Summary Basis of Decision for Naglazyme

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

Summary Basis of Decision (SBD) documents provide information related to the original authorization of a product. The SBD for Naglazyme is located below.

Recent Activity for Naglazyme

SBDs written for eligible drugs approved after September 1, 2012 will be updated to include post-authorization information. This information will be compiled in a Post-Authorization Activity Table (PAAT). The PAAT will include brief summaries of activities such as submissions for new uses of the product, and whether Health Canada's decisions were negative or positive. PAATs will be updated regularly with post-authorization activity throughout the product's life cycle.

Post-Authorization Activity Table (PAAT) for Naglazyme

Updated: 2023-04-06

The following table describes post-authorization activity for Naglazyme, a product which contains the medicinal ingredient galsulfase. For more information on the type of information found in PAATs, please refer to the Frequently Asked Questions: Summary Basis of Decision (SBD) Project: Phase II and to the list of abbreviations that are found in PAATs.

For additional information about the drug submission process, refer to the Management of Drug Submissions and Applications Guidance.

Drug Identification Number (DIN):

  • DIN 02412683 - 1 mg/mL galsulfase solution, intravenous administration

Post-Authorization Activity Table (PAAT)

Activity/submission type, control number Date submitted Decision and date Summary of activities
SNDS # 246115 2020-11-06 Issued NOC 2021-04-22 Submission filed as a Level I – Supplement to update the inner and outer labels and package insert. The submission was reviewed and considered acceptable, and an NOC was issued.
NC # 221396 2018-10-26 Issued NOL 2019-01-18 Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change to the drug substance fermentation process. The submission was reviewed and considered acceptable, and an NOL was issued.
NC # 192008 2016-02-05 Issued No Objection Letter
2016-05-03
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to add a new testing site and make changes regarding the reference standard. The submission was reviewed and considered acceptable, and a No Objection Letter was issued.
Drug product (DIN 02412683) market notification Not applicable Date of first sale:
2014-01-01
The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.
NDS # 159020 2012-10-10 Issued NOC
2013-09-16
Notice of Compliance issued for New Drug Submission.
Summary Basis of Decision (SBD) for Naglazyme

Date SBD issued: 2013-12-10

The following information relates to the New Drug Submission for Naglazyme.

Galsulfase, 5 mg/5 mL (1 mg/mL), solution, Intravenous Infusion

Drug Identification Number (DIN):

  • 02412683

BioMarin Pharmaceutical Inc.

New Drug Submission Control Number: 159020

 

On September 16, 2013 Health Canada issued a Notice of Compliance to BioMarin Pharmaceutical Inc. for the drug product, Naglazyme.

The market authorization was based on quality (chemistry and manufacturing), non-clinical (pharmacology and toxicology), and clinical (pharmacology, safety, and efficacy) information submitted. Based on Health Canada's review, the benefit/risk profile of Naglazyme is favourable for long-term enzyme replacement therapy (ERT), in patients with a confirmed diagnosis of Mucopolysaccharidosis VI (MPS VI; N-acetylgalactosamine 4-sulfatase deficiency; Maroteaux-Lamy syndrome).

1 What was approved?

Naglazyme, an enzyme replacement therapy was authorized for long-term enzyme replacement therapy in patients with a confirmed diagnosis of Mucopolysaccharidosis VI (MPS VI ; N-acetylgalactosamine 4-sulfatase deficiency; Maroteaux-Lamy syndrome).

Naglazyme is contraindicated for patients who are hypersensitive to the active substance or to any of the excipients. Naglazyme was approved for use under the conditions stated in the Naglazyme Product Monograph taking into consideration the potential risks associated with the administration of this drug product.

Naglazyme (1 mg/mL, galsulfase) is presented as a solution for intravenous (IV) infusion (concentrate 1 mg/mL, sterile solution 5 mg/5 mL). In addition to the medicinal ingredient, the concentrate and sterile solution contains Polysorbate 80, Sodium chloride, Sodium phosphate dibasic heptahydrate, Sodium phosphate monobasic monohydrate, and water for injection.

