Summary Basis of Decision for Sprycel
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:
Sprycel
Dasatinib (as monohydrate), 20 mg, 50 mg, and 70 mg, Tablets, Oral
Bristol-Myers Squibb Canada
Submission control no: 104993
Date issued: 2007-08-07
Health Products and Food Branch
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Health Products and Food Branch
Également disponible en français sous le titre : Sommaire des motifs de décision (SMD), PrSPRYCEL*, dasatinib, comprimés de 20 mg, 50 mg et 70 mg, Bristol-Myers Squibb Canada, No de contrôle de la présentation 104993
Foreword
Health Canada's Summary Basis of Decision (SBD) documents outline the scientific and regulatory considerations that factor into Health Canada regulatory decisions related to drugs and medical devices. SBDs are written in technical language for stakeholders interested in product-specific Health Canada decisions, and are a direct reflection of observations detailed within the evaluation reports. As such, SBDs are intended to complement and not duplicate information provided within the Product Monograph.
Readers are encouraged to consult the 'Reader's Guide to the Summary Basis of Decision - Drugs' to assist with interpretation of terms and acronyms referred to herein. In addition, a brief overview of the drug submission review process is provided in the Fact Sheet entitled 'How Drugs are Reviewed in Canada'. This Fact Sheet describes the factors considered by Health Canada during the review and authorization process of a drug submission. Readers should also consult the 'Summary Basis of Decision Initiative - Frequently Asked Questions' document.
The SBD reflects the information available to Health Canada regulators at the time a decision has been rendered. Subsequent submissions reviewed for additional uses will not be captured under Phase I of the SBD implementation strategy. For up-to-date information on a particular product, readers should refer to the most recent Product Monograph for a product. Health Canada provides information related to post-market warnings or advisories as a result of adverse events (AE).
For further information on a particular product, readers may also access websites of other regulatory jurisdictions. The information received in support of a Canadian drug submission may not be identical to that received by other jurisdictions.
Other Policies and Guidance
Readers should consult the Health Canada website for other drug policies and guidance documents. In particular, readers may wish to refer to the 'Management of Drug Submissions Guidance'.
1 Product and submission information
Brand name:
Manufacturer/sponsor:
Medicinal ingredient:
International non-proprietary Name:
Strength:
Dosage form:
Route of administration:
Drug identification number(DIN):
- 02293129 20 mg/tablet
- 02293137 50 mg/tablet
- 02293145 70 mg/tablet
Therapeutic Classification:
Non-medicinal ingredients:
Film-coating: hypromellose, titanium dioxide, polyethylene glycol
Submission type and control no:
Date of Submission:
Date of authorization:
* ™ of Bristol-Myers Squibb Company
used under license by Bristol-Myers Squibb Canada
2 Notice of decision
On March 26, 2007, Health Canada issued a Notice of Compliance under the Notice of Compliance with Conditions (NOC/c) Policy to Bristol-Myers Squibb Canada for the drug product Sprycel. The product was authorized under the NOC/c Policy on the basis of the promising nature of the clinical evidence, and the need for confirmatory studies to verify the clinical benefit. Patients should be advised of the fact that the market authorization was issued with conditions.
Sprycel contains the medicinal ingredient dasatinib which is a protein-tyrosine kinase inhibitor.
Sprycel is indicated for the treatment of adults with chronic, accelerated, or blast phase chronic myeloid leukemia (CML) with resistance or intolerance to prior therapy including imatinib mesylate. Dasatinib inhibits the activities of the proteins BCR-ABL kinase and the SRC family kinases (LYN, HCK), along with a number of other kinases. By inhibiting these proteins, Sprycel prevents the growth and survival of the leukemia cells.
The market authorization was based on submitted data from quality (chemistry and manufacturing) studies, as well as data from non-clinical and clinical studies. The efficacy and safety were studied in six clinical studies (one Phase I and five Phase II studies). The results of the studies show promising evidence of clinical effectiveness based on the rates of hematologic and cytogenetic responses, and an acceptable safety profile. Duration of follow-up was limited. There were no controlled trials demonstrating a clinical benefit, such as improvement in disease-related symptoms or increased survival.
Sprycel [20 mg, 50 mg, and 70 mg dasatinib (as monohydrate)] is presented in tablet form. The recommended dosage of Sprycel is 140 mg/day administered orally in two divided doses (70 mg twice a day), one in the morning and one in the evening with or without food. Dosing guidelines are available in the Product Monograph.
Sprycel is contraindicated for patients with hypersensitivity to dasatinib or to any other component of Sprycel. Sprycel 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 Sprycel are described in the Product Monograph.
