tolerated without mortalities. Mortality which may be associated with tolerability issues at the administration site was apparent at higher doses.

The acute toxicity studies have indicated that the potential for toxicity following accidental overdose of indacaterol is low.

Repeat-Dose Toxicity

The sponsor has conducted repeat-dose toxicity studies in mice, rats and dogs. The effects of indacaterol seen in repeat-dose toxicity studies in dogs were mainly on the cardiovascular system. These effects consisted of tachycardia and associated increased QTc intervals, arrhythmias and myocardial lesions that included myocardial fibrosis. These are known pharmacological effects and can be explained by the beta2-agonistic properties of indacaterol. Beta2-agonistic mediated vasodilation and associated hypotension is known to result in reflex tachycardia, which when excessive is associated with heart lesions. The effects seen in rats were mild irritancy of the upper respiratory tract, consisting of rhinitis and epithelial changes of the nasal cavity and larynx. All these findings were observed only at exposures considered sufficiently in excess of the maximum human exposure.

Mutagenicity

There was no evidence of any mutagenic or clastogenic potential with the administration of indacaterol.

Carcinogenicity

The carcinogenic potential of indacaterol was evaluated in a 2-year inhalation rat study and in a 26-week oral transgenic mouse study. Lifetime treatment of rats resulted in increased incidences of benign ovarian leiomyoma and focal hyperplasia of ovarian smooth muscle in females at doses approximately 272-times the dose of 75 mcg once-daily for humans (on a mg/m2 basis). Increases in leiomyomas of the rat female genital tract have been similarly demonstrated with other beta2-adrenergic agonist drugs. A 26-week oral (gavage) study in mice with indacaterol did not show any evidence of tumorigenicity at doses approximately 40,000-times the dose of 75 mcg once-daily for humans (on a mg/m2 basis).

Reproductive and Developmental Toxicity

Findings in the reproductive toxicity studies were typical of those seen following systemic exposure to beta2 agonists. Adverse effects with respect to fertility, pregnancy, embryonal/foetal development, pre- and postnatal development could only be demonstrated at doses approximately 800-fold the daily inhalation dose of 75 mcg in humans (on a mg/m2 basis). The effects, namely an increased incidence of one type of skeletal abnormality, were observed in rabbits.

Indacaterol and its metabolites were also noted to transfer rapidly into the milk of lactating rats.

Local Tolerance

Local tolerance studies suggest that indacaterol is a weak lymph node activator and a skin sensitizer after topical application with probable phototoxic potential.

3.2.4 Summary and Conclusion

The non-clinical pharmacology and toxicology program for Onbrez Breezhaler (indacaterol) demonstrated that the compound is relatively safe in reference to the approved indication. Adequate statements are in place in the Product Monograph to address the identified safety concerns.

3.3 Clinical basis for decision

3.3.1 Pharmacodynamics

Onbrez Breezhaler (indacaterol) is a long-acting beta2-adrenergic agonist. Upon inhalation, it acts locally in the lung as a bronchodilator. Onbrez Breezhaler has a rapid onset of action (within 5 minutes) following inhalation, and 24 hour duration of action.

The pharmacological effects of beta2-adrenoceptor agonists are at least in part attributable to stimulation of intracellular adenyl cyclase, the enzyme that catalyzes the conversion of ATP to cAMP. Increased cAMP levels cause relaxation of bronchial smooth muscle. In vitro studies have shown that indacaterol has more than 24-fold greater agonist activity at beta2-receptors compared to beta1-receptors and 20-fold greater agonist activity compared to beta3-receptors.

Although beta2-receptors are the predominant adrenergic receptors in bronchial smooth muscle and beta1-receptors are the predominant receptors in the human heart, there are also beta2-adrenergic receptors in the human heart comprising 10% to 50% of the total adrenergic receptors. The precise function of beta2-adrenergic receptors in the heart is not known, but their presence raises the possibility that even highly selective beta2-adrenergic agonists may have cardiac effects. The clinical safety programme included a thorough QT study in healthy subjects and additional pharmacology studies in COPD patients. The results of these studies did not reveal significant effect of indacaterol on QT prolongation, heart-rate, breathlessness, and health status.