For more information, refer to the Clinical, Non-Clinical, and Quality (Chemistry and Manufacturing) Basis for Decision sections.

Additional information may be found in the Naglazyme Product Monograph, approved by Health Canada and available through the Drug Product Database.

2 Why was Naglazyme approved?

Health Canada considers that the benefit/risk profile of Naglazyme is favourable for long-term enzyme replacement therapy in patients with a confirmed diagnosis of Mucopolysaccharidosis VI (MPS VI ; N-acetylgalactosamine 4-sulfatase deficiency; Maroteaux-Lamy syndrome).

Mucopolysaccharidosis VI (MPS VI ), or Maroteaux-Lamy syndrome, is a rare autosomal-recessive heterogeneous lysosomal storage disease (LSD) resulting from a deficiency in the enzyme N-acetylgalactosamine 4-sulfatase (ASB; arylsulfatase B), causing intracellular accumulation of dermatan sulphate, a glycosaminoglycan (GAG), in multiple tissues and organs. Currently, there are 11 patients diagnosed with MPS VI in Canada. Ultimately, affected individuals become wheelchair-bound or bedridden secondary to skeletal deformity, cardiopulmonary disease, blindness and/or spinal cord compression, and eventually succumb to infection, surgical complications, or cardiorespiratory failure. Naglazyme (rhASB, galsulfase) is the only approved enzyme replacement therapy treatment for MPS VI patients in other jurisdictions. It has demonstrated improvements in the clinical signs and symptoms in patients diagnosed with MPS VI.

Naglazyme has been shown to be efficacious in Mucopolysaccharidosis VI patients, however, adequate safety precautions should be taken to monitor for hypersensitivity reactions during infusion.

The market authorization for Naglazyme was based on data from a randomized, double-blind, placebo-controlled pivotal study (ASB-03-05) as well as data from four open-label clinical studies: ASB-00-01, ASB-01-04, ASB-03-06, and ASB-008, and an open-label study conducted in four infants.

The pivotal study (ASB-03-05) was designed to assess the treatment effect of Naglazyme versus (vs.) a placebo-control in a total of 39 patients with MPS VI and a 12 minute walk distance of 5 to 400 metres. The primary endpoint in this pivotal study was the distance walked in the 12 minute walk test (12 MWT). The Naglazyme-treated group showed greater mean increases in the distance walked in the 12 MWT compared with the placebo group. Therefore, the primary endpoint was met. A secondary endpoint, the 3-Minute Stair Climb Test, was not met in the pivotal study.

Due to the low number of patients in clinical studies conducted, adverse event (AE) data from all Naglazyme studies were combined and reviewed in a single, clinical trial safety analysis.

The safety evaluation for Naglazyme was conducted in 59 patients in clinical studies. All patients treated with Naglazyme (59/59) reported at least one adverse event (AE). The majority (71%) of patients experienced at least one adverse drug reaction (ADR). The most common adverse reactions were pyrexia, rash, pruritus, urticaria, chills/rigors, nausea, headache, abdominal pain, vomiting and dyspnea. Serious adverse reactions included laryngeal edema, apnea, pyrexia, urticaria, respiratory distress, angioedema, asthma, and anaphylactoid reaction.

Because of the potential for infusion reactions, patients should receive antihistamines with or without antipyretics prior to infusion. Despite routine pre-treatment with antihistamines, infusion reactions (some severe), have occurred in 56% of patients treated with Naglazyme. Serious adverse reactions during infusion included laryngeal edema, apnea, pyrexia, urticaria, respiratory distress, angioedema, and anaphylactoid reaction. Severe adverse reactions included urticaria, chest pain, rash, dyspnea, apnea, laryngeal edema, and conjunctivitis.

