Summary Basis of Decision for Trulicity

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 Trulicity is located below.

Recent Activity for Trulicity

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 Trulicity

Updated:

2020-03-02

The following table describes post-authorization activity for Trulicity, a product which contains the medicinal ingredient dulaglutide. 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 Guidance.

Drug Identification Numbers (DINs):

  • DIN 02448572 – 0.75 mg/0.5 mL dulaglutide, solution (pre-filled syringe), subcutaneous injection
  • DIN 02448580 – 1.5 mg/0.5 mL dulaglutide, solution (pre-filled syringe), subcutaneous injection
  • DIN 02448599 – 0.75 mg/0.5 mL dulaglutide, solution (single use pen), subcutaneous injection
  • DIN 02448602 – 1.5 mg/0.5 mL dulaglutide, solution (single use pen), subcutaneous injection

Post-Authorization Activity Table (PAAT)

Activity/submission type, control numberDate submittedDecision and dateSummary of activities
SNDS # 2202782018-09-19Issued NOC
2019-08-15
Submission filed as a Level I - Supplement to add a new indication for Trulicity. The indication authorized was Trulicity is indicated for the once-weekly treatment of adult patients with type 2 diabetes mellitus to improve glycemic control, in combination with sodium glucose co-transporter 2 inhibitor (SGLT2i) with metformin, when diet and exercise plus SGLT2i with or without metformin do not achieve adequate glycemic control. Regulatory Decision Summary published.
NC # 2267672019-04-11Issued NOL
2019-05-23
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to update an in-process control used in the manufacturing process. The submission was reviewed and considered acceptable, and an NOL was issued.
NC # 2224082018-11-28Issued NOL
2019-03-05
Submission filed as a Level II (90 day) Notifiable Change to update the PM with new safety information. As a result of the NC, modifications were made to the Warnings and Precautions section of the PM, and corresponding changes were made to the PM Part III: Patient Medication Information. The submission was reviewed and considered acceptable, and an NOL was issued.
NC # 2183092018-07-17Issued NOL
2018-09-11
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to add a test method for the drug product. The submission was reviewed and considered acceptable, and an NOL was issued.
NC # 2154182018-04-12Issued NOL
2018-06-15
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to add test methods for the drug product. The submission was reviewed and considered acceptable, and an NOL was issued.
NC # 2151822018-04-04Issued NOL
2018-04-18
Submission filed as a Level II (90 day) Notifiable Change to update the PM. As a result of the NC, modifications were made to the Instructions for Use section of the PM. The submission was reviewed and considered acceptable, and an NOL was issued.
SNDS # 2019642017-01-16Issued NOC
2017-12-22
Submission filed as a Level I - Supplement to add a new indication for Trulicity. The indication authorized was Trulicity is indicated for the once-weekly treatment of adult patients with type 2 diabetes mellitus to improve glycemic control, in combination with basal insulin with metformin, when diet and exercise plus basal insulin with or without metformin do not achieve adequate glycemic control. Regulatory Decision Summary published.
NC # 2117482017-11-30Issued a Screening Rejection Letter
2017-12-07
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for an alternate site for quality control testing. The changes were not in scope of an NC but were considered to be Level III changes. A Screening Rejection Letter was issued.
NC # 2046772017-04-11Issued NOC
2017-06-15
Submission filed as a Level II (90 day) Notifiable Change  (Risk Management Change) to update the PM based on post-market safety information. The submission was reviewed and considered acceptable, and an NOL was issued.
NC # 1973602016-08-03Issued NOL
2016-10-24
Submission filed as a Level II (90 day) Notifiable Change  (Moderate Quality Changes) to update the cell line identity test. The submission was reviewed and considered acceptable, and an NOL was issued.
NC # 1953872016-05-25Issued NOL
2016-08-04
Submission filed as a Level II (90 day) Notifiable Change (Risk Management Change) to update the PM with safety-related changes. The submission was reviewed and considered acceptable, and an NOL was issued.
NC # 1938342016-03-30Issued NOL
2016-06-07
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to add a single-dose pen assembly line at the manufacturing site and to add new control laboratories for release testing. The submission was reviewed and considered acceptable, and an NOL was issued.
NC # 1939742016-04-05Issued NOL
2016-06-01
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to change the drug substance purification process. The submission was reviewed and considered acceptable, and an NOL was issued.
Drug product (DIN 02448599) market notificationNot applicableDate of first sale:
2016-01-08
The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.
Drug product (DIN 02448602) market notificationNot applicableDate of first sale:
2015-11-24
The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.
NDS # 1686712015-01-19Issued NOC
2015-11-27
Notice of Compliance issued for New Drug Submission.
Summary Basis of Decision (SBD) for Trulicity

Date SBD issued: 2016-02-05

The following information relates to the new drug submission for Trulicity.

Dulaglutide, 0.75 mg/0.5 mL and 1.5 mg/0.5 mL, solution, subcutaneous injection

Drug Identification Number (DIN):

  • DIN 02448572 - 0.75 mg/0.5 mL, solution (pre-filled syringe)
  • DIN 02448580 - 1.5 mg/0.5 mL, solution (pre-filled syringe)
  • DIN 02448599 - 0.75 mg/0.5 mL, solution (single use pen)
  • DIN 02448602 - 1.5 mg/0.5 mL, solution (single use pen)

Eli Lilly Canada Inc.

