Summary Basis of Decision for Onglyza ™

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
OnglyzaTM

Saxagliptin hydrochloride, 5 mg, Tablet, Oral

Bristol-Myers Squibb Canada

Submission control no: 123854

Date issued: 2010-06-10

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:

OnglyzaTM

Manufacturer/sponsor:

Bristol-Myers Squibb Canada

Medicinal ingredient:

Saxagliptin hydrochloride

International non-proprietary Name:

Saxagliptin hydrochloride

Strength:

mg

Dosage form:

Tablet

Route of administration:

Oral

Drug identification number(DIN):

  • 02333554

Therapeutic Classification:

Antihyperglycemic agent

Non-medicinal ingredients:

Core tablet: lactose monohydrate, microcrystalline cellulose, croscarmellose sodium, and magnesium stearate.

Film coating: polyvinyl alcohol, polyethylene glycol, titanium dioxide, talc, and iron oxides.

Printing ink: FD&C Blue #2 and shellac glaze.

Submission type and control no:

New Drug Submission, Control Number: 123854

Date of Submission:

2008-07-31

Date of authorization:

2009-09-14

ONGLYZA is a trade-mark of Bristol-Myers Squibb Company used under license by Bristol-Myers Squibb Canada

2 Notice of decision

On Sept. 14, 2009, Health Canada issued a Notice of Compliance to Bristol-Myers Squibb Canada for the drug product, Onglyza. Onglyza is being jointly developed by Bristol-Myers Squibb Canada and AstraZeneca Canada Inc.

Onglyza contains the medicinal ingredient saxagliptin, as saxagliptin hydrochloride. Onglyza is classified as an oral antihyperglycemic agent. Onglyza acts as a dipeptidyl peptidase 4 (DPP-4) inhibitor and thereby an incretin enhancer. The incretins, including glucagon-like peptide-1 (GLP-1) and glucose-dependent insulinotropic polypeptide (GIP), are part of an endogenous system involved in the physiologic regulation of glucose homeostasis. When blood glucose concentrations are elevated, GLP-1 and GIP increase insulin synthesis and its release from pancreatic beta cells. GLP-1 also lowers glucagon secretion from pancreatic alpha cells, leading to reduced hepatic glucose production.

Onglyza is indicated for patients with type 2 diabetes mellitus to improve glycemic control in combination with metformin or a sulfonylurea, when metformin or the sulfonylurea used alone, with diet and exercise, does not provide adequate glycemic control.

The market authorization was based on the review of quality, non-clinical, and clinical data submitted. Safety and efficacy were supported primarily from two 24-week Phase III, multicentre, randomized, double-blind, placebo-controlled studies. One study assessed the use of Onglyza in combination with metformin in type 2 diabetic patients with inadequate glycemic control on metformin alone. The second study assessed the use of Onglyza in combination with sulfonylurea in type 2 diabetic patients who had inadequate glycemic control on a sulfonylurea alone. In both studies, treatment with Onglyza 5 mg produced clinically relevant and statistically significant improvements in haemoglobin A1c, fasting plasma glucose, and postprandial glucose compared to control. Controlled, long-term extensions of these studies confirmed that the effect on haemoglobin A1c was sustained at week 50.

Onglyza (5 mg, saxagliptin, as saxagliptin hydrochloride) is presented in tablet form. The recommended dose of Onglyza is 5 mg once daily. Dosing guidelines are available in the Product Monograph.

Onglyza is contraindicated for patients with a history of serious hypersensitivity to any ingredient in the formulation or to another DPP-4 inhibitor. Onglyza 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 Onglyza 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 Onglyza is favourable for patients with type 2 diabetes mellitus to improve glycemic control in combination with metformin or a sulfonylurea, when metformin or the sulfonylurea used alone, with diet and exercise, does not provide adequate glycemic control.

3 Scientific and Regulatory Basis for Decision

3.1 Quality Basis for Decision

3.1.1 Drug Substance (Medicinal Ingredient)
General Information

Saxagliptin hydrochloride, the medicinal ingredient of Onglyza is an oral antihyperglycemic agent which selectively blocks the DPP-4 enzyme responsible for breaking down incretin hormones. Incretin hormones are known to contribute to the control of blood glucose through the endogenous system. As a result, by enhancing incretin levels (GLP-1 and GIP) Onglyza increases insulin secretion and decreases glucagon levels in a glucose-dependent fashion.