In the Phase III double-blind, placebo-controlled, randomized study (ASB-03-05), 19 patients were treated with Naglazyme compared to 20 patients treated with placebo and the most common ADRs were pain (abdominal, ear, joint, and general pain, 47-32% vs. 35-5%, respectively), conjunctivitis (21% vs. 0) and chills (21% vs 0).

In addition to infusion reactions reported in clinical studies, serious reactions which occurred during Naglazyme infusion in the worldwide marketing experience include anaphylaxis, shock, hypotension, bronchospasm, and respiratory failure. These serious reactions have been captured in the Naglazyme Product Monograph (PM).

A Risk Management Plan (RMP) for Naglazyme was submitted by BioMarin Pharmaceutical (Canada) Inc. to Health Canada. Upon review, the RMP was considered to be acceptable. The RMP is designed to describe known and potential safety issues, to present the monitoring scheme and, when needed, to describe measures that will be put in place to minimize risks associated with the product.

Overall, based on the efficacy results from the Phase III study (ASB-03-05), in addition to the safety results from all Naglazyme studies and from post-marketing data, the benefit-risk of Naglazyme therapy is currently considered favourable for MPS VI patients in Canada. Due to the limited number of patients affected by this disease worldwide, and to the genetic heterogeneity of the disease, the risk-benefit analysis of this Enzyme Replacement Therapy requires periodic updates. In particular, the potential impact of Anti-Drug Antibody (ADA) (drug immunogenicity) on the long term efficacy and safety of Naglazyme must be reassessed as new clinical data become available.

This 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. For more information, refer to the Clinical, Non-Clinical, and Quality (Chemistry and Manufacturing) Basis for Decision sections.

3 What steps led to the approval of Naglazyme?

Submission Milestones: Naglazyme

Submission Milestone Date
Pre-submission meeting: 2012-10-04
Submission filed: 2012-10-10
Screening  
Screening Acceptance Letter issued: 2012-11-23
Review  
On-Site Evaluation: 2013-06-17 - 2013-06-20
Quality Evaluation complete: 2013-09-11
Clinical Evaluation complete: 2013-09-12
Labelling Review complete: 2013-06-28
Notice of Compliance (NOC) issued by Director General under the Notice of Compliance with Conditions (NOC/c) Guidance: 2013-09-16

 

For additional information about the drug submission process, refer to the Management of Drug Submissions Guidance.

4 What follow-up measures will the company take?

Requirements for post-market commitments are outlined in the Food and Drugs Act and Regulations.

6 What other information is available about drugs?

Up to date information on drug products can be found at the following links:

7 What was the scientific rationale for Health Canada's decision?
7.1 Clinical Basis for Decision

 

Clinical Pharmacology

Mucopolysaccharide storage disorders are caused by the deficiency of specific lysosomal enzymes required for the catabolism of glycosaminoglycan (GAG). Mucopolysaccharidosis VI (MPS VI) is characterized by the absence or marked reduction in N-acetylgalactosamine 4-sulfatase which results in the accumulation of the GAG substrate, dermatan sulfate, throughout the body. This accumulation leads to widespread cellular, tissue, and organ dysfunction.

Galsulfase, the medicinal ingredient of Naglazyme, is intended to provide an exogenous enzyme that will be taken up into lysosomes and increase the catabolism of GAG. Galsulfase uptake by cells into lysosomes is most likely mediated by the binding of mannose-6-phosphate-terminated oligosaccharide chains of galsulfase to specific mannose-6-phosphate receptors.

The pharmacokinetic parametres of Naglazyme were evaluated in 13 patients with MPS VI who received 1 mg/kg of galsulfase as a weekly 4-hour infusion for 24 weeks. Development of anti-galsulfase antibodies appears to affect galsulfase pharmacokinetics however the data are limited. Due to the large assay variability, these data are difficult to interpret and the impact of the observed drug immunogenicity on clinical efficacy remains unclear. This has been captured in the Naglazyme Product Monograph.