New Drug Submission Control Number: 168671

On November 10, 2015, Health Canada issued a Notice of Compliance to Eli Lilly Canada Inc. for the drug product, Trulicity.

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 Trulicity is favourable for the once-weekly treatment of adult patients with type 2 diabetes mellitus to improve glycemic control, in combination with:

  • diet and exercise in patients for whom metformin is inappropriate due to contraindication or intolerance.
  • metformin, when diet and exercise plus maximal tolerated dose of metformin do not achieve adequate glycemic control.
  • metformin and a sulfonylurea, when diet and exercise plus dual therapy with metformin and a sulfonylurea do not achieve adequate glycemic control.
  • prandial insulin with metformin, when diet and exercise plus basal or basal-bolus insulin therapy (up to two injections of basal or basal plus prandial insulin per day) with or without oral antihyperglycemic medications, do not achieve adequate glycemic control.

1 What was approved?

Trulicity, an antihyperglycemic agent, was authorized for the once-weekly treatment of adult patients with type 2 diabetes mellitus to improve glycemic control, in combination with:

  • diet and exercise in patients for whom metformin is inappropriate due to contraindication or intolerance.
  • metformin, when diet and exercise plus maximal tolerated dose of metformin do not achieve adequate glycemic control.
  • metformin and a sulfonylurea, when diet and exercise plus dual therapy with metformin and a sulfonylurea do not achieve adequate glycemic control.
  • prandial insulin with metformin, when diet and exercise plus basal or basal-bolus insulin therapy (up to two injections of basal or basal plus prandial insulin per day) with or without oral antihyperglycemic medications, do not achieve adequate glycemic control.

Trulicity has not been studied in combination with basal insulin (long acting).

Trulicity is not a substitute for insulin. Trulicity should not be used in patients with type 1 diabetes mellitus (formerly known as insulin-dependent diabetes mellitus or IDDM) or for the treatment of diabetic ketoacidosis.

Trulicity was studied in a limited number of patients 65 years of age or older and in few patients 75 years of age or older.

The safety and efficacy of Trulicity have not been established in pediatric patients. Therefore, Trulicity should not be used in this patient population.

Trulicity is contraindicated for patients who are hypersensitive to this drug or to any ingredient in the formulation or component of the container. Trulicity is also contraindicated in patients with a personal or family history of medullary thyroid carcinoma or in patients with Multiple Endocrine Neoplasia syndrome type 2 (MEN 2). Additionally, Trulicity is also contraindicated for use during pregnancy or in breast‑feeding women. Trulicity was approved for use under the conditions stated in the Trulicity Product Monograph taking into consideration the potential risks associated with the administration of this drug product.

Health Canada also added the following limitations on clinical use:

  • Trulicity has not been studied in combination with basal insulin (long-acting).
  • Trulicity is not a substitute for insulin.
  • Trulicity should not be used in patients with type 1 diabetes mellitus (formerly known as insulin‑dependent diabetes mellitus or IDDM) or for the treatment of diabetic ketoacidosis.

In the New Drug Submission, the sponsor also recommended a 1.5 mg once-weekly dose. Based on the efficacy and safety data of the two doses studied in clinical trials (0.75 mg and 1.5 mg), Health Canada revised the recommended dose as follows:

The recommended initiating dose of Trulicity is 0.75 mg administered subcutaneously once‑weekly. The dose may be increased to 1.5 mg once‑weekly for additional glycemic control. The maximum recommended dose is 1.5 mg once‑weekly.

Trulicity (0.75 mg/0.5 mL and 1.5 mg/0.5 mL, dulaglutide) is supplied in both strengths as either a single‑use pre‑filled syringe or single‑use pre‑filled pen for self‑injection once weekly. Each single‑use syringe or pen provides 0.75 mg or 1.5 mg Trulicity per 0.5 mL of solution. In addition to the medicinal ingredient dulaglutide, the single‑use syringe or pen also contains the following non-medicinal ingredients: citric acid anhydrous, mannitol, polysorbate 80, and trisodium citrate dehydrate.

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 Trulicity Product Monograph, approved by Health Canada and available through the Drug Product Database.

2 Why was Trulicity approved?

Health Canada considers that the benefit/risk profile of Trulicity is favourable for the once-weekly treatment of adult patients with type 2 diabetes mellitus (T2DM) to improve glycemic control, in combination with:

  • diet and exercise in patients for whom metformin is inappropriate due to contraindication or intolerance.
  • metformin, when diet and exercise plus maximal tolerated dose of metformin do not achieve adequate glycemic control.
  • metformin and a sulfonylurea, when diet and exercise plus dual therapy with metformin and a sulfonylurea do not achieve adequate glycemic control.
  • prandial insulin with metformin, when diet and exercise plus basal or basal-bolus insulin therapy (up to two injections of basal or basal plus prandial insulin per day) with or without oral antihyperglycemic medications, do not achieve adequate glycemic control.