3.3.2 Pharmacokinetics

Absorption

Following oral inhalation, indacaterol was rapidly absorbed, from a combination of pulmonary and intestinal absorption, and achieved peak serum concentrations in approximately 15 minutes following either single or repeated dosing. Systemic exposure to indacaterol increased with increasing dose (150 mcg to 600 mcg) in a dose proportional manner, and was about dose-proportional in the dose range of 75 mcg to 150 mcg. The absolute bioavailability of indacaterol after an inhaled dose was on average 43-45%.

Distribution

Following intravenous infusion, the volume of distribution of indacaterol during the terminal elimination phase was 2,361 L to 2,557 L indicating an extensive distribution. The in vitro human serum and plasma protein binding was 94.1 to 95.3% and 95.1 to 96.2%, respectively. After multiple dosing, pharmacokinetic steady-state was achieved within 12-15 days of inhalation.

Metabolism

After oral administration of radiolabelled indacaterol, unchanged indacaterol was the main component in serum, accounting for about one-third of the total drug-related exposure over 24 hours. A hydroxylated derivative was the most prominent metabolite in serum. Phenolic O-glucuronides of indacaterol and hydroxylated indacaterol were further prominent metabolites. A diastereomer of the hydroxylated derivative, an N-glucuronide of indacaterol, and C- and N-dealkylated products were further metabolites identified. In vitro investigations indicated that indacaterol has negligible potential to cause metabolic interactions with medications (by inhibition or induction of cytochrome P450 enzymes, or induction of UGT1A1) at the systemic exposure levels achieved in clinical practice.

Clinical drug interaction studies were carried out using potent and specific inhibitors of CYP3A4 and P-gp (i.e. ketoconazole, erythromycin, verapamil and ritonavir). The data suggest that systemic clearance of indacaterol is influenced by modulation of both CYP3A4 and P-pg activities and that there is an approximate 2-fold increase in indacaterol systemic exposure (Area under the Curve) caused by the strong dual inhibitor ketoconazole reflects the impact of maximal combined inhibition. The increase in exposure observed was not considered a safety concern given the safety experience of treatment with Onbrez Breezhaler in clinical studies was up to one year at higher doses (up to 600 mcg).

Excretion

Following oral administration, indacaterol was excreted primarily through the faeces as unchanged parent drug (54% of the dose) and, to a lesser extent as hydroxylated indacaterol metabolites (23% of the dose).  Following inhalation, the amount of indacaterol excreted unchanged via urine was generally lower than 2% of the dose.

3.3.3 Clinical Efficacy

This NDS submission 143984 is a re-file of the NDS 127743, which received a Notice of Non-compliance (NON) on Jan 13, 2010 because the review concluded that the lowest effective dose of indacaterol in the management of COPD had not been established.

The sponsor re-filed the submission by proposing two lower doses, 75 mcg and 150 mcg for approval. With this re-file, the Sponsor has provided a satisfactory response to the key points raised in the NON. In addition, new clinical studies that complemented the original data package were submitted.

The efficacy of Onbrez Breezhaler was studied in 21 Phase III controlled studies in over 13,500 patients, where indacaterol was used at doses of 75 mcg, 150 mcg, 300 mcg, and 600 mcg. In addition to the clinical studies, which consisted of dose ranging studies, as well as pivotal studies for efficacy and safety, the sponsor provided pooled data, as well as a modelling report of the bronchodilatory dose-response analysis of indacaterol in COPD.

A dose-ranging study (Study B2357), conducted in bronchoreactive (asthma) population, suggested that the doses of 75 and 150 mcg had similar bronchodilatory effects after 14 days of dosing and that lower doses were suboptimal. A dose-ranging study (Study B2356) conducted in patients with COPD, confirmed the efficacy of the two doses, but also suggested that there were no meaningful differences in lung function between the 75 mcg and 150 mcg doses of indacaterol in this patient population.

The recommended for approval dose of Onbrez Breezhaler 75 mcg once daily was studied in two pivotal 12-week, multicentre, randomized, double-blind, placebo-controlled, parallel-group studies Study B2355 and Study B2354. These two studies enrolled 641 patients with a clinical diagnosis of COPD, who were 40 years or older; had a history of smoking; had a post-bronchodilator forced expiratory volume in one second (FEV1) less than 80% and at least 30% of the predicted normal value and a post-bronchodilator ratio of FEV1 over forced expiratory vital capacity (FVC) of less than 70%. The primary efficacy endpoint for both studies was 24-hour post-dose trough FEV1, (defined as the average of two FEV1 measurements taken after 23 hours 10 minutes and 23 hours and 45 minutes after the previous dose) following 12 weeks of treatment. Secondary efficacy variables included other FEV1 and FVC time points, rescue medication use, symptoms, transition dyspnoea index (TDI), and health-related quality of life measured using the St. George's Respiratory Questionnaire (SGRQ), a disease-specific patient reported instrument which measures symptoms, activities, and impact of disease on daily life.