Based on the Health Canada review of data on quality, safety, and effectiveness, Health Canada considers that the benefit/risk profile of Sprycel is favourable for the treatment of adults with chronic, accelerated, or blast phase CML with resistance or intolerance to prior therapy including imatinib mesylate.
3 Scientific and Regulatory Basis for Decision
3.1 Quality Basis for Decision
3.1.1 Drug Substance (Medicinal Ingredient)
General Information
Dasatinib (as Dasatinib monohydrate), the medicinal ingredient of Sprycel, is a protein-tyrosine kinase inhibitor. Dasatinib inhibits the activities of the proteins BCR-ABL kinase and the SRC family kinases (LYN, HCK), along with a number of other kinases. By inhibiting these proteins, Sprycel prevents the growth and survival of leukemia cells in patients with CML.
Manufacturing Process and Process Controls
Dasatinib is synthetically derived. Materials used in the manufacture of the drug are considered to be suitable and/or meet standards appropriate for their intended use. The manufacturing process is considered to be adequately controlled within justified limits.
Characterisation
The structure of dasatinib has been adequately elucidated and the representative spectra have been provided.
Impurities arising from manufacturing were reported and characterized. These products were found to be within ICH recommended limits or were qualified through toxicological studies and are therefore considered to be acceptable.
Control of Drug Substance
Copies of the analytical methods and, where appropriate, validation reports are considered satisfactory for all analytical procedures used for release and stability testing of dasatinib.
The specifications are considered acceptable for the drug substance. Batch analysis results were reviewed and were within the proposed specification acceptance criteria.
The drug substance packaging is considered to be acceptable.
Stability
Based on real-time and accelerated stability study data, the suggested shelf-life and storage conditions for dasatinib are supported and considered to be acceptable.
3.1.2 Drug Product
Description and Composition
Sprycel immediate release film-coated tablets in strengths of 20 mg, 50 mg, and 70 mg dasatinib (as dasatinib monohydrate) contain the following non-medicinal ingredients for the tablet core: croscarmellose sodium, hydroxypropyl cellulose, lactose monohydrate, magnesium stearate and microcrystalline cellulose. The film-coating contains hypromellose, polyethylene glycol and titanium dioxide.
- Sprycel 20 mg tablets are white to off-white, biconvex, round, film-coated tablets with "BMS" debossed on one side and "527" on the other side.
- Sprycel 50 mg tablets are white to off-white, biconvex, oval, film-coated tablets with "BMS" debossed on one side and "528" on the other side.
Sprycel 70 mg tablets are white to off-white, biconvex, round, film-coated tablets with "BMS" debossed on one side and "524" on the other side.
- Sprycel tablets are supplied in high-density polyethylene bottles with child-resistant closures containing a cotton coiler and one silica gel desiccant canister. The tablets are also packaged in blister packages.
All of the non-medicinal ingredients found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations. The compatibility of dasatinib with these ingredients are demonstrated by the stability data presented on the proposed commercial formulation.
Pharmaceutical Development
Changes to the manufacturing process and formulation made throughout the development are considered acceptable upon review.
Manufacturing Process and Process Controls
The tablets are manufactured using standard pharmaceutical procedures that include wet granulation, drying, milling, blending, compression, coating, and packaging. The specifications for all the ingredients are either approved in accordance with USP/NF or Ph. Eur. standards.
All manufacturing equipment, in-process manufacturing steps, and detailed operating parameters were adequately described in the submitted documentation and are found to be acceptable. The manufacturing process is considered to be adequately controlled within justified limits.
Control of Drug Product
Sprycel is tested to verify that the identity, appearance, content uniformity, dissolution, and the levels of degradation products and microbiological impurities are within 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 considered to be acceptable based on ICH recommendations and the clinical/toxicology data.
Copies of the analytical methods and, where appropriate, validation reports are considered satisfactory for all analytical procedures used for release and stability testing of Sprycel. Data from final batch analyses were reviewed and are considered to be acceptable according to the specifications of the drug product.
Stability
Based upon the long-term and accelerated stability study data submitted, the proposed shelf-life of 24 months is considered acceptable when Sprycel tablets are packaged in the commercial container closure system and stored between 15 and 30°C.
The compatibility of the drug product with the container closure system was demonstrated through compendial testing and stability studies.
3.1.3 Facilities and Equipment
The design, operations and controls of the facility and equipment that are involved in the production are considered suitable for the activities and products manufactured. All of the proposed manufacturing sites comply with the requirements of Division 2 of the Food and Drug Regulations.