Type 2 diabetes mellitus is a metabolic disorder characterized by high levels of blood glucose due to insulin resistance and/or insulin deficiency, which can lead to substantial morbidity and mortality, including an increased risk of microvascular and macrovascular complications. Type 2 diabetes mellitus is usually initially managed with lifestyle changes, including diet and exercise. Yet, as the condition progresses, medications may be necessary to achieve and maintain glycemic control.

Trulicity has been shown to be efficacious in the treatment of patients with T2DM. The market authorization was based primarily on four randomized, placebo‑ and/or active‑controlled, Phase III studies. These four studies evaluated the use of Trulicity as add‑on therapy to metformin Studies H9X‑MC‑GBCF and H9X‑MC‑GBDE, as add‑on combination therapy to metformin and sulfonylurea Study H9X‑MC‑GBDB, and as combination therapy with insulin lispro with or without metformin Study H9X-MC-GBDD.

The primary efficacy endpoint for all four studies was the change in glycated hemoglobin (HbA1c) from baseline. The timing of the primary endpoint assessment ranged from 26 weeks to 52 weeks, depending on the study.

For HbA1c change from baseline, results from the studies showed that treatment with Trulicity was non‑inferior to sitagliptin, liraglutide (another GLP-1 receptor agonist), and to insulin glargine. For the indications authorized, Trulicity was effective in reducing HbA1c when combined with metformin or with metformin plus sulfonylurea, or with prandial insulin and metformin. Other benefits observed include reduction of fasting blood glucose (FPG) and body weight [as with other glucagon‑like peptide 1 (GLP‑1) agonists].

Trulicity was also evaluated in Study H9X‑MC‑GBCM in patients with renal impairment for whom metformin was inappropriate due to contraindication or intolerance. Results from this study demonstrated no trends of clinical concern with respect to safety and increase in renal impairment.

The safety profile of Trulicity was found to be comparable to other marketed GLP‑1 receptor agonists in Canada. One major concern identified during the safety review of the Trulicity submission was the potential risk of developing thyroid cancer with the use of Trulicity. Thyroid C‑cell tumors have also been observed in animal studies conducted with other similar GLP‑1 receptor agonists at clinically relevant doses. While it cannot be confirmed whether Trulicity does cause thyroid C‑cell tumors, a Serious Warnings and Precautions Box has been inserted in the Trulicity Product Monograph indicating Trulicity is contraindicated in patients with a personal or family history of medullary thyroid carcinoma (MTC) or in patients with Multiple Endocrine Neoplasia type 2 (MEN2).

Other relevant safety issues included cardiovascular effects (increase in heart rate, PR interval prolongation, and tachyarrhythmia), gastrointestinal events, and rare cases of pancreatitis.

A Risk Management Plan (RMP) for Trulicity was submitted by Eli Lilly 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.

A Look‑alike Sound‑alike brand name assessment was performed and the proposed name Trulicity has been deemed acceptable.

Overall, the therapeutic benefits seen in the Phase III studies are robust and the benefits of Trulicity therapy are considered to outweigh the risks. Trulicity has an acceptable safety profile based on the non-clinical data and clinical studies. The identified safety issues can be managed through labelling and adequate monitoring. Appropriate warnings and precautions are in place in the Trulicity Product Monograph to address the identified safety concerns.

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 Trulicity?

A New Drug Submission (NDS) for Trulicity was filed with Health Canada on February 10, 2014. During the review of the Trulicity submission, a concern was raised regarding the cardiovascular safety profile of Trulicity where an adequate benefit‑risk assessment could not be conducted with the information provided. As a result, on September 23, 2014 the sponsor was issued a Notice of Deficiency (NOD) requesting additional data from all completed and ongoing clinical studies to provide more data which could assist in establishing a more comprehensive benefit‑risk assessment. A revised summary of major adverse cardiovascular events (MACE) analysis was also requested as part of the NOD. In response to the NOD, additional information and data were provided by the sponsor. As a result, all issues outlined in the NOD were satisfactorily addressed and a Notice of Compliance (NOC) was issued on November 10, 2015.

Submission Milestones: Trulicity

Submission MilestoneDate
Submission filed:2014-02-10
Screening 1
Screening Acceptance Letter issued:2014-04-04
Review 1
Quality Evaluation complete:
Clinical Evaluation complete:2014-09-23
Notice of Deficiency (NOD) issued by Director General (safety issues):2014-09-23
Meeting to discuss NOD:2014-11-03
Response filed:2014-12-16
Screening 2
Screening Acceptance Letter issued:2015-01-14
Review 2
On-Site Evaluation:2015-08-03 - 2015-08-07
Quality Evaluation complete:2015-11-06
Clinical Evaluation complete:2015-11-10
Labelling Review complete:2015-10-28
Notice of Compliance issued by Director General:2015-11-10

The Canadian regulatory decision on the non-clinical, clinical and quality review of Trulicity was based on a critical assessment of the Canadian data package. The foreign reviews completed by the European Union's centralized procedure European Medicines Agency (EMA) and the United States Food and Drug Administration (FDA) were used as an added reference during review of the clinical data package.