Manufacturing Process and Process Controls

The medicinal ingredient of Onglyza, as saxagliptin hydrochloride, is synthetically derived. In-process controls performed during manufacture were reviewed and are considered acceptable.

Characterization

The structure of saxagliptin monohydrate has been adequately elucidated and the representative spectra have been provided. Physical and chemical properties have been described and are found to be satisfactory.

Impurities and degradation products arising from manufacturing and/or storage were reported and characterized. These products were found to be within International Conference on Harmonisation (ICH)-established limits and are considered acceptable.

Control of Drug Substance

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

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, saxagliptin monohydrate is considered to be a stable compound when packaged as suggested over the proposed storage period.

3.1.2 Drug Product
Description and Composition

Onglyza 5 mg tablets contain approximately 5.95 mg of saxagliptin as the hydrochloride salt. The immediate release film-coated tablets are pink in color with a biconvex and round shape. Printed in blue ink is the number "5" on one side and "4215" on the other side. The 5 mg tablets are supplied in aluminum blister packs and packaged in cartons of 30 or 100.

Each film-coated tablet contains the following non-medicinal ingredients: lactose monohydrate, microcrystalline cellulose, croscarmellose sodium, and magnesium stearate. The tablet coating consists of polyvinyl alcohol, polyethylene glycol, titanium dioxide, talc, and iron oxides.

All non-medicinal ingredients found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations. The compatibility of saxagliptin hydrochloride with the non-medicinal ingredients is demonstrated by the stability data presented on the proposed commercial formulation.

Pharmaceutical Development

Pharmaceutical development data provided adequately supports the formulation and method of manufacturing specified.

Manufacturing Process and Process Controls

Although the drug product is an immediate release film coated tablet, it is manufactured using rather a unique procedure in which the core is non-functional and contains only inactive ingredients with a coating applied to the inert core that includes the active drug substance as a hydrochloride salt. The inert core tablets are manufactured using conventional ingredients along with a direct compression method. Saxagliptin is then embedded within a film coat of Opadry which is then spray-dried onto the inert core tablet. The process minimises active pharmaceutical ingredients contact with excipients and ensures product stability.

Control of Drug Product

Onglyza is tested using Professed Standards with specifications that conform to ICH requirements. Validation results of the analytical method used in manufacturing of saxagliptin hydrochloride were determined suitable for the intended use. Data from final batch analyses were also reviewed and complied with the proposed drug specifications. Impurities arising from manufacturing and/or storage were reported and characterized and are considered to be acceptable.

Stability

Based on long-term and accelerated stability data submitted, the proposed shelf-life and storage conditions of Onglyza is supported and considered to be satisfactory.

3.1.3 Facilities and Equipment

The design, operations and controls of the facility and equipment which are involved in the production of Onglyza are considered suitable for the activities and products manufactured. All of the proposed manufacturing sites comply with the requirements of Division 2 of the Food and Drug Regulations.

3.1.4 Adventitious Agents Safety Evaluation

The inactive ingredients lactose monohydrate and magnesium stearate are known to be derived from animal and vegetable origins, respectively. Letters of attestation confirming that these materials are not obtained from a bovine spongiform encephalopathy (BSE)/ transmissible spongiform encephalopathy (TSE)-affected country/area have been provided for this product indicating that it is considered to be safe for human use.

3.1.5 Conclusion

The Chemistry and Manufacturing information submitted for Onglyza 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 pharmacological studies have demonstrated that saxagliptin is a highly potent and reversible inhibitor of the DPP-4 enzyme. Evidence from in vitro studies demonstrated that saxagliptin is a more potent DPP-4 enzyme inhibitor than most other DPP-4 inhibitors belonging to the same class of compounds [that is (i.e.) sitagliptin and vildagliptin]. Saxagliptin also has more activity against the related enzymes, DPP-8 and DPP-9 compared to vildagliptin, with 400-fold selectivity for DPP-4 versus DPP-8 and 75-fold selectivity for DPP-4 versus DPP-9. By slowing the inactivation of incretin hormones, including GLP-1 which regulates blood glucose by multiple mechanisms, saxagliptin stimulates insulin secretion and inhibits glucagon secretion.

