Summary Basis of Decision for Prolensa

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 Prolensa is located below.

Recent Activity for Prolensa

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 Prolensa

Updated:

2019-04-02

The following table describes post-authorization activity for Prolensa, a product which contains the medicinal ingredient bromfenac sodium sesquihydrate. 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 Number (DIN):

  • DIN 02439123 - 0.07% w/v, bromfenac sodium sesquihydrat, solution, ophthalmic

Post-Authorization Activity Table (PAAT)

Activity/submission type, control numberDate submittedDecision and dateSummary of activities
SNDS # 2001952016-11-10Issued NOC
2017-02-08
Submission filed as a Level I - Supplement to update the PM regarding the in-use period of the drug product. The submission was reviewed and considered acceptable. Changes were made to the Dosage and Administration section of the PM and the PM Part III: Patient Medication Information. An NOC was issued.
NC #1976022016-08-12Cancellation Letter Received
2016-08-24
Submission filed as a Level II (90 day) Notifiable Change (Risk Management Change) to update the PM with new safety information. The proposed revisions exceeded the scope of an NC. The submission was therefore cancelled administratively by the sponsor so as to be filed as an SNDS.
Drug product (DIN 02439123) market notificationNot applicableDate of first sale:
2015-09-25
The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.
NDS # 1716572014-04-04Issued NOC
2015-03-26
Notice of Compliance issued for New Drug Submission.
Summary Basis of Decision (SBD) for Prolensa

Date SBD issued: 2015-05-12

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

Bromfenac sodium sesquihydrate, 0.07% w/v, solution, ophthalmic

Drug Identification Number (DIN):

  • 02439123

Bausch & Lomb Inc.orporated

New Drug Submission Control Number: 171657

On March 26, 2015, Health Canada issued a Notice of Compliance to Bausch & Lomb Incorporated for the drug product, Prolensa.

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 Prolensa is favourable for the treatment of postoperative inflammation and reduction of ocular pain in patients who have undergone cataract surgery.

1 What was approved?

Prolensa, a non-steroidal anti-inflammatory agent, was authorized for the treatment of postoperative inflammation and reduction of ocular pain in patients who have undergone cataract surgery.

No overall differences in safety and effectiveness have been observed between elderly (>70 years of age) and younger adult patients.

The safety and effectiveness in pediatric patients (<18 years of age) have not been established.

Prolensa is contraindicated for patients who are hypersensitive to this drug or to any ingredient in the formulation or component of the container. Since there exists the potential for cross-sensitivity, Prolensa should not be used in patients in whom acute asthmatic attacks, urticaria, rhinitis or other allergic manifestations are precipitated by acetylsalicylic acid (ASA) or other non-steroidal anti-inflammatory agents. Prolensa was approved for use under the conditions stated in the Prolensa Product Monograph taking into consideration the potential risks associated with the administration of this drug product.

Prolensa (bromfenac 0.07% w/v, as bromfenac sodium sesquihydrate) is presented as a topical ophthalmic solution. In addition to the medicinal ingredient, bromfenac sodium sesquihydrate, the solution also contains benzalkonium chloride, boric acid, edetate disodium, povidone, sodium borate, sodium sulfite, tyloxapol, sodium hydroxide, and water.

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

2 Why was Prolensa approved?

Health Canada considers that the benefit/risk profile of Prolensa is favourable for the treatment of postoperative inflammation and reduction of ocular pain in patients who have undergone cataract surgery.

Post-cataract surgery inflammation is an expected reaction that is usually self-resolving, but without treatment it can cause significant discomfort, pain, anxiety, and longer recovery. It has been estimated that approximately 20% of Canadians 65 to 79 years of age, and 30% of Canadians ≥80 years of age are diagnosed with cataracts at some point. Other alternative treatments approved in Canada include eye drops containing non-steroidal anti-inflammatory drugs [NSAIDs, for example (e.g.), ketorolac, diclofenac, or nepafenac], or corticosteroids (e.g., loteprednol, or rimexolone).

Prolensa, a topical NSAID, has been shown to be efficacious for the treatment of pain and inflammation following cataract eye surgery. The market authorization was based on two pivotal multicentre, randomized, double-blinded, parallel-group and placebo (vehicle) -controlled studies. A total of 440 patients were assessed. The primary efficacy endpoint for both studies was the proportion of patients achieving a complete clearance of ocular inflammation by Day 15 of the study.

The benefits of Prolensa were established by a statistically and clinically significantly higher rate of responders for patients with cleared ocular inflammation at Day 15 [46% with Prolensa versus (vs.) 13% to 28% with placebo], and a higher rate of responders for patients that were pain free at Day 1 (76% to 81% for Prolensa, vs. 44% to 56% for placebo). Various sensitivity analyses of the main efficacy endpoints provided evidence that the primary analyses were robust. Other secondary endpoints generally provided support to the main efficacy results. Furthermore, the rate of adverse events was significantly lower with Prolensa as compared to placebo.