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

Trulicity contains the medicinal ingredient dulaglutide, which is a long‑acting glucagon‑like peptide 1 (GLP‑1) receptor agonist. Like endogenous GLP‑1, Trulicity helps regulate postprandial blood glucose concentrations by increasing intracellular cyclic adenosine monophosphate (cAMP) in pancreatic beta cells leading to insulin release in the presence of elevated glucose concentrations. This insulin secretion subsides as blood glucose concentrations decrease and approach euglycemia. Trulicity also decreases glucagon secretion and slows gastric emptying, thereby reducing the rate at which postprandial glucose appears in the circulation.

The clinical pharmacology included reports on the human pharmacodynamic and pharmacokinetic studies. The clinical pharmacological data support the use of Trulicity for the proposed dosing regimen of 0.75 mg (which may be increased to 1.5 mg) once weekly.

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

Clinical Efficacy

The Clinical program included more than 35 clinical studies, however only the data relevant to the indications and the conditions of use of this product shall be summarized below.

The efficacy of Trulicity was evaluated primarily in four controlled Phase III clinical studies, H9X‑MC‑GBCF, H9X‑MC‑GBDE, H9X‑MC‑GBDB, and H9X‑MC‑GBDD. The primary efficacy endpoint for all four studies was the change in glycated hemoglobin (HbA1c) from baseline. The timing of the primary endpoint assessment ranged from 26 weeks to 52 weeks, depending on the study.

Trulicity was also evaluated in Study H9X‑MC‑GBCM in patients with renal impairment for whom metformin is inappropriate due to contraindication or intolerance

Clinical Studies
Study H9X‑MC‑GBCF: Add-On Combination Therapy to Metformin

Study H9X‑MC‑GBCF was a 104-week, multicentre, double‑blind, placebo‑controlled study. A total of 972 patients with type 2 diabetes mellitus (T2DM) were randomized and received either Trulicity 0.75 mg or Trulicity 1.5 mg administered once‑weekly, placebo, or sitagliptin 100 mg/day (after 26 weeks, patients in the placebo treatment group received blinded sitagliptin 100 mg/day for the remainder of the study), all as add-on to metformin. Randomization occurred after an 11-week lead-in period to allow for a metformin titration period followed by a 6-week glycemic stabilization period. The primary objective of the study was to demonstrate that the HbA1c change from baseline for Trulicity 1.5 mg administered once‑weekly was non‑inferior to sitagliptin at 52 weeks, with a non‑inferiority margin of 0.25%.

Study results showed that treatment with Trulicity once‑weekly resulted in a statistically significant reduction in HbA1c compared to placebo (at 26 weeks) and compared to sitagliptin (at 52 weeks). The proportions of patients who achieved a HbA1c target of <7% were 49%, 59% and 33% in the Trulicity 0.75 mg, Trulicity 1.5 mg, and sitagliptin groups respectively.

Study H9X‑MC‑GBDE: Add‑On Combination Therapy to Metformin

Study H9X‑MC‑GBDE was a 26‑week, multicentre, open-label study where 599 patients were randomized to receive either once‑weekly Trulicity 1.5 mg or once daily liraglutide 1.8 mg, both as add‑on to metformin. Patients randomized to liraglutide were initiated at 0.6 mg daily (QD) for one week, then escalated to 1.2 mg QD for one week and then escalated to 1.8 mg QD for the remainder of the study. The primary objective of this study was to demonstrate the non‑inferiority of Trulicity 1.5 mg administered once‑weekly compared to liraglutide 1.8 mg QD, both on a background of metformin, in achieving HbA1c reduction from baseline when compared to Week 26, with a non‑inferiority margin of 0.4%.

Study results obtained at Week 26 demonstrated that treatment with Trulicity 1.5 mg once‑weekly was non‑inferior to liraglutide 1.8 mg QD; with both on a background to metformin. The percentage of patients achieving an HbA1c target of <7% was 68% in the Trulicity 1.5 mg group versus (vs) 68% in the liraglutide group.

Study H9X‑MC‑GBDB: Add‑On Combination Therapy to Metformin and Sulfonylurea

Study H9X‑MC‑GBDB was a 78‑week multicentre, parallel‑arm, open-label (double‑blind with respect to Trulicity dose assignment), active comparator (insulin glargine) study. A total of 807 patients were randomized and received either Trulicity 0.75 mg or Trulicity 1.5 mg administered once‑weekly compared to insulin glargine QD, all as add‑on to maximally tolerated doses of metformin and glimepiride. Randomization occurred after a 10-week lead-in period; during the initial 2 weeks of the lead-in period, patients were titrated to maximally tolerated doses of metformin and glimepiride. This was followed by a 6- to 8-week glycemic stabilization period prior to randomization.

At randomization, patients assigned to the insulin glargine arm were started on a dose of 10 units QD. Insulin glargine dose adjustments occurred twice‑weekly for the first 4 weeks of treatment based on self-measured fasting plasma glucose, followed by once‑weekly titration through Week 8 of study treatment, utilizing an algorithm with an fasting plasma glucose (FPG) target of <5.6 mmol/L. After Week 8, patients continued to self-adjust insulin glargine to the FPG target. The insulin glargine dose was also reviewed and revised, as needed, at subsequent office visits (Weeks 14, 20, 26, 35, 44, 52, 65, and 78). The dose of glimepiride could be reduced or discontinued after randomization (at the discretion of the investigator) in the event of persistent hypoglycemia.