All sites are rated Good Manufacturing Practices (GMP) compliant for the associated manufacturing activities.
3.1.4 Adventitious Agents Safety Evaluation
N/A
3.1.5 Summary and Conclusion
The Chemistry and Manufacturing information submitted for Sprycel 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
CML is a progressing bone marrow malignancy characterized by overproduction of granulocytes from bone marrow stem cells. Over expression or activation of oncogenic kinases, including BCR-ABL and SRC family kinases along with other oncogenic kinases such as c-KIT, ephrin (EPH) receptor kinases, and PDGFβ receptors, play critical roles in the etiology of various cancer types and in malignant characteristics such as unregulated proliferation and metastasis.
3.2.1 Pharmacodynamics
The in vitro and in vivo pharmacodynamic studies demonstrated that dasatinib inhibits the activity of the BCR-ABL and SRC family kinases, as well as a number of other kinases including c-KIT, EPH receptor kinases, and PDGFβ receptors. The in vitro studies showed that dasatinib inhibited proliferation of imatinib-sensitive and imatinib-resistant CML cell lines, with mechanisms of resistance derived from over-expression of FYN, LYN, PGP efflux pump, or BCR-ABL mutations (except T315I). Dasatinib was also effective in inhibiting the growth of two imatinib-sensitive and one imatinib-resistant cell lines in mice xenograft models.
Safety pharmacology studies demonstrated that dasatinib had no specific affinities for other receptor/ion channels tested in the in vitro ligand binding studies. However, dasatinib was positive in the hERG/IKr and Purkinje fiber assays, suggesting potential effects on QT prolongation. In an in vivo study, single doses of 10 mg/kg dasatinib
administered to six conscious monkeys increased mean QTc intervals 16-19 msec between 1.5-2.5 hours post dose in the treatment cohort compared to the vehicle control, and increased systolic blood pressure (6-15%) and diastolic blood pressure (8-21%) for two hours following dosing.
3.2.2 Pharmacokinetics
Absorption
Dasatinib was rapidly absorbed following oral administration to mice, rats, dogs and monkeys, with the oral bioavailability ranging from 14-34%. In rats and monkeys, the systemic exposure of dasatinib was dose related, with no apparent gender difference.
The dasatinib solubility in an aqueous solution is highly pH dependent which potentially affects absorption of the drug due to limited solubility at certain pH levels in the gastrointestinal (GI) tract.
Distribution
Dasatinib was highly bound (>91%) to plasma proteins in mice, rats, dogs, and monkeys. The steady state volume of distribution of dasatinib in all species was greater than the volume of total body water suggesting extravascular distribution of the drug. The drug was widely distributed to the various tissues and organs, with the largest concentrations in the GI tract and liver.
Metabolism
Dasatinib was extensively metabolized in rats and monkeys. The identified metabolites were products of hydroxylation, N-oxidation, N-dealkylation, oxidation to form a carboxylic acid, glucuronidation, and sulfation. Unchanged dasatinib was the most abundant drug-related component in the plasma.
The primary oxidative metabolites were mainly generated by CYP3A4 in vitro.
Dasatinib did not induce CYP1A2, CYP2B6, CYP2C9, or CYP3A4 in primary human hepatocyte cultures at concentrations up to 25 µM. The potential for dasatinib to cause increased clearance of drugs that are metabolized by these enzymes is minimal.
Excretion
After oral administration of radiolabelled dasatinib to rats and monkeys, drug-derived radioactivity was recovered primarily in the feces with only a small portion of the dose excreted in the urine. Only a small fraction of the unchanged parent drug was detected in the bile and urine, suggesting that metabolism plays a major role in the elimination of dasatinib in these species.
3.2.3 Toxicology
Single-dose and repeat-dose toxicology studies were conducted in rats, rabbits, monkeys and dogs. All pivotal studies were conducted in compliance with Good Laboratory Practice regulations.
Acute Toxicity
In single-dose studies in rats and monkeys, the major acute toxicity findings that attributed to mortality were GI toxicity, bone marrow and lymphoid depletion, and multifocal myocardial necrosis (in rats only) and hemorrhage. The drug exposure was 7x the human exposure at the therapeutic dose when 100% mortality occurred in monkeys, which was attributed to GI toxicity (hemorrhage, and fluid and electrolyte losses) and suppression of the immune system due to tissue lymphoid depletion. Other major clinical findings included hypothermia, hemorrhages at numerous sites including thorax, limbs, gingiva, head, neck, and retina. In addition, in the single-dose toxicity study in monkeys, there was a trend of QTc interval increases (mean QTc interval 5.3-18.8 msec for doses 15-45 mg/kg) in treated animals within two hours following dasatinib administration.