Known risks of topical ophthalmic NSAIDs include corneal toxicity which is uncommon but may occur in some patients, especially when underlying corneal conditions exist. Increased bleeding time may lead to hemorrhage, especially in patients with bleeding tendencies or if other anticoagulant drugs are used concomitantly. Delayed wound healing, especially when NSAIDs are used with corticosteroids may also occur. These risks are adequately labelled in the Warnings and Precautions and Drug Interactions sections of the Prolensa Product Monograph.

A Risk Management Plan (RMP) for Prolensa was submitted by Bausch & Lomb 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.

A Look-alike Sound-alike brand name assessment was performed and the proposed name Prolensa has been deemed appropriate and acceptable.

Overall, the therapeutic benefits seen in the pivotal studies are positive and the benefits of Prolensa therapy are considered to outweigh the potential risks. Prolensa has an acceptable safety profile based on the non-clinical data and clinical studies. The identified safety issues can be managed through labelling. Appropriate warnings and precautions are in place in the Prolensa 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 Prolensa?

Submission Milestones: Prolensa

Submission MilestoneDate
Submission filed:2014-04-04
Screening
Screening Acceptance Letter issued:2014-05-31
Review
Quality Evaluation complete:2015-03-19
Clinical Evaluation complete:2015-03-25
Labelling Review complete:2015-03-25
Notice of Compliance issued by Director General:2015-03-26

The Canadian regulatory decision on the non-clinical and clinical review of Prolensa was based on a critical assessment of the Canadian data package. The foreign reviews completed by the United States Food and Drug Administration (FDA) were used as an added reference.

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

Bromfenac, the active ingredient of Prolensa, is a non-steroidal anti-inflammatory drug (NSAID). The mechanism of action is thought to be due to the drug's ability to block prostaglandin synthesis by inhibiting cyclooxygenase (COX) 1 and 2. Prostaglandins have been shown in many animal models to be mediators of certain kinds of intraocular inflammation.

Since Prolensa is for short-term topical ophthalmic administration, the assessment of bromfenac pharmacokinetics was minimal.

Ocular topical dosing (four times daily for 28 days in healthy human subjects) suggested that the bromfenac plasma concentration was very low (possibly ≤50 ng/mL). Therefore, systemic exposure following treatment with Prolensa is expected to be very low and of little clinical significance when Prolensa is used as directed. No major safety issues were detected after a 28-day topical ocular administration of 11 to 23 times the intended daily clinical dose for Prolensa. No other human pharmacology studies and no drug interaction studies were provided, however given the ophthalmic route of administration, this was found acceptable.

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

Clinical Efficacy

The clinical efficacy of Prolensa (bromfenac ophthalmic solution 0.07% w/v) was evaluated primarily in two similar multicentre, randomized, double-blinded, parallel-group and placebo (vehicle) -controlled, pivotal Phase III studies of identical design (Study 1 and Study 2). The efficacy of Prolensa was compared with placebo in the treatment of ocular inflammation and pain associated with cataract surgery.

Patients undergoing cataract surgery self-administered Prolensa or placebo once daily (QD), beginning 1 day prior to surgery, continuing on the morning of surgery and for 14 days after surgery. Complete clearance of anterior chamber (AC) inflammation was assessed on Days 1, 3, 8 and 15 post-surgery using slit lamp biomicroscopy. A pain score was self-reported.

The patient population included adults who required unilateral cataract surgery (phacoemulsification or extracapsular) with posterior chamber intraocular lens (PCIOL) implantation and for whom no other ophthalmic surgical procedures [for example (e.g), relaxing incisions, iridectomy, conjunctival excisions, et cetra (etc.)] were planned.

In the intent-to-treat (ITT) populations, a total of 440 patients were assessed. In Study 1, a total of 220 patients were randomized; 112 were treated with Prolensa, and 108 were treated with placebo. In Study 2, 110 were treated with Prolensa, and 110 were treated with placebo.

The primary efficacy endpoint for Study 1 and Study 2 was defined as the proportion of patients achieving a complete clearance of anterior ocular inflammation; that is, zero anterior chamber (AC) cell and no AC flare by Day 15 of the study. The main secondary efficacy endpoint (ocular pain) was determined by the proportion of patients who were pain free at Day 1.

Four analyses of efficacy were performed: an analysis of data based on last observation carried forward (LOCF), the primary efficacy analysis; an analysis of data based on observed cases (OC); an analysis of data based on baseline observation carried forward (BOCF); and an analysis based on multiple imputation. The latter three analyses were performed to assess the sensitivity of using different approaches for handling missing data.