The primary objective of the study was to demonstrate the non‑inferiority of Trulicity 1.5 mg once‑weekly compared to insulin glargine (titrated to target FPG of <5.6 mmol/L), both on a background of metformin and glimepiride, in achieving HbA1c reduction from baseline compared to Week 52, with a non‑inferiority margin of 0.4%. Only 23.5% of patients in the insulin glargine group achieved the target FPG. The dose of glimepiride was reduced or discontinued in 28%, 32%, and 29% of patients randomized to Trulicity 0.75 mg, Trulicity 1.5 mg, and insulin glargine.

Study results at the 52‑week time point demonstrated that Trulicity 1.5 mg and 0.75 mg were non‑inferior to insulin glargine for HbA1c change from baseline. The proportion of patients who achieved an HbA1c target of <7% were 37%, 53% and 31% in the Trulicity 0.75 mg, Trulicity 1.5 mg and insulin glargine groups respectively.

Study H9X‑MC‑GBDD: Combination Therapy with Insulin Lispro (with or without Metformin)

Study H9X‑MC‑GBDD was a 52‑week Phase III, randomized, parallel‑arm, open-label (double‑blind with respect to Trulicity dose assignment) active comparator (insulin glargine) study. This study evaluated the efficacy of either Trulicity 0.75 mg or Trulicity 1.5 mg administered once‑weekly, both in combination with insulin lispro, with or without metformin, in patients with T2DM previously treated with a stable, conventional insulin regimen for at least three months.

A total of 884 patients on one or two insulin injections QD, alone or with oral antihyperglycemic therapy, were enrolled. Randomization occurred after a 9‑week lead‑in period. During the initial two weeks of the lead‑in period, patients continued their pre‑study insulin regimen, but could also be initiated and/or up-titrated with metformin, based at investigator discretion. This was then followed by a 7‑week glycemic stabilization period prior to randomization.

At randomization, patients discontinued their pre‑study insulin regimen and were randomized to Trulicity 0.75 mg or 1.5 mg administered once‑weekly, or insulin glargine QD, all in combination with prandial insulin lispro three times daily, with or without metformin. Insulin lispro was titrated in both arms based on pre‑prandial and bedtime glucose, and insulin glargine was titrated based on a target fasting glucose of <5.6 mmol/L.

The primary objective of the study was to demonstrate non‑inferiority of Trulicity 1.5 mg once‑weekly compared to insulin glargine, both in combination with prandial insulin lispro, in HbA1c reduction from baseline at 26 weeks, with a non‑inferiority margin of 0.4%. Only 35.8% of patients in the glargine arm achieved their target fasting glucose.

Study results at the 26‑week time point demonstrated that Trulicity 1.5 mg was non‑inferior to insulin glargine for HbA1c change from baseline. Trulicity 0.75 mg was also non‑inferior to insulin glargine. The proportion of patients who achieved a HbA1c target of <7% were 69%, 68% and 57% in the Trulicity 0.75 mg, Trulicity 1.5 mg, and insulin glargine groups respectively.

Study H9X-MC-GBCM: Renal Impairment 

Study H9X-MC-GBCM was a parallel‑design, open‑label, multicentre, single‑dose study in patients with renal impairment and control subjects with normal renal function. A total of 48 subjects were enrolled and completed this study: eight patients in each of the renally impaired groups (mild, moderate, severe, and end‑stage renal disease) and 16 healthy (control) subjects. There was no clinically relevant effect of renal impairment on the pharmacokinetics of Trulicity.  A single subcutaneous dose of 1.5 mg Trulicity was generally well‑tolerated in all renal function groups. There were no trends of clinical concern with respect to safety and increase in renal impairment. This data indicated that Trulicity may be administered to patients with renal impairment without dose adjustment.

Other Supporting Data Addressing Renal Impairment 

In placebo-controlled studies with a duration of ≥26 weeks, the majority of patients did not change their chronic kidney disease (CKD) stage (all doses of Trulicity: 91.7%; placebo: 90.1%). Numerically fewer patients in the Trulicity treatment arms had CKD stage that became worse compared to placebo (6.6% and 8.4%, respectively). Moreover, no Trulicity dose‑effects were observed with serum creatinine level or the estimated glomerular filtration rate (eGFR). Significant, decreases were observed for albumin excretion in Trulicity 1.5 mg treatment arm compared with Trulicity 0.75 mg.

A total of 425 (7.1%) patients in Phase II and III studies had a degree of renal impairment at baseline [eGFR <60 mL/min/1.73 m2 and/or macroalbuminuria (urine albumin creatinine ratio) (UACR) >300 mg/g)]. A total of 270 (6.7%) of Trulicity-treated patients had renal impairment.  In patients with renal dysfunction at baseline, treatment with Trulicity did not alter serum creatinine or eGFR compared to placebo.