Long-Term Toxicity
Repeated-dose studies were conducted from two weeks to six months in rats and from ten days to nine months in monkeys. One study conducted in dogs was terminated within two days due to excessive GI toxicity. Doses were generally reduced in the longer studies.
Hematological and serum chemistry changes were similar in both species, and consisted of decreases in hemoglobin, red blood cells, lymphocyte counts, total protein, albumin, alkaline phosphatase, phosphorus, and calcium, and increases in alanine transaminase, aspartate aminotrasferase, and urea nitrogen.
In the 2-week exploratory study in rats, 100% mortality occurred between days 8-12 at a systemic exposure 13x the human exposure at the therapeutic dose. Decreases in absolute number of splenic T-cells and B-cells, and T-cell dependent antibody response to Keyhole Limpet Hemocyanin (KLH) were observed. This suggested a reduced immune response. In the 1-month rat study, mortality (43%) occurred at 4x the expected human exposure. In the 6-month rat study, 30% mortality occurred at 2.8x the expected human exposure, during weeks 3-22. The most common finding was fluid in the thoracic cavity for animals found dead or sacrificed in a moribund condition before scheduled study termination. Fluid in the pleural cavity was not observed in surviving animals that were administered dasatinib for the entire 6-month period.
In the 10-day exploratory study in monkeys, mortality (75%) occurred in animals with systemic exposure >5x that of humans. In the 9-month monkey study, 50% unscheduled euthanation and death occurred in monkeys at only half of the human drug exposure level, from 5 to 9 months; and 100% (before 6 months) at an exposure 2.6x the expected clinical exposure level.
Carcinogenicity
The carcinogenic potential of dasatinib was not studied.
Genotoxicity
In vitro, dasatinib was clastogenic to dividing Chinese hamster ovary cells, with and without metabolic activation, at concentrations ≥5 μg/mL.
Reproductive Toxicity
Reproductive toxicology studies were conducted in rats and rabbits and clearly showed that dasatinib is fetotoxic. In the embryo/fetal developmental study, embryo lethality occurred at doses that did not cause maternal toxicity in rats. Pathology findings in fetuses included misshapen clavicles, bent radius and femur, wavy or nodulated ribs, reduced ossification of the thoracic, lumbar, and sacral and forepaw phalanges, fluid-filled thoracic and abdominal cavities, edema, and microhepatia (small liver).
In a dose-finding rabbit study, groups that were administered doses of 6 and 10 mg/kg dasatinib had reduced numbers of live fetuses. Reduced litter sizes were observed at all doses.
Other Toxicity Studies
Other toxicity studies showed that dasatinib inhibited splenic T-cell proliferation and graft rejection. In addition, dasatinib inhibited platelet function both in vitro and in vivo. The latter effect is crucial because it indicates that dasatinib not only reduced platelet counts by causing bone-marrow depletion, but also affected platelet function.
3.2.4 Summary and Conclusion
Sprycel (dastanib) displayed strong inhibitory effects on the SRC family kinases, and the other kinases including BCR-ABL, c-KIT, EPH, and PDGFβ receptors. Inhibiting growth was seen in imatinib-sensitive and imatinib-resistant CML cell lines, as well as other CML cell lines. Dasatinib was also effective in inhibiting cell lines harbouring 14 mutations of BCR-ABL, with the one exception of mutation T315I.
Induced toxicities were primarily observed in the GI tract, lymphoid system and bone marrow, with hematological and biochemical manifestations. Dasatinib was also shown to affect T-cell proliferation, which can potentially weaken the immune system. Dasatinib demonstrated fetal toxicity, and therefore should not be administered to pregnant women. Life-threatening toxicity was observed in a 9-month monkey study with 50% mortality reported in monkeys at only half of the clinical exposure level. Therefore, the safety of human exposure ≥6 months should be closely monitored for potential fatal adverse drug reactions.
Based on the non-clinical pharmacodynamic, pharmacokinetic, and toxicological studies, Sprycel is recommended for the indications proposed in the Product Monograph. Dose-reduction studies are recommended to be conducted in order to find a lower effective dose to reduce the risk of potentially fatal toxicities. Furthermore, a myocardiotoxicity study should be conducted to rule out the possibility of adverse cardiomyocyte effects.
