Summary Basis of Decision for Grastofil

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 Grastofil is located below.

Recent Activity for Grastofil

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 Grastofil

Updated: 2024-05-31

The following table describes post-authorization activity for Grastofil, a product which contains the medicinal ingredient filgrastim. 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 found in Post-Authorization Activity Tables (PAATs).

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

Drug Identification Number (DIN):

  • DIN 02441489 - 300 mcg/0.5 mL, filgrastim, solution, subcutaneous or intravenous administration
  • DIN 02454548 - 480 mcg/0.8 mL, filgrastim, solution, subcutaneous or intravenous administration

Post-Authorization Activity Table (PAAT)

Activity/Submission Type, Control Number

Date Submitted

Decision and Date

Summary of Activities

SNDS # 273628

2023-03-23

Issued NOC 2023-08-04

Submission filed as a Level II – Supplement (Safety) to update the PM with new safety information and to revise typographical and formatting errors. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Adverse Reactions section of the PM, and corresponding changes were made to Part III: Patient Medication Information and to the package insert. An NOC was issued.

NC # 271405

2023-01-13

Issued NOL 2023-03-30

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change in the standard/monograph (i.e., specifications) claimed for the drug product. The submission was reviewed and considered acceptable, and an NOL was issued.

NC # 258724

2021-11-17

Issued NOL 2022-02-09

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change in the parameters of an approved holding step or addition of a new holding step and a change in the controls (in-process tests and/or acceptance criteria) applied during the drug substance manufacturing process or on intermediates. The submission was reviewed and considered acceptable, and an NOL was issued.

SNDS # 245830

2020-10-29

Issued NOC 2021-09-29

Submission filed as a Level I – Supplement to update the PM with new immunogenicity information from Study KWI-300-104, and migrate it to the 2020 format. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Adverse Reactions and Clinical Trials sections of the PM. An NOC was issued.

NC # 249976

2021-02-25

Issued NOL 2021-06-02

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change in the drug substance release or shelf-life specifications. The submission was reviewed and considered acceptable, and an NOL was issued.

SNDS # 232723

 

2019-10-18

Issued NOC 2019-12-27

Submission filed as a Level I – Supplement for labelling updates to the inner and outer labels, package insert, and PM due to changes in the needle guard. The submission was reviewed and considered acceptable, and an NOC was issued.

NC # 218803

2018-07-31

Issued NOL

2018-09-25

 

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for changes to the manufacture of the drug substance. The submission was reviewed and considered acceptable, and an NOL was issued.

NC # 219303

2018-08-17

Issued NOL

2018-06-18

 

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to change testing procedures for the drug substance. The submission was reviewed and considered acceptable, and an NOL was issued.

NC # 218311

2018-07-17

Issued NOL

2018-09-10

 

Submission filed as a Level II (90 day) Notifiable Change (Risk Management Change) to update the PM with new safety information. As a result of the NC, modifications were made to the, Warnings and Precautions, and Adverse Reactions sections 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.

SNDS # 211537

2017-11-22

Issued NOC

2018-02-02

 

Submission filed as a Level I – Supplement to update the labelling. The submission was reviewed and considered acceptable, and an NOC was issued.

NC # 210933

2017-11-02

Issued NOL

2018-01-11

 

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for changes related to the release tests for the drug substance and drug product.

SNDS # 208012

2017-07-31

Issued NOC

2017-10-05

 

Submission filed as a Level I – Supplement to update the PM, the package insert, and blister labels. The submission was reviewed and considered acceptable, and an NOC was issued.

Drug product (DIN 02454548) market notification

Not applicable

Date of first sale:

2016-11-28

The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.

SNDS # 186164

2015-07-23

Issued NOC

2016-10-07

 

Submission filed as a Level I – Supplement for the addition of a new single dose presentation. The information was reviewed and considered acceptable. Revisions were made to the PM and package insert and were deemed acceptable. A new DIN (02454548) was issued for the new presentation (480 µg/0.8 mL). An NOC was issued.

Drug product (DIN 02441489) market notification

Not applicable

Date of first sale: 2016/03/17

The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.

SNDS # 189384

2015/11/16

Issued NOC 2016/01/18

Submission filed as a Level I - Supplement (labelling only) for a redesigned blister pack configuration. Revisions to the Product Monograph Part III: Patient Medication Information were submitted, to provide the consumer with information related to the use of the blister packs.