Indication

In the New drug Submission (NDS) the sponsor had proposed the following indication: Trulicity is indicated for the once-weekly treatment of patients with type 2 diabetes mellitus to improve glycemic control, in combination with:

  • diet and exercise in patients for whom metformin is inappropriate due to contraindication or intolerance.
  • metformin, when diet and exercise plus maximal tolerated dose of metformin do not achieve adequate glycemic control.
  • metformin and a sulfonylurea, when diet and exercise plus dual therapy with metformin and a sulfonylurea do not achieve adequate glycemic control.
  • metformin and a thiazolidinedione when diet and exercise plus dual therapy with metformin and thiazolidinedione do not achieve adequate glycemic control.
  • prandial insulin (with or without metformin) when diet and exercise plus prandial insulin (with or without metformin) do not achieve adequate glycemic control.

The approved indication by Health Canada is as follows:

Trulicity is indicated for the once-weekly treatment of adult patients with type 2 diabetes mellitus to improve glycemic control, in combination with:

  • diet and exercise in patients for whom metformin is inappropriate due to contraindication or intolerance.
  • metformin, when diet and exercise plus maximal tolerated dose of metformin do not achieve adequate glycemic control.
  • metformin and a sulfonylurea, when diet and exercise plus dual therapy with metformin and a sulfonylurea do not achieve adequate glycemic control.
  • prandial insulin with metformin, when diet and exercise plus basal or basal-bolus insulin therapy (up to two injections of basal or basal plus prandial insulin per day) with or without oral antihyperglycemic medications, do not achieve adequate glycemic control.

Note, the combination therapy with thiazolidinediones was not granted due to the cardiovascular risk inherent with this class of products. Also, the combination with prandial insulin was revised to reflect the research study design, along with current clinical practice in Canada.

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

Clinical Safety

The safety of Trulicity in patients with type 2 diabetes mellitus (T2DM) was evaluated across nine Phase II and III clinical studies, including a total of 4,006 patients (for 3,531 patient-years) who received Trulicity. A total of 3,045 patients received Trulicity for at least 24 weeks, with 2,279 patients continuing treatment for at least 50 weeks. A total of 369 patients were treated with Trulicity for approximately two years.

In placebo‑controlled studies of at least 26‑week duration, the incidence of discontinuation due to adverse events was 2.6% for Trulicity 0.75 mg and 6.1% for Trulicity 1.5 mg versus 3.7% for placebo. Through the full duration of the studies (up to 104 weeks), the incidence of discontinuation due to adverse events was 5.1% and 8.4% for Trulicity 0.75 mg and 1.5 mg respectively. The most frequent adverse events leading to discontinuation for 0.75 mg and 1.5 mg Trulicity were nausea (1.0%, 1.9%), diarrhea (0.5%, 0.6%), and vomiting (0.4%, 0.6%).

The proportion of patients reporting at least one treatment‑emergent adverse event (TEAE) was 68.1% for Trulicity 0.75 mg, 71.6% for Trulicity 1.5 mg, and 66.7% with placebo. Gastrointestinal adverse events appeared to be dose‑dependent with more Trulicity 1.5 mg treated patients (21.1%) than Trulicity 0.75 mg treated patients (12.4%) reporting these events compared to placebo (5.3%). The most frequently reported gastrointestinal events were nausea (12.4% for 0.75 mg, 21.1% for 1.5 mg vs 5.3% for placebo), diarrhea (8.9%, 12.6% vs 6.7%), and vomiting (6.0%, 12.6% vs 2.3%). In studies up to 104 weeks, gastrointestinal events continued to be the most common TEAEs reported.

In placebo‑controlled studies of 26‑weeks duration, the incidence of serious adverse events (SAEs) was 3.9% for patients treated with Trulicity 0.75 mg, 4.4% for patients treated with Trulicity 1.5 mg, and 4.4% for patients treated with placebo.

Adverse Events of Special Interest
Pancreatitis 

A total of 151 patients had events/criteria that underwent pancreatic adjudication in Phase II and III studies. Of these, 19 patients had TEAEs of pancreatitis reported by investigators. Of the 151 patients (including the 19 who reported TEAE pancreatitis), nine patients [placebo: 1 (3.523/1,000 patient-year); sitagliptin: 3 (4.707/1,000 patient‑year); dulaglutide: 5 (1.416/1,000 patient-year)] were determined to have pancreatitis by adjudication. Six of these patients were considered to have acute pancreatitis, two had chronic pancreatitis, and one had type unknown.

Immunogenicity

The incidence of treatment-emergent Trulicity anti-drug antibodies in Trulicity‑treated patients were low, 1.6% (64 of 3,907); for patients treated with non‑GLP‑1 receptor agonist comparators (controls), it was 0.7%. These generally represented low titer findings with only four Trulicity-treated patients having high titers (≥1:128). Of the 64 (1.6%) Trulicity‑treated patients with treatment‑emergent anti-drug antibodies, 34 (0.9% of total population) had Trulicity neutralizing anti-drug antibodies, and four patients (0.1% of the total population) had native sequence GLP‑1 neutralizing antibodies. There was no evidence that treatment‑emergent Trulicity anti-drug antibodies interfere with the pharmacological effects of Trulicity on efficacy parameters. No Trulicity‑treated patient with treatment‑emergent Trulicity anti-drug antibodies reported a systemic hypersensitivity reaction.