Results from the two pivotal studies demonstrated that compared to placebo, Onbrez Breezhaler 75 mcg led to a significantly greater trough FEV1 (tFEV1) at 12 weeks by 0.14 L and 0.12 L in study B2355 and B2354, respectively. Consistent with the expected response to a bronchodilator drug, other spirometry based endpoints also demonstrated superiority of indacaterol 75 mcg over placebo including tFEV1 on Days 2, 29, 57 and 84; FEV1 AUC5min-4hr; peak FEV1 over 5 minutes to 4 hours on Days 1 and Week 12. At 5 minutes post first dose, the treatment difference was statistically significant, 0.10 L (B2355) and 0.09 L (B2354). On day 84, the treatment difference achieved at 5 minutes post dose was 0.18 L (B2355 and B2354). There was no difference in the rate of change in tFEV1 for indacaterol 75 mcg from Day 29 to Week 12. The key secondary end-point TDI, did not achieve a clinically and statistically significant improvement compared with placebo-treated patients in the B2355 study. However, in the B2354 study both statistically and clinically significant improvements versus placebo were noted. The quality of life questionnaire, SGRQ total score, which was -3.6 in Study B2355 and -3.8 in Study B2354, reached statistical significance versus placebo in both studies; however, it did not meet the predefined clinically meaningful difference of -4. Rescue medication use was also statistically significantly reduced over 12 weeks of treatment with indacaterol 75 mcg compared with placebo.

Pooled efficacy analyses showed that both the 75 and 150 mcg doses of indacaterol were clinically and statistically significantly superior to placebo in terms of spirometry endpoints, as well as symptom-related parameters, such as TDI, SGRQ, and rescue medication use. However, based on the clinical data, as well as the analysis of the modeling report, it was concluded that at this time, there is no robust evidence for any meaningful clinical benefit of the higher dose of 150 mcg over the 75 mcg of Onbrez Breezhaler.

3.3.4 Clinical Safety

The safety of Onbrez Breezhaler has been studied at doses of 75 mcg, 150 mcg, 300 mcg, and 600 mcg administered once daily. The COPD safety population consisted of 449 patients who received 75 mcg; 2,611 patients who received 150 mcg; 1,157 patients who received 300 mcg; and 547 patients who received 600 mcg up to 12 months. The safety profile of Onbrez Breezhaler was similar to that of other long-acting beta agonists.

The most common adverse drug reactions of Onbrez Breezhaler observed at the 75 mcg dose were: cough; nasopharyngitis; headache; nausea and oropharyngeal pain; muscle spasms; and viral upper respiratory tract infection. The severity of these events was in the vast majority mild to moderate.

In the B2355 study, no deaths were reported. Two deaths (myocardial infarction and a ruptured aortic aneurysm) were reported in the B2354 study within the placebo group.

Across the two studies, a total of 10 patients (3 patients in the Onbrez Breezhaler 75 mcg treatment group and 7 patients in the placebo group) had Serious Adverse Events which lead to discontinuation from the study. There were no clinically meaningful differences reported between treatment groups in the haematology, chemistry laboratory (including serum potassium, blood glucose and transaminases) or urinalysis assessments, vitals or electrocardiogram.

In a 12-month study (B2334), treatment with Onbrez Breezhaler 300 mcg and 600 mcg in COPD patients resulted in an increased number of serious cardiovascular or cerebrovascular adverse events [for example (e.g.) atrial fibrillation, myocardial ischemia, cardiac failure congestive, angina pectoris, ventricular tachycardia] in comparison with either formoterol or placebo. In the 12-month study, the increased risk was noticeable in a sub-group of patients with cardiovascular risk factors (e.g., hypertension, hyperlipidemia, diabetes mellitus, obesity, etcetera) and/or with pre-existing cardiovascular or cerebrovascular conditions. However, analysis of pooled Phase 3 safety data (by Standardised MedDRA Queries analysis and Antiplatelet Trialists' Collaboration event analysis) did not show an overall excess of cardio-cerebrovascular (CCV) events, either as a whole or with respect to specific events, for any dose of indacaterol compared with placebo or active comparators. This observation has been identified within the Product Monograph with inclusion of a Long-Acting Beta2-adrenergic Agonist (LABA) class labelling cautionary statement for the use of Onbrez Breezhaler in patients with cardiovascular disorders (coronary artery disease, acute myocardial infarction, cardiac arrhythmias and hypertension), in patients with convulsive disorders or thyrotoxicosis, and in patients who are unusually responsive to beta2-adrenergic agonists.