3.3 Clinical basis for decision
3.3.1 Pharmacodynamics
Dasatinib is a potent tyrosine kinase inhibitor with potency at sub-nanomolar concentrations for BCR-ABL, c-KIT, EPH, PDGFβ receptor, and SRC kinases. The inhibitory effect of dasatinib has been demonstrated in both in vitro and in vivo systems for CML cell lines and some solid tumour cell lines. The potency of dasatinib for inhibiting all the CML cell lines was higher than that of imatinib.
3.3.2 Pharmacokinetics
Absorption
Dasatinib was rapidly absorbed following oral administration in patients with leukemia. The maximum plasma concentrations occurred at 0.5-3 hours post-dose. The mean half-life of dasatinib was approximately 5-6 hours.
Distribution
Dasatinib had a large apparent volume of distribution suggesting that the drug is extensively distributed into the extravascular space.
Metabolism
Dasatinib was extensively metabolized in humans. The cytochrome P450 enzyme, CYP3A4, was the major enzyme responsible for the metabolism of dasatinib.
Excretion
Dasatinib, mostly in the form of metabolites, was primarily excreted in the feces.
Drug Interactions
Clinical drug interaction studies were conducted with a CYP3A4 substrate (simvastatin) and a CYP3A4 inducer (rifampin). Additional interaction studies with an aluminum hydroxide/magnesium hydroxide-containing antacid (e.g., Maalox) and the H2-blocker famotidine were also conducted.
Co-administration of dasatinib with CYP3A4 substrate, simvastatin, increased the exposures to simvastatin and simvastatin acid by approximately 20-40% compared with simvastatin alone. The effect of the CYP3A4 substrate on the dasatinib exposure was not studied. There was an increased chance of borderline QTc prolongation following the concomitant use of both products in healthy subjects.
Plasma levels of dasatinib and two of its metabolites were significantly reduced by the CYP3A4 inducer, rifampin. It is also noted that more patients experienced borderline QTc prolongation with the combined treatment compared to those that received dasatinib alone, despite the fact that rifampin and dasatinib were administered 12 hours apart. The increased combined effect cannot be explained because no adverse QTc effect was known for rifampin; and rifampin greatly reduced the drug exposure parameters, Cmax and AUC of dasatinib and the two active metabolites in the plasma.
Significant reductions of dasatinib exposure, 61% and 55%, were reported 10-12 hours following administration of famotidine and Maalox, respectively. The logical explanation for the reduced exposure of dasatinib is probably due to its pH-dependent solubility.
Famotidine and Maalox are known to increase the GI fluid pH. As a result, dasatinib was less soluble when the GI fluid pH was increased and presumably was less absorbed.
3.3.3 Clinical Efficacy
The clinical efficacy of Sprycel was evaluated for the treatment of adults with chronic, accelerated, or blast phase CML. The effectiveness was based on the rates of hematologic and cytogenetic responses. The primary efficacy endpoints were either hematologic or cytogenetic responses depending on the stage of the disease, i.e., in the advanced stages (accelerated or blast phase) the primary endpoint was the hematologic response whereas in the chronic phase studies it was the cytogenetic response.
Duration of follow-up is limited. There were no controlled trials demonstrating a clinical benefit, such as improvement in disease-related symptoms or increased survival. Based on the results of the Phase I dose escalating study, a starting dose of 70 mg BID (twice a day) was chosen. There was no linear dose-response relationship and responses were achieved at levels both above and below 70 mg BID. Further studies confirming the starting dose of 70 mg BID should be conducted.
Chronic Phase CML
Two Phase II studies were conducted with patients with chronic phase CML. Study CA180017 was a randomized, non-comparative study with patients who were resistant to imatinib ≤600 mg per day. No imatinib-intolerant patients were enrolled in this study. Patients were randomized in a 2:1 ratio to receive either Sprycel 70 mg BID or imatinib 400 mg BID. The primary efficacy endpoint was the rate of major cytogenetic response (MCyR). At the time of interim analysis, the number of patients in this study was small. The 12-week assessment from the first 36 randomized patients (22 in the Sprycel arm and 14 in the imatinib arm) showed a MCyR in nine patients receiving Sprycel and in three patients receiving imatinib (based on at least 20 metaphases counted). A complete cytogenetic response (CCyR) occurred in six patients receiving Sprycel and in one patient receiving imatinib. Crossover to alternate therapy occurred in two patients of the Sprycel arm and in 11 patients of the imatinib arm. The median duration of treatment was 3.7 months in the Sprycel arm and 2.7 months in the imatinib arm. The interim data have demonstrated that Sprycel induced complete and major hematologic responses in patients with chronic phase CML resistant to imatinib 400 to 600 mg/day, including those who had not achieved cytogenetic response on prior imatinib therapy. A larger number of patients with a longer follow-up is required in order to assess treatment results in these two groups of patients. Final analysis from this randomized pivotal study will be required to confirm the efficacy of dasatinib when follow-up data become available.