In vivo pharmacodynamics studies, ranging from 5 weeks to 15  months duration, were conducted utilizing cats with the MPS VI genotype. Routes of administration were intravenous (IV), intraarticular (IA) and intrathecal (IT). Results of these studies revealed that long-term treatment of MPS VI -affected cats with Naglazyme was well tolerated by all routes and improved many characteristic morphological changes associated with the disease. Findings included decreased urinary GAG excretion, reduction of storage vacuoles in Kupffer cells and connective tissue, an increase in bone mineral volume, greater mobility and flexibility, and improvement in the neurological symptoms secondary to spinal cord compression. When treatment was initiated before symptoms were evident, that is (i.e.) shortly after birth, there was also a significant positive impact on bone growth and remodeling.

Rapid degradation and elimination of stored GAG did not induce toxicity, and weekly dosing was sufficient to maintain adequate tissue levels. The lowest dose that resulted in significant clinical improvement in affected cats was 1.0 mg/kg body weight (bw)/week. Naglazyme was generally well-tolerated in single and repeat-dose toxicity studies at doses up to 20 mg/kg bw. Reproductive toxicity studies demonstrated that Naglazyme did not impair fertility potential/implantation, and did not result in maternal toxicity, embryo-fetal toxicity nor teratogenicity. The primary findings across all toxicology studies were reddening of the skin inside the ears and/or facial edema in dogs, swelling of the mouth, nose, and/or paws in rats, and serocellular/pustular epidermititis in monkeys. These findings were, in part, considered to be related to the repeated administration of a heterologous protein with or without the subsequent development of an anaphylactic type hypersensitivity reaction, and/or to the polysorbate 80 in the Naglazyme formulation, which has been shown to have histamine-releasing properties. A statement was therefore included in the product monograph to indicate that there is the potential for a hypersensitivity reaction while on treatment.

The non-clinical toxicology data base was considered adequate to assess the safety profile of Naglazyme and support its use in the proposed clinical populations provided adequate safety precautions are taken to monitor for hypersensitivity reactions during infusion.

For further details, please refer to the Naglazyme Product Monograph, approved by Health Canada and available through the Drug Product Database.

Clinical Efficacy

The clinical efficacy of Naglazyme was primarily evaluated in one Phase III, double-blind, placebo-controlled study (ASB-03-05). In addition, an open-label extension study (ASB-03-06), and four open-label clinical studies, including ASB-00-01, ASB-01-04, ASB-008, (conducted in four infants) were evaluated. A Phase 4 study, the Clinical Surveillance Program (CSP) to evaluate long-term safety and efficacy data is ongoing.

The Phase III study was a randomized, double-blind, placebo-controlled study in which 19 patients received weekly infusions of 1 mg/kg Naglazyme and 20 patients received placebo; of the 39 patients 66% were female, and 62% were White, non-Hispanic. Patients were aged 5 years to 29 years. Naglazyme-treated patients were approximately 3 years older than placebo-treated patients (mean age 13.7 years vs. 10.7 years, respectively). Enrollment was restricted to patients with a 12 minute walk distance of 5 to 400 metres. All patients were treated with antihistamines prior to each infusion. Following the 24-week placebo-controlled study period, 38 patients received open-label Naglazyme for 72 weeks.

The primary endpoint in this pivotal study was the distance walked in the 12 minute walk test (12 MWT). The secondary endpoints were a 3-minute stair climb test and urinary GAG levels.

The Naglazyme-treated group showed greater mean increases in the distance walked in 12 minutes (12 minute walk test, 12-MWT) compared with the placebo group. In the 3-minute stair climb test, the rate in the Naglazyme-treated group increased over time [mean (± standard deviation (SD))]: 19 ± 13 stairs per minute at baseline and 27 ± 17 stairs per minute at Week 24. The placebo group showed a nearly constant rate of number of stairs climbed over time [mean (± SD)]: 31 ± 18 stairs per minute at baseline and 33 ± 20 stairs per minute at Week 24). The difference in change in rates [mean (± SD)] for the Naglazyme and placebo patients was 6 ± 3 stairs per minute (p = 0.053).