Thyroid

Trulicity did not increase mean serum calcitonin values compared with placebo. Similar proportions of patients who received placebo or Trulicity had treatment‑emergent calcitonin ≥20 pg/mL. There was no apparent dose‑effect on calcitonin. One case of medullary thyroid carcinoma (MTC), identified after six months of treatment with dulaglutide 2 mg but considered to be pre‑existing, was reported during Phase II and III studies. Two papillary thyroid carcinomas were also identified, both in patients who received Trulicity 1.5 mg.

Cardiovascular

Dose‑dependent increases from baseline in mean heart rate (HR) [2 to 4 beats per minute (bpm)] were observed with Trulicity treatment. The increases were greater for Trulicity compared with placebo. These increases were also greater for Trulicity 1.5 mg than with 0.75 mg. The increases in HR were not associated with increased reporting of tachyarrhythmias by electrocardiogram (ECG) rhythm assessments or adverse events reporting. Increases in mean PR interval (2 to 3 milliseconds) were observed along with increased reporting of 1st degree atrioventricular block.

Malignancy

There was no increased reporting of malignancy in general or any specific malignancy type with Trulicity compared with placebo or active comparators. Two cases of pancreatic carcinoma were identified in Trulicity‑treated patients: one event was determined to be pre‑existing and the other was a large tumour discovered after approximately 5 months of Trulicity treatment.

Dose-Dependent Safety (Trulicity 0.75 mg vs Trulicity 1.5 mg)

The overall safety profile for Trulicity 0.75 mg and Trulicity 1.5 mg was comparable for the majority of safety measures. A dose-dependent increase in heart rate (range: 2 to 4.6 bpm) was observed with Trulicity treatment versus placebo in a Phase II study. The mean increases were greater for the Trulicity 1.5 mg dose compared with the Trulicity 0.75 mg dose from Week 4 through Week 26. The 1.5 mg dose was also associated with a higher risk of gastrointestinal disorders and discontinuation rate at the beginning of treatment (first 2 weeks). Dose-dependent increases in gastrointestinal adverse events were most notably nausea (12% for 0.75 to 21% for 1.5 mg) and vomiting (6% for 0.75 and 13% for 1.5 mg). Overall discontinuation rate was low due to gastrointestinal disorders but was higher in the 1.5 mg dose group (3.5%) compared with the 0.75 mg dose group (1.3%). A dose‑dependent increase in pancreatic enzymes was also observed, however, the clinical relevance is unknown.

Other Safety Issues
Injection Site Reactions

In the placebo‑controlled clinical studies, injection site adverse events were reported in 38 (1.7%) Trulicity‑treated patients compared to 6 (0.9%) patients in the placebo group. Injection site hematoma was the most frequently reported injection site reaction for both the placebo (3, 0.4%) and all Trulicity (17, 0.8%) treatment groups. Injection site pain (6, 0.3%) and erythema (4, 0.2%) were only reported in the Trulcity treatment group. Two Trulicity-treated patients discontinued study drug due to injection site reaction.

In studies of up to 104 weeks 1.9% of patients in the Trulicity 0.75 mg and 1.5 mg groups reported injection site reactions. Again injection site hematoma was the most commonly reported event (Trulicity 0.75 mg: 15, 0.9% and Trulicity 1.5 mg: 10, 0.6%). One patient in this group discontinued study drug due to injection site reaction.

Across the clinical studies of 26 up to 104 weeks duration, potentially immune‑mediated injection site adverse events [for example (e.g.), rash, and erythema] were reported in 0.5% and 0.7% of patients who received Trulicity 0.75 mg and 1.5 mg, respectively.

Hypoglycemia

When Trulicity was used in combination with a non-sulfonylurea, non-secretagogue, documented symptomatic hypoglycemia occurred in 2.6% to 6.3% of patients treated with Trulicity 0.75 mg and in 5.6% to 10.9% of patients treated with Trulicity 1.5 mg. No episodes of severe hypoglycemia were reported.

When Trulicity was used in combination with a sulfonylurea (plus metformin), symptomatic hypoglycemia occurred in 39% of patients treated with Trulicity 0.75 mg and 40.3% of patients treated with Trulicity 1.5 mg. Severe hypoglycemia events occurred in 0% of patients treated with Trulicity 0.75 mg and 0.7% of patients treated with Trulicity 1.5 mg.

When Trulicity was used in combination with prandial insulin, symptomatic hypoglycemia occurred in 85.3% of patients treated with Trulicity 0.75 mg and 80.0% of patients treated with Trulicity1.5 mg. Severe hypoglycemia events occurred in 2.4% and 3.4% of patients respectively for Trulicity 0.75 mg and 1.5 mg.

Hypersensitivity

In clinical studies, systemic hypersensitivity events (e.g. severe urticaria, systemic rash, facial edema, lips swelling) were reported in 0.5% of patients receiving Trulicity.

Safety Conclusion
Overall, the safety profile of Trulicity did not raise any new concerns and was comparable to the previously authorized GLP-1 agonists. The safety data submitted support the use of Trulicity 0.75 mg as the initiating dose and which may be increased to up 1.5 mg as clinically needed (additional glycemic control).