In vitro pharmacological studies also assessed whether saxagliptin (a DPP-4 inhibitor) may also be a potent inhibitor of T-cell activity, given DPP-4 cell surface markers are known to be identical to CD26 (T-cells surface markers). Cell model studies reviewed suggest that DPP-4 inhibitors were potent inhibitors of T-cell surface DPP activity, but had no effect in triggering immunosuppressive activity. Nonetheless, close attention should be paid to evaluate for any signs of immunosuppressive activity (i.e. increased susceptibility to infection) within clinical trials.

Safety pharmacological studies demonstrated saxagliptin was well-tolerated in rodents and dogs when chronically treated with doses higher than the recommended therapeutic dose. No adverse effects were noted on cardiovascular system, respiratory system and the central nervous system.

3.2.2 Pharmacokinetics
Absorption

In rats, dogs, and monkeys, saxagliptin was rapidly absorbed after a single-dose oral administration. Bioavailability following the single-dose administration ranged from 51% to 76% in all three species.

Distribution

Radioactive experiments showed that saxagliptin distributes extensively throughout the body with highest concentrations in the gastrointestinal tract, liver, urinary bladder, and kidney. Plasma protein binding of saxagliptin was very low in mouse, rat, dog, monkey, and human serums with a free fraction of approximately ≥70%.

In pregnant rats, saxagliptin did cross the placental barrier and distributed widely in foetal tissues. Saxagliptin also appeared in the milk of lactating rats.

Metabolism

Studies conducted in rats, dogs, and monkeys showed saxagliptin and its active metabolite, 5-hydroxy saxagliptin, were the most prominent drug-related components in the plasma when assessed at various time intervals post-drug administration. In animals, the major enzyme responsible for metabolizing saxagliptin to 5-hydroxy saxagliptin was the cytochrome P450 (CYP) 3A4/3A5 (CYP3A4/5) enzyme. This suggests that co-administered drugs that either inhibit or induce the CYP3A4/5 enzyme may also increase or decrease exposure to saxagliptin.

Excretion

Saxagliptin is eliminated by both hepatic and renal pathways. Radioactive studies across species demonstrated that direct excretion and its metabolism to form 5-hydroxysaxagliptin were the major clearance pathways for saxagliptin. Of the 75% of the dose excreted in human urine, 24% was saxagliptin and 36% was 5-hydroxysaxagliptin. Of the 22% of the dose excreted in faeces, <1% was saxagliptin and 8% was 5-hydroxysaxagliptin.

3.2.3 Toxicology

All pivotal toxicity studies supporting the safety of saxagliptin were appropriately designed and conducted in compliance with ICH guidelines and Good Laboratory Practices (GLP) regulations.

Single-Dose Toxicity

Saxagliptin had a relatively low acute toxicity with a minimal lethal dose of approximately 4000 mg/kg in both mice and rats. A single 50 mg/kg dose of saxagliptin is considered to be the lethal dose in monkeys

Repeat-Dose Toxicity

Saxagliptin was well-tolerated in rodents and dogs when treated chronically with doses that were high multiples of the recommended human dose of 5 mg/day. The most significant toxicity finding was observed in a 3-month study with monkeys who were administered 3 mg/kg/day of saxagliptin (representing 20 to 28 times over the recommended human dose). The findings showed the development of skin lesions, characterized as scabs, erosions and ulcerations occurring mainly on the extremities. These skin lesions were not observed at lower doses in monkeys. Similar, lesions have not been associated with saxagliptin in human clinical trials.

Genotoxicity

There is no evidence to suggest that saxagliptin has the potential to cause in vivo genotoxicity. In a battery of in vitro and in vivo tests, saxagliptin was not genotoxic.

Carcinogenicity

The carcinogenicity studies conducted in mice and rats have provided adequate evidence that saxagliptin has no or limited carcinogenic potential.