Based on the primary efficacy endpoint of cleared inflammation using the ITT dataset with the last observation carried forward (LOCF) method, the responders' rate by Day 15 was statistically and clinically significantly higher with Prolensa (48% in Study 1, 49% in Study 2), as compared to placebo (17% in Study 1, and 32% in Study 2), for a difference between groups of 31% in Study 1 (p <0.0001), and 17% in Study 2 (p = 0.013). The treatment effect was apparent starting on Day 8.

The sensitivity analyses using the OC datasets captured only partially the benefit at Day 15 seen in the analysis using ITT/LOCF. The benefit of Prolensa was present in both studies at Day 8. The sensitivity analyses using BOCF datasets did not capture any of the differences between the treatment groups. This was likely due to the higher proportion of patients discontinuing the investigational product (IP) at Day 15 in the Prolensa group compared to the placebo group. Given that early IP discontinuation due to lack of efficacy was significantly more frequent with the placebo group (24%) as compared to the Prolensa group (3%), these sensitivity analyses were acceptable and were not considered to contradict the primary results using ITT with LOCF. In addition, two other sensitivity analyses for early study discontinuation, one assuming "treatment failures" and the other assuming "treatment success", supported the ITT/LOCF findings and their robustness.

One minor issue was noted in regard to the primary efficacy endpoint of cleared inflammation "at" each visit yielding results that were in line with the primary efficacy analysis "by" visit. Small differences were reported due to a few patients that may have had cleared inflammation before Day 15 but not at Day 15. This prompted Health Canada to use the results of the "at visit" primary efficacy analysis (ITT/LOCF) in the Prolensa Product Monograph. The "at visit" (or "at day") analyses are the most commonly used measures for this type of drug and condition. This did not change the overall results and efficacy conclusions.

Proportion of Patients with Cleared Ocular Inflammation (Intent-to-Treat Population with Last Observation Carried Forward)
Proportion of Patients with Cleared Ocular Inflammation (zero AC cells and no AC flare, the primary efficacy endpoint at Day 15)
Study Visit Bromfenac 0.07% Placebo Difference in rates
Study 1 At Day 8 27/112 (24.1%) 7/108 (6.5%) 17.6% (p = 0.001)
At Day 15 51/112 (45.5%) 14/108 (13.0%) 32.5% (p < 0.0001)
Study 2 At Day 8 33 /110 (30.0%) 15/110 (13.6%) 16.4% (p = 0.0259)
At Day 15 50/110 (45.5%) 31/110 (28.2%) 17.3% (p = 0.0466)

For the proposed indication, it was imperative that Prolensa be efficacious on both ocular inflammation and pain. The measure of ocular pain was the main secondary efficacy endpoint in the efficacy analysis. The proportion of patients that were pain free at Day 1 [that is (i.e.), pain grade of None at Day 1] in the ITT/LOCF analyses was statistically and clinically significantly larger in patients treated with Prolensa (81% in Study 1, and 76% in Study 2), as compared to those receiving placebo (44% in Study 1, and 56% in Study 2), for a statistically and clinically significant difference of 38% in Study 1 (p <0.0001), and 21% in Study 2 (p = 0.002). The difference in response rates was maintained at Day 3, Day 8, and to a lesser extent at Day 15. The results from the two sensitivity analyses, and the multiple imputations analysis for the pain endpoint were in line with those from the ITT/LOCF analysis or did not raise any significant issue.

Rescue medications (mostly prednisolone or Prolensa) were statistically significantly more likely used by those treated with placebo (34% to 44%) as compared to Prolensa (5% to17%), which lent support to the efficacy findings. Many other efficacy analyses were performed but did not add significant information to the assessment of efficacy beyond the results of the two main efficacy endpoints (and associated sensitivity analyses).

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

Clinical Safety

Two multicentre, randomized, double-blinded, parallel-group and placebo (vehicle) -controlled, pivotal Phase III studies of identical design (Study 1 and Study 2, described in the Clinical Efficacy section) evaluated the clinical safety of Prolensa. In the pooled studies, 212 patients received Prolensa alone and 204 received placebo once daily beginning one day prior to surgery, continuing on the day of surgery, and through the first 14 days post-surgery.

Drug compliance with Prolensa was acceptable (88% of patients had a compliance rate of ≥75%) and higher than that of patients with placebo (59% of patients had a compliance rate of ≥75%). In the pooled studies, the number of patients with adverse events (AEs), i.e., regardless of causal relationship to the drug, was higher with placebo (43%) as compared to Prolensa (29%). The rate of ocular AEs related to IP was also higher with placebo [21% versus (vs.) 7%].

Discontinuation of the IP due to adverse events (AEs) was reported in 14% of patients with placebo and 5% of patients with Prolensa. This difference may indirectly reflect the effects of Prolensa and outcomes of the surgery.