Study CA180013 was a single-arm Phase II study involving 186 patients with chronic phase CML, resistant or intolerant to imatinib. Patients received Sprycel 70 mg BID. Dose escalation to 90 mg BID was allowed for patients who showed evidence of progression or lack of response. In addition to imatinib, 42% of the patients had received prior cytotoxic chemotherapy, 70% had received prior interferon, and 9% had received a prior stem cell transplant. The median duration of treatment was 5.6 months. Based on ≥20 metaphases counted, the percentage of patients that demonstrated a MCyR and CCyR were 40% and 31%, respectively.
Accelerated Phase CML
In study CA180005, Sprycel was evaluated in a total of 107 patients with accelerated phase CML, who were resistant or intolerant to imatinib. Prior treatment also included cytotoxic chemotherapy, interferon, or a stem cell transplant. The median duration of treatment was 5.5 months. The major and complete hematologic response (MaHR, CHR) rates were 59% and 33%, respectively. The MCyR and CCyR rates were 24% and 15%, respectively.
Blast Phase CML
In study CA180006, Sprycel was evaluated in a total of 74 patients with myeloid blast phase CML, who were resistant or intolerant to imatinib. Prior treatment also included cytotoxic chemotherapy, interferon, or a stem cell transplant. The median duration of treatment was 3.5 months. The MaHR and CHR rates were 32% and 24%, respectively. The MCyR and CCyR rates were 22% and 18%, respectively.
In study CA180015, a total of 42 CML patients in the lymphoid blast phase who were resistant or intolerant to imatinib were analyzed. Prior treatment also included cytotoxic chemotherapy, interferon, or a stem cell transplant. The median duration of treatment was 2.8 months. The MaHR and CHR rates were 31% and 26%, respectively. The MCyR and CCyR rates were 43% and 36%, respectively.
Conclusion
The results of the clinical studies show promising evidence of clinical effectiveness based on the rates of hematologic and cytogenetic responses, however additional efficacy data are required to confirm the clinical benefit of Sprycel.
As part of the post-approval commitments, the sponsor has agreed to provide periodic and final efficacy analysis from all ongoing Phase I/II dasatinib studies included in this submission. Results for the chronic phase CML dose optimization study (Study CA180034) will also be provided.
3.3.4 Clinical Safety
One Phase I study and five Phase II studies provided the safety data for this drug submission. Each of the six studies represented a single stage of the disease, with the exception of the Phase I study which included patients from all stages, and Study CA1800015, which included patients with lymphoid blast phase CML and Ph+ ALL. The integrated safety database consisted of 511 patients. Most patients (289, 57%) received treatment for 3-6 months. Fewer patients (167, 33%) were treated for ≤3 months. The remaining patients were treated for 6-12 months (55, 11%) or longer (1, 0%). The majority of deaths were due to disease progression.
Almost all patients reported at least one treatment-emergent adverse event (AE). Most reactions were mild to moderate. The proportion of severe adverse events (SAEs) increased with increasing disease severity, from 48% in chronic phase patients up to 83% in lymphoid blast phase CML and Ph+ ALL patients. The most frequently reported AEs, regardless of causality or severity, were fluid retention (49%), diarrhea (48%), hemorrhage (41%), pyrexia (40%), headache (39%), musculoskeletal pain (38%), fatigue (35%), rash (34%), nausea (32%), dyspnea (31%), infection (29%), abdominal pain (25%), cough (24%), vomiting (23%), asthenia (22%), and pain (21%).
Laboratory Abnormalities
Most (>85%) of the patients developed some degree of myelosuppression, which was severe in more than half of the patients. Patients with greater disease severity had more moderate and severe abnormalities at baseline, and went on to develop more severe myelosuppression on treatment.
Frequent occurrences of significant hypophosphatemia and hypocalemia were reported. The proportion of patients with grade 3 and 4 abnormalities was significantly higher in patients with myeloid blast or lymphoid blast phase CML.
Information on thyroid function was not available. A request was made to the sponsor to provide relevant data. Information from Periodic Safety Update Reports may mandate monitoring of thyroid function.
Adverse Events of Special Interest
Generally, SAEs and AEs were common. Many of these were anticipated as a result of underlying disease, and by the nature of the therapy. Certain events were of special interest either because of unexpected frequency or severity. In addition, some potential AEs were noted after examining the safety data from imatinib (another tyrosine kinase inhibitor), and were therefore actively pursued.