Reproductive and Developmental Toxicity

Reproductive toxicity studies conducted in rats and rabbits have indicated that saxagliptin has limited potential to cause infertility or developmental effects. Although saxagliptin demonstrated limited potential for teratogenic activity in pregnant rats, its potential to cause embryo-foetal developmental effects in humans cannot be ascertained in absence of clinical data. Therefore, saxagliptin should not be used in women during pregnancy. Similarly, it is not recommended to be used in lactating women, as saxagliptin is expected to pass through the mother's milk.

Local Tolerance

Local tolerance studies provided adequate evidence that saxagliptin has no or limited potential to induce skin hypersensitivity and it is not irritating to the skin or to the eyes.

3.2.4 Summary and Conclusion

The non-clinical profile of saxagliptin was established in a comprehensive investigational program that included studies of in vitro and in vivo pharmacodynamics, safety pharmacology, pharmacokinetics, and toxicity and toxicokinetics. Where applicable, non-clinical data for saxagliptin was also compared to other currently known DPP-4 inhibitors developed for the treatment of type 2 diabetes mellitus.

Overall, based on non-clinical studies, there are no major safety concerns that would predict unexpected adverse effects in patients treated with saxagliptin at the recommended therapeutic dose. Thus, from the perspective of the non-clinical studies saxagliptin is recommended for approval of use in humans.

3.3 Clinical basis for decision

3.3.1 Pharmacodynamics

In patients with type 2 diabetes, administration of saxagliptin led to a dose-dependent inhibition response of DPP-4 enzyme activity for a 24-hour period. After an oral glucose load, this DPP-4 inhibition resulted in a 2- to 3-fold increase in circulating levels of active GLP-1.

The pharmacodynamic data showed that 24 weeks of saxagliptin treatment increased postprandial insulin and C-peptide and decreased post-prandial glucagon concentrations in the treated patients. These changes in insulin and glucagon levels may lead to lower hemoglobin A1c and lower fasting and post-prandial glucose concentrations.

3.3.2 Pharmacokinetics
Absorption

Saxagliptin is absorbed after oral administration, with maximum plasma concentrations attained within 2 hours after dosing. Plasma exposure for saxagliptin and its active metabolite increased in proportion with the saxagliptin dose. No accumulation was observed upon repeated once-daily dosing at any dose up to 400 mg. No dose- and time-dependency was observed in saxagliptin clearance over 14 days of once-daily dosing with saxagliptin at doses ranging from 2.5 to 400 mg. Food had modest effect on saxagliptin pharmacokinetics. Grapefruit juice however, being a weak inhibitor of CYP3A4 gut wall metabolism may increase plasma levels of saxagliptin.

Results of a bioavailability study conducted with the Onglyza 10 mg tablet indicated that the rate of absorption (Cmax) of Onglyza is similar in the presence of food, but the extent of exposure (AUC) is increased approximately 26% following a high-fat meal. A bioequivalence waiver was granted for the 5 mg tablet formulation proposed for market given these tablets are considered to be proportionally formulated to the 10 mg clinical trial tablets.

Distribution

In vitro serum studies demonstrated saxagliptin and its major metabolite BMS-510849 do not bind to plasma proteins. This observation was further confirmed by a mass balance study. This suggests that saxagliptin and its related compounds are not retained in the body to a substantial extent.

Metabolism

Saxagliptin is metabolized primarily by the CYP3A4/5 enzyme to an active metabolite, 5-hydroxy saxagliptin. This active metabolite was also demonstrated to be a reversible, selective, competitive DPP-4 inhibitor. Systemic exposure values for the metabolite were between 2- and 7-times higher than those of saxagliptin. Saxagliptin is metabolized by the CYP3A4/5 enzyme and co-administered drugs that either inhibit or induce the CYP3A4/5 enzyme may increase or decrease the human exposure to saxagliptin.

Excretion

Mass balance and metabolic profiling data showed that saxagliptin is eliminated by both metabolic and renal pathways. Renal excretion is the primary elimination pathway for saxagliptin and its active metabolite. Based on the renal clearance values, saxagliptin renal elimination occurs by a combination of glomerular filtration and net tubular secretion, whereas the active metabolite appears to be only filtered.