Most AEs were mild (18 to 19% in both groups), or moderate (17% with placebo and 8% with Prolensa). Severe AEs occurred in 7% of patients with placebo, and 3% of those with Prolensa. No particular severe AE occurred more frequently with Prolensa.

The ocular AEs related to IP most frequently reported were eye pain (2.8% with Prolensa vs. 7.8% with placebo), anterior chamber (AC) inflammation (2.4% vs. 5.4%), conjunctival hyperemia (0.9% vs. 3.9%), corneal edema (0.5% vs. 2.5%), increased lacrimation (0.5% vs. 2.5%), ocular hyperaemia (0 vs. 2.0%), foreign body sensation in eyes (0% vs. 2.5%), and photophobia (0.5% vs. 3.9%). For more details, see the Prolensa Product Monograph.

Systemic AEs were reported in approximately 6% of patients in each group, however none were considered to be related to the IP, except for headache (1 case with Prolensa and 2 with placebo). Some systemic AEs led to IP discontinuation but were not considered related to IP (e.g., hypoxia, myocardial infarction, high blood pressure, arrhythmia). Serious AEs were reported in 3 patients with Prolensa and 4 patients with placebo, all considered not related to the IP. No deaths were reported. Discontinuations due to AEs were significantly less frequent with Prolensa (5%) compared to placebo (14%), and were all considered not related to IP except for one case each of eyelid erythema/edema, uveitis, conjunctival hyperemia, and AC inflammation.

The mean intraocular pressure (IOP) in the Prolensa group was statistically significantly larger compared to the placebo group, but the differences were of modest magnitude (+ 1 to + 1.4 mmHg) and of little clinical relevance. Increases from baseline IOP ≥10 mmHg were recorded more frequently in patients treated with Prolensa [5.7%, number (n) = 12], as compared to those receiving placebo (2.5%, n = 5). This difference was only seen on Day 1, and not thereafter. Therefore, it was not a significant safety issue, and the sponsor was required to include this information in the Prolensa Product Monograph. Visual acuity (VA) change from baseline showed an average improvement of approximately 10 to 12 letters from baseline VA in both groups. Ocular comfort grades were in favour of Prolensa as compared to placebo. There was no evidence of a significant effect of age or gender on the AE profile of Prolensa as compared to placebo.

Based on the information provided, both of the two pivotal confirmatory clinical studies had an acceptable design and conduct, and Prolensa was shown to be efficacious with an acceptable safety profile in line with other topical ophthalmic NSAIDs in patients undergoing cataract surgery. Also, 20 other clinical studies used various ophthalmic solution formulations and concentrations, and the safety profile for the pooled bromfenac 0.09% QD studies in the post-surgery patients was in line with that seen in the pivotal Phase III studies for Prolensa.

Review of post-marketing data showed no findings that were unexpected for a topical ocular NSAID drug. Very rare cases of corneal effects (some of which serious and significant) were reported, however, corneal toxicity is a known and relatively uncommon potential effect of NSAIDs, and appropriate warnings are included in the Prolensa Product Monograph. The foreign post-marketing experience did not raise any specific significant issues at this time, and was therefore considered acceptable.

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

7.2 Non-Clinical Basis for Decision

A comprehensive non-clinical testing program was submitted. Based on the non-clinical data, there were no significant or unexpected safety issues that would prevent the approval of Prolensa for the specified indication.

In animal studies using ocular administration, there was no significant ocular toxicity (at up to 20-30 times the intended Prolensa dose) and only sporadic, often reversible, findings were reported.

Bromfenac, the active ingredient of Prolensa, did not affect fertility in rats or cause fetal malformations in rats or rabbits; however, there were post-implantation loss and reduced pup growth rates which might be associated with maternal toxicity (at 30 times the predicted human exposure with Prolensa). Furthermore, fetal cardiovascular toxicity is a known class effect for NSAIDs. This was labelled accordingly in the Prolensa Product Monograph regarding the use of Prolensa in pregnant or nursing women.

The results of the non-clinical studies as well as the potential risks to humans have been included in the Prolensa Product Monograph. In view of the intended use of Prolensa, there are no pharmacological/toxicological issues within this submission which preclude authorization of the product.

For more information, refer to the Prolensa 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 Prolensa 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. Changes to the manufacturing process and formulation made throughout the pharmaceutical development are considered acceptable upon review. Based on the stability data submitted, the proposed shelf-life is considered acceptable.

Proposed limits of drug-related impurities are considered adequately qualified; i.e. within International Conference on Harmonisation (ICH) limits and/or qualified from toxicological studies.

All sites involved in production are compliant with Good Manufacturing Practices.

All non-medicinal ingredients (excipients) found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations.

The drug substance bromfenac sodium sesquihydrate is free of Bovine Spongiform Encephalopathy (BSE)/Transmissible Spongiform Encephalopathy (TSE), as the active ingredient and excipients are not of animal origin.