Following the 24-week placebo-controlled study period, 38 patients received open-label Naglazyme for 72 weeks (Study ASB-03-06). Among the 19 patients who were initially randomized in Naglazyme and who continued to receive treatment for 72 weeks (total of 96 weeks), increases in the 12-MWT distance and in the rate of stair climbing were observed compared to the start of the open-label period [[mean (±SD) change]: 72 ± 116 metres and 5.6 ± 10.6 stairs/minute, respectively)]. Among the 19 patients who were randomized initially to placebo for 24 weeks, and then crossed over to treatment with Naglazyme, the increases after 72 weeks of Naglazyme treatment compared to the start of the open-label period, [(mean (± SD) change): were 118 ± 127 metres and 11.1 ± 10.0 stairs/minute, for the 12-MWT and the rate of stair climbing, respectively.]

Bioactivity was evaluated with urinary GAG concentration.  Overall, 95% of patients showed at least a 50% reduction in urinary GAG levels after 72 weeks of treatment with Naglazyme. No patient receiving Naglazyme reached the normal range for urinary GAG levels.

The four open-label clinical studies (ASB-00-01, ASB-01-04, ASB-03-06, ASB-008 CSP) were conducted in MPS VI patients aged 3  months to 29 years with Naglazyme administered at doses of 0.2 mg/kg [number (n) = 2], 1 mg/kg (n = 55), and 2 mg/kg (n = 2). The mean exposure to the recommended dose of Naglazyme (1 mg/kg) was 138 weeks (range = 54 to 261 weeks). Two infants (12.1  months and 12.7 months) were exposed to 2 mg/kg of Naglazyme for 105 and 81 weeks, respectively. Observed adverse events (AEs) in the four open-label clinical studies (up to 261 weeks treatment) were not different in nature or severity to those observed in the Phase III study. No patients discontinued during open-label treatment with Naglazyme due to AEs. Safety results in infants were consistent with results observed in patients 5 to 29 years old.

During ASB-008 a Phase IV, randomized, two-dose level study, four MPS VI patients (3 months to 12.7 months) were treated at 1 or 2 mg/kg/week for 53 to 153 weeks. Safety results in infants were consistent with results observed in patients 5 to 29 years old.

Based on the efficacy results from the Phase III study, and on the safety results from all Naglazyme studies and post-marketing data, the benefit-risk of Naglazyme therapy is considered favourable for MPS VI patients in Canada. Safety and efficacy data were updated in the Naglazyme Product Monograph.

For more information, refer to the Naglazyme Product Monograph, approved by Health Canada and available through the Drug Product Database.

Clinical Safety

Due to the low number of patients in clinical studies conducted, the clinical safety evaluation was based on adverse event (AE) data from all Naglazyme studies (previously described in the Clinical Efficacy section) that were combined and reviewed in a single, clinical safety analysis.

All patients treated with Naglazyme (59/59) in clinical studies conducted reported at least one adverse event (AE). The majority (42/59; 71%) of patients experienced at least one adverse drug reaction (ADR). The most common adverse reactions were pyrexia (50%), rash, pruritus, urticaria, chills/rigors, nausea, headache, abdominal pain, vomiting and dyspnea (3%). Serious adverse reactions included laryngeal edema, apnea, pyrexia, urticaria, respiratory distress, angioedema, asthma, and anaphylactoid reaction.