Drug-Drug Interactions

Saxagliptin and its active metabolite neither inhibited CYP1A2, 2A6, 2B6, 2C9, 2C19, 2D6, 2E1, or 3A4, nor induced CYP1A2, 2B6, 2C9, or 3A4 in vitro. Therefore, saxagliptin and its major metabolite are unlikely to alter the metabolic clearance of co-administered drugs that are metabolized by these enzymes.

The pharmacokinetics of saxagliptin and its active metabolite were noted as not meaningfully altered by co-administration of the following drugs: metformin, glyburide, pioglitazone, digoxin, simvastatin, diltiazem, omeprazole, Malox max (aluminum hydroxide + magnesium hydroxide + simethicone) and famotidine. As well, the pharmacokinetics of the co-administered drugs (i.e. metformin, glyburide, pioglitazone, digoxin, simvastatin, diltiazem and ketoconazole) demonstrated to be not meaningfully altered by saxagliptin.

Special Populations

Age, Gender, Race and Obesity
Gender, race and obesity had no clinical relevance on Onglyza pharmacokinetics. Elderly subjects had 23% and 59% higher Cmax and AUC values. Given geriatric patients are also more likely to have decreased renal function care should be taken when prescribing Onglyza within this population. The assessment of renal functions prior to administration of Onglyza and periodically thereafter is recommended.

Studies were not performed in the pediatric population. The use in this population is not recommended.

Renal Impairment
Given Onglyza is excreted through renal pathways, renal function plays an important role in the pharmacokinetics of Onglyza. Patients with moderate, severe, or with end-stage renal disease on dialysis had approximately a 2.1-fold higher plasma drug exposure compared to subjects with normal renal function following a single 10 mg dose of Onglyza. Clinical study experience with Onglyza in patients with moderate or severe renal insufficiency is limited; therefore, use of Onglyza in moderate or severe renal impaired patients is not recommended.

Hepatic Impairment
In patients with hepatic impairment (Child-Pugh classes A, B, and C) following administration of a single 10 mg dose of Onglyza, there were higher AUC values for Onglyza with increasing severity of hepatic impairment indicating a reduced capacity to metabolize Onglyza as hepatic function declines. There are limited clinical data in patients with hepatic impairment; therefore, use of Onglyza in moderate to severe hepatic impairment is not recommended. 

Congestive Heart Failure
Due to limited data in patients with congestive heart failure, Onglyza isnot recommended for use in this population.

3.3.3 Clinical Efficacy

Safety and efficacy were supported primarily from two 24-week Phase III, multicentre, randomized, double-blind, placebo-controlled studies, CV181014 and CV181040, and will hereafter be known by their abbrs, STUDY 1 and STUDY 2, respectively. STUDY 1 assessed the use of Onglyza in combination with metformin in type 2 diabetic patients with inadequate glycemic control on metformin alone. STUDY 2 assessed the use of Onglyza in combination with a sulfonylurea in type 2 diabetic patients who had inadequate glycemic control on a sulfonylurea alone. In both studies, treatment with Onglyza 5 mg produced clinically relevant and statistically significant improvements in haemoglobin A1c (HbA1c), fasting plasma glucose, and post-prandial glucose compared to the control group.

Add-On Combination Therapy with Metformin
STUDY 1 was a pivotal multicentre, randomized, double-blind, placebo-controlled, Phase III Study evaluating the efficacy and safety of Onglyza in combination with metformin in subjects with type 2 diabetes who had inadequate glycemic control on metformin alone. The clinical study enrolled 743 patients (191 received Onglyza 5 mg) with primary efficacy evaluated by the reduction in HbA1c at 24-weeks. Patients who met entrance criteria were enrolled in a single-blind, two-week, dietary and exercise placebo lead-in period during which patients received metformin at their pre-study dose, up to 2500 mg daily for the duration of the study. Following the lead-in period, eligible patients were randomized to 2.5 mg, 5 mg, or 10 mg of Onglyza or placebo in addition to their current dose of open-label metformin. Patients who failed to meet specific glycemic goals during the study were treated with pioglitazone rescue therapy, added on to placebo or Onglyza plus metformin. Dose titrations of Onglyza and metformin were not allowed in this study. The results demonstrated that in patients already taking metformin, the addition of 5 mg Onglyza reduced the HbA1c baseline mean by -0.83% after 24-weeks of treatment as compared to metformin alone. A long-term extension period followed the 24-week study period for patients who met eligibility. Results from the long-term study showed that the reduction from baseline in HbA1c was upheld at every time-point measured thereafter up to 102-weeks of treatment at which point the placebo-adjusted reduction was -0.72%.