Fluid Retention
Fluid retention, manifested as edema and pleural effusions, was reported to be very common with the use of imatinib. The etiology of this was unclear, but an unexpectedly high incidence of myocardial dysfunction was subsequently observed. The possibility of a link between the two is now being assessed prospectively in an ongoing trial with dasatinib. In the integrated safety database of 511 patients, edema and pleural effusion were common throughout all of the CML disease phases. Pericardial effusion was not rare in any disease phase, with an overall incidence of 4%.
Hemorrhagic Events
Patients with CML commonly have thrombocytopenia. This, along with marrow suppression and impaired clot stability due to dasatinib, made bleeding events common, occurring in approximately a third of all patients. The majority of non-gastrointestinal (GI) and non-intracranial hemorrhages were mild (grade 1 or 2). The dosing of dasatinib was reduced or interrupted infrequently, and no patients discontinued treatment because of hemorrhages. Hemorrhages were more common in patients with advanced disease.
GI hemorrhage is common in patients with advanced leukemia and is usually associated with severe thrombocytopenia. Slightly more than 16% of subjects in the studies reported a GI bleed of any grade. Just over a half of all reported GI bleeds were grade 3 or 4, and most of these patients needed blood transfusion.
Intracranial hemorrhage is known to be associated with advanced leukemia, and is frequently fatal. All the central nervous system (CNS) bleeds reported in the studies were associated with grade 3 or 4 thrombocytopenia.
Cardiovascular Events
The safety pharmacology studies revealed that Sprycel has the potential to cause QTc prolongation. This was also observed in healthy volunteers when dasatinib was administered with CYP3A4 substrates or CYP3A4 inducers. In Phase II clinical studies in patients with leukemia treated with Sprycel, the mean changes from baseline in QTcF interval were 3-6 msec; the upper 95% confidence interval for all mean changes from baseline was <8 msec and the lower 95% confidence interval for all mean changes from baseline was >-2 msec. Three patients (<1%) experienced a QTcF >500 msec.
The Product Monograph includes a warning that dasatinib may cause significant QTc prolongation if given to subjects known to have a congenital long QTc interval syndrome, and that co-administration of dasatinib with other drugs known to cause QTc prolongation should be monitored carefully.
Attention was focused on cardiac toxicity presented in a paper that was published last year that suggested imatinib therapy may cause left ventricular (LV) dysfunction. Clinical trials with ABL-BCR tyrosine kinase inhibitors have consistently reported a high incidence of edema, some of which were severe, as well as severe dyspnea. Although these findings are relatively common in patients with CML, it is possible that treated patients may develop LV dysfunction and congestive heart failure (CHF) without previous cardiac history. The occurrence of direct drug-induced cardiotoxicity has not been established at this time. From the integrated safety database of 511 patients, the incidence reports of CHF, pulmonary edema, and cardiomyopathy were pooled together for each of the CML disease phases, as all three AEs may represent a manifestation of LV dysfunction. The total number of these three events for the chronic phase, accelerated phase, myeloid blast phase, and lymphoid blast phase were 13 (6%), 10 (8%), 17 (18%), and 3 (3%), respectively.
The incidence of dyspnea was high throughout all CML disease phases. The total numbers of cases in the chronic phase, accelerated phase, myeloid blast phase, and lymphoid blast phase were 52 (25%), 34 (29%), 33 (34%), and 20 (23%), respectively. The etiology of the dyspnea is not known, but it seems likely that a significant proportion is due to LV dysfunction. Interestingly, the incidence is quite similar across the disease spectrum, suggesting that this may be a drug-related effect. The results of prospective and serial cardiac function tests now being carried out in ongoing studies may be illuminating. Warnings regarding CHF and pulmonary edema are presented in the Product Monograph for dasatinib.
Gastrointestinal and Hepatic Events
GI AEs were common throughout all CML disease phases. The most common events were diarrhea, nausea, and vomiting, with incidences of 48%, 32%, and 23%, respectively, for all disease phases pooled. Together, these three AEs were considered to be severe (grade 3 or 4) in 8% of the pooled population. Non-specific abdominal pain was also frequently reported.
Non-specific elevations of liver enzymes, bilirubin, ratio of prothombin time (INR), and decreases in albumin were reported frequently. No patients developed significant hepatic impairment and most abnormalities were resolved spontaneously with or without a dose interruption. The incidence of hepatic function abnormalities increased with increasing disease severity. None of the patients discontinued dasatinib due to hepatic toxicity. Although causality was not established, the development of liver function abnormalities should be approached with caution. The median duration of follow-up for the full safety set was only three months. These hepatic abnormalities are included in the Product Monograph.