In Phase III clinical studies, during clinic visits on average 14-15% of patients experienced a sporadic cough that occurred usually within 15 seconds following inhalation of Onbrez Breezhaler and typically lasted for 5 seconds. There is no evidence that cough experienced post inhalation is associated with bronchospasm, exacerbations, and deteriorations of disease or loss of efficacy.

Onbrez Breezhaler is a LABA. Data from a large placebo-controlled study conducted in the United States in patients with asthma which compared the safety of a twice-daily administration of another LABA to that of a placebo, each added to usual asthma therapy, showed an increase in asthma-related deaths in patients receiving the LABA. The increased risk of asthma-related death may represent a class effect of all LABAs, including Onbrez Breezhaler. The safety and efficacy of Onbrez Breezhaler in patients with asthma has not been established; therefore Onbrez Breezhaler is not indicated for the treatment of asthma. However, the LABA class labeling, a serious boxed warning statement regarding the possible increased risk of asthma related death in patients using LABA, has been included in the Product Monograph of Onbrez Breezhaler in line with other LABA products currently marketed in Canada.

3.4 Benefit/Risk Assessment and Recommendation

3.4.1 Benefit/Risk Assessment

The review of the re-filed submission, which in addition to the controlled clinical studies included pooled analyses at 3-months and 6-months, (and 12-month, but not for the 75 mcg dose), as well as a modelling analysis of FEV1 data from various clinical studies, concluded that the data provided by the sponsor was adequate to support the efficacy and safety of the 75 mcg dose for the long-term, once-daily, maintenance bronchodilator treatment of airflow obstruction in patients with COPD, including chronic bronchitis and emphysema. However, the proposal of Onbrez Breezhaler 150 mcg dose as providing additional efficacy benefit over the 75 mcg dose in patients with more severe bronchial obstruction was not supported by the totality of the data. The safety profile of Onbrez Breezhaler is similar to other LABA. There are well-known safety concerns with LABAs, particularly at higher doses, such as the risk of dose-dependent increase of cardiovascular and cerebrovascular events, as well as the possible risk of asthma-related death if used in patients with asthma. These have been highlighted in the Product Monograph. A sporadic post-inhalation cough that occurred usually within 15 seconds following inhalation of Onbrez Breezhaler and typically lasted for 5 seconds has been identified during the clinical trials. It was not associated with bronchospasm, exacerbations, deteriorations of disease or loss of efficacy.

In conclusion, the overall risk/benefit assessment supports the market authorization of 75 mcg Onbrez Breezhaler for the proposed indication of long-term, once-daily, maintenance bronchodilator treatment of airflow obstruction in patients with COPD, including chronic bronchitis and emphysema. Onbrez Breezhaler 150 mcg dose was not recommended for approval at this time.

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 Onbrez Breezhaler is favourable for long-term, once-daily, maintenance bronchodilator treatment of airflow obstruction in patients with chronic obstructive pulmonary disease (COPD), including chronic bronchitis and emphysema. 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: Onbrez Breezhaler

Submission MilestoneDate
Pre-submission meeting:2008-07-09
Original Submission Number 127743
Submission filed:2009-02-10
Screening
Screening Acceptance Letter issued:2009-03-19
Review
Quality Evaluation complete:2010-01-08
Clinical Evaluation complete:2010-01-11
Biostatistics Evaluation complete:2009-12-23
Notice of Non-Compliance (NON) issued by Director General (safety, efficacy and quality issues):2010-01-13
Cancellation Letter (from Sponsor) received:2010-04-12
Re-filed, Submission Number 143984
Submission filed:2010-12-22
Screening
Screening Acceptance Letter issued:2011-02-11
Review
Quality Evaluation complete:2011-11-30
Clinical Evaluation complete:2011-12-02
Biostatistics Evaluation complete:2011-07-07
Labelling Review complete:2011-11-29
Notice of Compliance (NOC) issued by Director General:2011-12-06