Support for the primary efficacy analysis was further demonstrated through review of the secondary efficacy endpoints which included the following:

  • Change from baseline in fasting plasma glucose;
  • Proportion of patients achieving a therapeutic glycemic response defined as HbA1c <7.0%;
  • Change from baseline in the area under the curve (AUC) from 0 to 180 minutes for post-prandial glucose response to an oral glucose tolerance test.

Add-On Combination Therapy with a Sulfonylurea
STUDY 2 was a pivotal multicentre, randomized, double-blind, placebo-controlled, Phase III Study with 768 patients (253 received Onglyza 5 mg) evaluating the efficacy and safety of Onglyza in combination with a sulfonylurea (glyburide) in patients with type 2 diabetes who have inadequate glycemic control on glyburide alone (up-titrated to near maximal dose). The primary efficacy endpoint was the reduction in HbA1c at 24-weeks. Patients who met entrance criteria were enrolled in a single-blind, 4-week, dietary and exercise lead-in period and placed on glyburide 7.5 mg once daily. Following the lead-in period, eligible patients with HbA1c ≥ 7% to ≤ 10% were randomized to either 2.5 mg or 5 mg of Onglyza plus 7.5 mg glyburide, or placebo plus a 10 mg total daily dose of glyburide. Patients who received placebo were eligible to have glyburide up-titrated in blinded fashion to a total daily dose of 15 mg. Up titration of glyburide was not allowed in patients who received Onglyza 2.5 or 5 mg. Glyburide could be down-titrated in any treatment group once during the 24-week study period due to hypoglycemia as deemed necessary by the investigator. Approximately 92% of patients in the placebo plus glyburide group were up-titrated to a final total daily dose of 15 mg during the study period. Patients who failed to meet specific glycemic goals during the study were treated with metformin rescue, added on to the Onglyza plus glyburide or the placebo plus up-titrated glyburide group. Dose titration of Onglyza was not permitted during the study. The results demonstrated that in patients already taking a sulfonlyurea, the addition of 5 mg Onglyza reduced the HbA1c baseline mean by -0.72% after 24-weeks on treatment, compared to up-titrated glyburide alone. Data for a long-term extension period of 50 weeks from baseline showed that the reduction from baseline in HbA1c was upheld with a placebo-adjusted HbA1c reduction of -0.63%.

The primary efficacy results were also supported by fasting plasma glucose at Weeks 24 and 50, responder analysis (subjects achieving <7% A1c) at Week 24 and 50, postprandial glucose AUC (Week 24), and 120 minute postprandial glucose (Week 24).

3.3.4 Clinical Safety

The clinical safety of Onglyza as an add-on combination therapy with either metformin or a sulfonylurea was primarily evaluated in the two studies (STUDY 1 and STUDY 2) described in the 3.3.4 Clinical Efficacy section. However, a non-pivotal study CV181039 (hereafter known as STUDY 3) was also reviewed for pertinent safety information regarding the combination of Onglyza and metformin, but it is considered non-pivotal given it was conducted in a healthier sample of diabetic patients (i.e. drug naïve). The non-pivotal study provided data on 320 patients taking Onglyza 5 mg plus metformin for up to 50 weeks. Additional safety information was obtained in 323 patients taking Onglyza 10 mg plus metformin.

The safety results from STUDY 1 and STUDY 3 did not reveal any serious concerns or trends inconsistent with the DPP-IV class. There were four deaths among subjects taking Onglyza when combining outcome results from both studies. These deaths were as follows: pulmonary embolism/pulmonary neoplasm (Onglyza 10 mg with metformin), tetanus (Onglyza 5 mg with metformin), sudden death- bundle branch block (Onglyza 10 mg with metformin), and coronary artery disease (Onglyza 10 mg monotherapy).