Conclusion
Treatment-emergent AEs were frequent in all disease phases, with the frequency of AEs correlating with disease severity. Overall, the safety and tolerability of Sprycel (dasatinib) is acceptable for the patient group for which it is indicated. Ongoing monitoring is required to clarify the importance of some unexpected treatment-emergent AEs.
Additional safety data is required to confirm the clinical benefit and long-term safety of Sprycel. As part of the post-approval commitments, the sponsor has agreed to provide periodic safety analysis and results from the completion of all ongoing Phase I/II dasatinib studies included in this submission. Clinical and non-clinical studies on left ventricular ejection fractions and potential myocardial toxicity will also be provided. The sponsor will report all serious adverse reactions that occurred in Canada and all serious unexpected adverse reactions that occurred outside of Canada within 15 days to Health Canada and submit a periodic safety update report (PSUR) semi-annually until the conditions of the authorization have changed.
3.4 Benefit/Risk Assessment and Recommendation
3.4.1 Benefit/Risk Assessment
Sprycel is a useful new drug for the treatment of imatinib-resistant CML. Patients with CML who are resistant to imatinib or who cannot tolerate imatinib have limited therapeutic options and no drugs are currently authorized for these indications. Dasatinib was clearly more potent than imatinib in inhibiting imatinib-sensitive CML cell lines, and was also effective in imatinib-insensitive or resistant CML cell lines. Dasatinib has expected and unexpected safety issues such as hematosuppression, fluid retention, GI tract toxicity, hemorrhages, and cardiovascular toxicities. Since there is no effective treatment currently available for patients who failed imatinib, and the toxicity profiles of dasatinib are largely predictable and manageable with careful clinical monitoring, the benefit/risk for dasatinib is positive.
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 Sprycel is favourable for the treatment of adults with chronic, accelerated, or blast phase CML with resistance or intolerance to prior therapy including imatinib mesylate.
This New Drug Submission (NDS) qualifies for authorization under the NOC/c policy. The NDS 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.
Consistent with the NOC/c policy, the sponsor has agreed to provide confirmatory data:
- 2-year follow-up data from the following studies conducted in accelerated phase and blast crisis phase CML: CA180002, CA180015, CA180006, CA180005, and CA180013.
- 24-month follow-up of MCyR data from study CA180017 as well as the results of the dose optimization study CA180034.
The sponsor has agreed to conduct additional post-market safety and PK studies to further characterize the safety profile of Sprycel, and final reports will be provided upon completion. This will include the clinical and non-clinical studies on left ventricular ejection fractions and potential myocardial toxicity, as well as studies evaluating the effects of ketoconazole, and liver impairment, on the PK of Sprycel.
All serious adverse reactions that occurred in Canada and all serious unexpected adverse reactions that occurred outside of Canada will be reported within 15 days to Health Canada, and a 120-day safety update report will be submitted following the issuance of the NOC/c. Periodic Safety Update Reports will be submitted semi-annually, until the conditions have been removed from the NOC/c by Health Canada.
4 Submission Milestones
Submission Milestones: Sprycel
Submission Milestone | Date |
---|---|
Pre-submission meeting: | 2005-11-15 |
Submission filed: | 2006-03-29 |
Screening 1 | |
Screening Deficiency Notice issued: | 2006-04-28 |
Response filed: | 2006-05-25 |
Screening Acceptance Letter issued: | 2006-06-22 |
Review 1 | |
Biopharmaceutics Evaluation complete: | 2006-12-12 |
Quality Evaluation complete: | 2006-12-13 |
Clinical Evaluation complete: | 2007-01-16 |
Labelling Review complete: | 2007-01-16 |
NOC/c-QN issued by Director General: | 2007-01-17 |
Response to QN filed: | 2007-01-30 |
Review 2 | |
NOC/c issued by Director General: | 2007-03-26 |
Related Drug Products
Product name | DIN | Company name | Active ingredient(s) & strength |
---|---|---|---|
SPRYCEL | 02293137 | BRISTOL-MYERS SQUIBB CANADA | DASATINIB (DASATINIB MONOHYDRATE) 50 MG |
SPRYCEL | 02293145 | BRISTOL-MYERS SQUIBB CANADA | DASATINIB (DASATINIB MONOHYDRATE) 70 MG |
SPRYCEL | 02293129 | BRISTOL-MYERS SQUIBB CANADA | DASATINIB (DASATINIB MONOHYDRATE) 20 MG |