Because of the potential for infusion reactions, patients should receive antihistamines with or without antipyretics prior to infusion. Despite routine pre-treatment with antihistamines, infusion reactions, some severe, have occurred in 33 of 59 (56%) patients treated with Naglazyme. Serious adverse reactions during infusion included laryngeal edema, apnea, pyrexia, urticaria, respiratory distress, angioedema, and anaphylactoid reaction. Severe adverse reactions included urticaria, chest pain, rash, dyspnea, apnea, laryngeal edema, and conjunctivitis.

In a study with 19 patients treated with Naglazyme compared to 20 patients treated with placebo, the most common ADRs were pain (abdominal, ear, joint, and general pain, 47-32% vs. 35-5%, respectively), conjunctivitis (21% vs. 0) and chills (21% vs 0).

In addition to infusion reactions reported in clinical studies, serious reactions which occurred during Naglazyme infusion in the worldwide marketing experience include anaphylaxis, shock, hypotension, bronchospasm, and respiratory failure. Appropriate warnings and precautions are in place in the approved Naglazyme Product Monograph to address the identified safety concerns.

For more information, refer to the Naglazyme Product Monograph, approved by Health Canada and available through the Drug Product Database.

7.2 Non-Clinical Basis for Decision

The non-clinical toxicology data was considered adequate to assess the safety profile of Naglazyme and support its use in patients with a confirmed diagnosis of Mucopolysaccharidosis VI (MPS VI) provided adequate safety precautions are taken to monitor for hypersensitivity reactions during infusion.

Naglazyme is intended for long-term lysosomal enzyme replacement therapy (ERT) for treatment of patients with the lysosomal storage disorder (LSD), MPS VI. This treatment replaces the enzyme, Arylsulfatase B (ASB) that is absent or deficient in MPS VI patients, thereby halting or reversing some aspects of disease progression.

The non-clinical testing regime was designed to support the chronic treatment of MPS VI patients. All test species used to conduct the toxicological assessment of Naglazyme express the mannose-6-phosphate receptor, the major uptake receptor for Naglazyme. Since Naglazyme is intended for intravenous infusion to patients, toxicity studies compliant with good laboratory practices (GLP) were conducted utilizing the intravenous route of exposure. The doses selected for the toxicity studies were up to 20-fold higher than the intended clinical dose for patients. Studies were conducted to evaluate acute-dose toxicity, repeat-dose toxicity, potential adverse effects on male and female fertility, and effects on maternal animals and embryo/fetal development.

In conclusion, Naglazyme was generally well-tolerated in single and repeat-dose toxicity studies at doses up to 20 mg/kg bw. Reproductive toxicity studies demonstrated that Naglazyme did not impair fertility potential/implantation, and did not result in maternal toxicity, embryo-fetal toxicity nor teratogenicity. The primary findings across all toxicology studies were reddening of the skin inside the ears and/or facial edema in dogs, swelling of the mouth, nose, and/or paws in rats, and serocellular/pustular epidermitis in monkeys. These findings were, in part, related to the repeated administration of a heterologous protein with or without the subsequent development of an anaphylactic type hypersensitivity reaction, and/or to the polysorbate 80 in the Naglazyme formulation, which has been shown to have histamine-releasing properties. Therefore, a statement has been included in the Naglazyme Product Monograph to indicate that there is the potential for a hypersensitivity reaction while on treatment.

For more information, refer to the Naglazyme Product Monograph, approved by Health Canada and available through the Drug Product Database.

7.3 Quality Basis for Decision

The Chemistry and Manufacturing information submitted for Naglazyme 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.

Characterization of the Drug Substance

Galsulfase, the active ingredient in Naglazyme, is a recombinant form of human N-acetylgalactosamine 4-sulfatase and is produced by recombinant DNA technology using mammalian Chinese Hamster Ovary (CHO) cell line.

Recombinant human N-acetylgalactosamine 4-sulfatase, also known as arylsulfatase B (rhASB), is a 495 amino acid lysosomal sulfatase that cleaves the sulfate ester from N-acetylgalactosamine 4-sulfate residues at the nonreducing ends of the glycosaminoglycans chondroitin sulfate and dermatan sulfate.