In both STUDY 1 and STUDY 3, there were slightly more Serious Adverse Events (SAEs) reported in the Onglyza/metformin group compared to the placebo/metformin group. Specifically in STUDY 1, over a two-year period, 9.9% of patients in the Onglyza 5 mg plus metformin group experienced SAEs in comparison to 5.6% of patients in the placebo/metformin group. In addition, STUDY 3 found that there were slightly more Onglyza 5 mg plus metformin patients with SAEs (3.8%) compared to the placebo/metformin patients (3%). However, neither trial showed any particular trends of specific SAEs for Onglyza/metformin subjects.

Although the overall incidence of adverse events (AEs) in the Onglyza/metformin group was quite similar to the placebo/metformin group, infections provided the highest number of AEs for both STUDY 1 (51.8% Onglyza 5 mg plus metformin versus 52.5% placebo/metformin) and STUDY 3 (25.3% Onglyza 5 mg plus metformin versus 27.1% placebo/metformin). The most common AE infections reported included: nasopharyngitis, upper respiratory tract infection, urinary tract infection, bronchitis, and gastroenteritis.

In STUDY 2, safety findings also showed slightly more adverse events among Onglyza/glyburide patients' compared to the placebo/glyburide patients notably with infections (urinary tract infection and pharyngitis), hypertension, hypoglycaemia, hypertriglyceridemia, and increased creatine kinase. Among patients taking Onglyza/glyburide, there was one death (myocardial infarct) in a patient taking Onglyza 5 mg plus glyburide. The death was attributed to atrioventricular block and cardiogenic shock and considered by the investigator to be unrelated to Onglyza.

There were no obvious trends observed among the SAEs. There were three SAEs considered by the investigator to be related to study treatment. These events, all in Onglyza subjects, were coronary artery disease, hypoglycemia, and thrombocytopenia consistent with a diagnosis of idiopathic thrombocytopenia purpura observed in the clinical program. The relationship of this event to Onglyza is not known.

There were also slightly more discontinuations due to AEs among the Onglyza/glyburide patients as compared to the placebo/glyburide patients, but there were no specific trends observed.

3.4 Benefit/Risk Assessment and Recommendation

3.4.1 Benefit/Risk Assessment

Overall, Onglyza in combination with either a metformin or a sulfonylurea provided glycemic control in adult patients with type 2 diabetes mellitus when metformin or the sulfonylurea alone did not provide adequate glycemic control. These results were also supported by several secondary efficacy endpoints demonstrating favorable results.Furthermore, the glucose-lowering efficacy was maintained throughout long-term studies.

The safety findings showed a slight increase in AEs in the Onglyza patients compared to the placebo/metformin or placebo/glyburide patients for infections, anemia, lymphopenia, thrombocytopenia, increased creatine kinase, gastrointestinal and skin-related adverse events (with no cases indicative of the serious skin lesions found in non-clinical monkey studies). The benefits in terms of glycemic control provided when Onglyza 5 mg is used in combination with either a metformin or a sulfonylurea outweigh the risks of these adverse events.

The review of this drug submission did not yield specific safety concerns however, given the anticipated wide and chronic use of Onglyza, as well as the known and potential risks of the drug; Health Canada has requested the applicant to voluntarily submit a Risk Management Plan as a means of enabling further pharmcovigilance monitoring. Provision of this update by the applicant will be reviewed by Health Canada.

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 Onglyza is favourable in the treatment of patients with type 2 diabetes mellitus to improve glycemic control when metformin or a sulfonylurea alone, with diet and exercise, does not provide adequate glycemic control. 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: OnglyzaTM

Submission MilestoneDate
Pre-submission meeting:2006-06-12
Pre-submission meeting:2008-05-15
Pre-submission meeting:2008-06-03
Submission filed:2008-07-31
Screening
Screening Deficiency Notice issued:2008-09-19
Response filed:2008-10-06
Screening Acceptance Letter issued:2008-11-18
Review
Biostatistics Evaluation complete:2009-08-27
Quality Evaluation complete:2009-09-14
Clinical Evaluation complete:2009-09-11
Biostatistics Evaluation complete:2009-05-07
Labelling Review complete:2009-09-14
Notice of Compliance (NOC) issued by Director General:2009-09-14