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

7.2 Non-Clinical Basis for Decision

The non‑clinical pharmacology, pharmacokinetic, and toxicology studies have characterized the non‑clinical profile of dulaglutide (the medicinal ingredient in Trulicity) in sufficient detail to support its use for the treatment of adults with T2DM.

It is however, important to note that dulaglutide did elicit pre-neoplastic and neoplastic changes to the thyroid gland in both rats and mice, at dose levels which are well within the range of human therapeutic doses. This indicates a potentially serious safety concern of thyroid toxicity and/or oncogenicity to humans, which must be taken into consideration when evaluating the human clinical data and conducting the risk/benefit analysis. Data from the mechanistic studies were insufficient to conclude that the thyroid C-cell findings in rodents are not relevant to human risk. Although there was no evidence of adverse effects to the pancreas, pancreatic cancers must be considered a potential safety risk, as is noted for other GLP‑1R agonists (exenatide, liraglutide and lixisenatide).

In addition, dulaglutide resulted in embryo/fetal toxicity, and was a potential teratogenic agent. Women who are trying to become pregnant should therefore be informed prior to treatment that Trulicity may result in adverse effects to the fetus. It is highly recommended that dulaglutide not be used to treat pregnant or lactating women.

The findings in animal studies were consistent with those reported with other GLP-1 receptor agonists (e.g. liraglutide). The risk of thyroid cancer is captured in the Warnings and Precautions box and the Risk Management Plan (RMP). In addition, based on these findings, Trulicity is contraindicated in pregnant and lactating women.

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

7.3 Quality Basis for Decision

Characterization of the Drug Substance

Detailed characterization studies were performed to provide assurance that dulaglutide, the drug substance, exhibits the desired characteristic structure and biological activity.  

Results from process validation studies indicate that the processing steps adequately control the levels of product- and process-related impurities and can consistently produce Drug Substance that meets pre-determined specifications.

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

Dulaglutide, the medicinal ingredient of Trulicity, is produced by recombinant deoxyribonucleic acid (DNA) technology in Chinese hamster ovary (CHO) cells. The manufacture of dulaglutide is based on a CHO master and working cell bank system, where the master and working cell banks have been thoroughly characterized and tested for adventitious contaminants and endogenous viruses in accordance with International Council for Harmonisation (ICH) guidelines. Results from genetic characterization studies also demonstrated stability of these cell banks.

The manufacturing process of dulaglutide consists of a series of steps which include cell culture, harvest, purification (including viral inactivation/removal steps), and formulation buffer exchange. The purification process includes a combination of chromatographic steps. The materials used in the manufacture of the drug substance are considered suitable and/or meet standards appropriate for their intended use.

The manufacturing of the drug product (Trulicity) consists of steps which include drug substance thawing, final formulation, sterile filtration, and aseptic syringe filling and plungering. The filled and plungered syringe is then assembled into either a single-use pen or a pre-filled syringe.  The drug product manufacturing process uses appropriate aseptic process techniques, equipment, and facilities.

In‑process controls and lot release tests for the drug substance and drug product were established and validated.

The materials used in the manufacture of the drug substance and drug product are considered to be suitable and/or meet standards appropriate for their intended use. The manufacturing processes are considered to be adequately controlled within justified limits.

All non-medicinal ingredients (excipients) found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations. The compatibility of dulaglutide with the excipients is supported by the stability data provided.

Control of the Drug Substance and Drug Product

The drug substance and drug product are tested against suitable reference standards to verify that they meet approved specifications and analytical procedures are validated in accordance with ICH guidelines.

Each lot of dulaglutide drug product is tested for appearance, content, identity, potency, purity, impurities, and safety (endotoxins and sterility). Established test specifications and validated analytical test methods are considered acceptable.

Through Health Canada’s lot release testing and evaluation program, consecutively manufactured drug product lots were tested, evaluated, and found to meet the specifications of the drug product for a subset of the release tests and confirm both the sponsor’s results and the suitability of those methods for routine lot release.

Stability of the Drug Substance and Drug Product

Based on the stability data submitted, the proposed shelf-life and storage conditions for the drug substance and drug product were adequately supported and are considered to be satisfactory. The proposed 24 months shelf-life for Trulicity is considered acceptable when stored refrigerated at 2 to 8°C and protected from light.

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.

An On-Site Evaluation (OSE) of the facility involved in the manufacture and testing of the drug substance was waived, given the facility was not in production during the review period.

There are two drug product manufacturing and testing sites. An OSE of one site was successfully conducted a by the Biologics and Genetic Therapies Directorate, Health Canada. An OSE was not conducted at the second site as a recent successful OSE had been conducted.

Adventitious Agents Safety Evaluation

The dulaglutide drug substance manufacturing process incorporates adequate control measures to prevent contamination and maintain microbial control. Pre-harvest culture fluid from each lot is tested to ensure freedom from adventitious microorganisms (bioburden, mycoplasma, and viruses). Purification process steps designed to remove and inactivate viruses are adequately validated.

Raw materials of animal and recombinant DNA origin used in the manufacturing process are adequately tested to ensure freedom from adventitious agents. The excipients used in the drug product formulation are not from animal or human origin.