Manufacturing Process and Process Controls of the Drug Substance and Drug Product

The manufacturing process for the drug substance, galsulfase, follows a typical process, starting with the thaw of a single vial of Working Cell Bank. The cells are expanded through a seed train and used to inoculate the production bioreactors. The harvest fluid is concentrated by ultrafiltration and then purified using conventional column chromatography steps. The last column eluate is concentrated by ultrafiltration and a final formulation step is performed prior to filling the Formulated Bulk Drug Substance (FBDS) into the approved storage container closure system.

The container closure system, shipping configurations, filling sites, and filling processes are the same as those used for Aldurazyme and therefore information already reviewed in the Aldurazyme New Drug Submission and Supplementary New Drug Submission was not re-reviewed.

The manufacturing process for the Drug Product is relatively simple as the Drug Substance is shipped as a formulated bulk. In the case of Jubilant HollisterStier (JHS), each bag of FBDS is transferred by gravity to a glass product vessel. The vessel is connected to redundant sterile filtration devices that feed into a surge vessel and the filtered bulk is delivered to the filling equipment as needed. In the case of Vetter, all FBDS bags are recombined into a single recombination bag using a peristaltic pump. The filtered bulk is delivered to the filling equipment as needed.

At both the JHS and Vetter Langenargen sites, adequate pilot and production scale data to support the manufacturing scales were provided.

Control of the Drug Substance and Drug Product

Process validation and production data for the Drug Substance support both scales and the comparability of Drug Substance manufactured at either scale.

The Drug Substance and the Drug Product testing methods are the same except that the peptide map, bioburden, host-cell protein content, SDS-PAGE, charge heterogeneity, sialic acid content, oligosaccharide profiling, and in vitro uptake tests are Drug Substance specific, and the dot blot identity test is Drug Product specific. The Drug Product release specifications also include the compendial tests for liquid Drug Product parenterals. The analytical release method validations were reviewed and found to be acceptable for their intended use.

Two assays, the rhASB endpoint activity assay (potency) and SEC-HPLC (aggregates), were performed in-house using material manufactured at Vetter and Jubilant HollisterStier. The results of the in-house testing supported the conclusion that the methods are suitable for their intended uses.

Stability of the Drug Substance and Drug Product

The updated specifications for Drug Substance and Drug Product presented at the On-Site Evaluation (OSE) have been reviewed and are acceptable.

Based on the complete real-time stability data, the proposed Formulated Bulk Drug Substance 24 month shelf-life at 2-8°C for Naglazyme is considered acceptable.

Stability data was provided for both Jubilant HollisterStier and Vetter manufactured Drug Product lots. Adequate real-time and accelerated stability data was provided to support the proposed Drug Product expiry dating of 36 months when stored at 2 to 8°C.

Facilities and Equipment

The design, operations, and controls of the facilities and equipment that are involved in production are considered suitable for the activities and products manufactured.

An On-Site Evaluation (OSE) of the BioMarin Novato Campus including the Galli Manufacturing Facility was conducted June 17 to 20, 2013 by the Biologics and Genetic Therapies Directorate, Health Canada. Four Risk 3 (minor) observations were made and successfully resolved after the OSE.

Adventitious Agents Safety Evaluation

The Naglazyme manufacturing process incorporates adequate control measures to prevent contamination and maintain microbial control.

All cell lines successfully passed tests for sterility, identity and the presence of adventitious agents. Genetic stability results showed that the cells maintained genetic stability and remained retrovirus-free at the limit of cell age (LCA). Therefore the proposed LCA was acceptable for both scales.

Certificates of Analysis (COAs) and European Directorate for the Quality of Medicines (EDQM) certificates of suitability for animal-derived products used in the cell culture media were provided in the NDS or obtained following the 2013 OSE. All other raw materials are of compendial grade or are tested by in-house methods prior to release for use.