NDS # 156897

2012/07/16

Issued NOC 2015/12/07

Notice of Compliance issued for New Drug Submission.

Summary Basis of Decision (SBD) for Grastofil

Date SBD issued: 2016-04-27

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

Filgrastim, 300 µg/0.5 mL, solution, subcutaneous or intravenous

Drug Identification Number (DIN):

  • DIN 02441489 - 300 µg/0.5 mL, filgrastim, solution, subcutaneous or intravenous
  • DIN 02454548 - 480 µg/0.8 mL, filgrastim, solution, subcutaneous or intravenous

Apotex Inc.

New Drug Submission Control Number: 156897

 

On December 7, 2015 Health Canada issued a Notice of Compliance to Apotex Inc. for the drug product Grastofil.

Grastofil was filed as a Subsequent Entry Biologic product to the Canadian authorized product, Neupogen. The term “subsequent entry biologic” is used by Health Canada to describe a biologic drug that enters the market subsequent to a version previously authorized in Canada, with demonstrated similarity to a reference biologic drug. In this drug submission, Neupogen is the reference product. Similarity between Grastofil and Neupogen was established in accordance with the Guidance for Sponsors: Information and Submission Requirements for Subsequent Entry Biologics (SEBs), for the authorized indications.

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 Grastofil is favourable for the following:

  • Cancer Patients Receiving Myelosuppressive Chemotherapy

Grastofil (filgrastim) is indicated to decrease the incidence of infection, as manifested by febrile neutropenia, in patients with non-myeloid malignancies receiving myelosuppressive anti-neoplastic drugs.

Grastofil is indicated in adult and pediatric patients with cancer receiving myelosuppressive chemotherapy.

A complete blood count (CBC) and platelet count should be obtained prior to chemotherapy and twice per week during Grastofil therapy to avoid leukocytosis and to monitor the neutrophil count. In Phase III clinical studies, filgrastim therapy was discontinued when the absolute neutrophil count (ANC) was >10 × 109/L after expected chemotherapy-induced nadir.

  • Patients with Acute Myeloid Leukemia

Grastofil is indicated for the reduction in the duration of neutropenia, fever, antibiotic use and hospitalization, following induction and consolidation treatment for acute myeloid leukemia.

  • Cancer Patients Receiving Myeloablative Chemotherapy Followed by Bone Marrow Transplantation

Grastofil is indicated to reduce the duration of neutropenia and neutropenia-related clinical sequelae (for example [e.g.] febrile neutropenia) in patients undergoing myeloablative therapy followed by bone marrow transplantation.

A CBC and platelet count should be obtained at a minimum of three times per week following marrow infusion to monitor marrow reconstitution.

  • Cancer Patients Undergoing Peripheral Blood Progenitor Cell (PBPC) Collection and Therapy

Grastofil is indicated for the mobilization of autologous peripheral blood progenitor cells in order to accelerate haematopoietic recovery by infusion of such cells, supported by filgrastim after myelosuppressive or myeloablative chemotherapy.

  • Patients with Severe Chronic Neutropenia (SCN)

Grastofil is indicated for chronic administration to increase neutrophil counts and to reduce the incidence and duration of infection in patients with a diagnosis of congenital, cyclic or idiopathic neutropenia.

  • Patients with HIV Infection

Grastofil is indicated in patients with human immunodeficiency virus (HIV) infection for the prevention and treatment of neutropenia, to maintain a normal ANC (e.g. between 2 × 109 and 10 × 109/L).

Grastofil therapy reduces the clinical sequelae associated with neutropenia (e.g. bacterial infections) and increases the ability to deliver myelosuppressive medications used for the treatment of HIV and its associated complications. It is recommended that complete blood counts and platelet counts be monitored at regular intervals (e.g. initially twice weekly for two weeks, once weekly for an additional two weeks, then once monthly thereafter, or as clinically indicated) during Grastofil  therapy.

 

1 What was approved?

 

Grastofil, a hematopoietic agent (granulocyte colony stimulating factor), was authorized for:

  • Cancer Patients Receiving Myelosuppressive Chemotherapy

Grastofil (filgrastim) is indicated to decrease the incidence of infection, as manifested by febrile neutropenia, in patients with non-myeloid malignancies receiving myelosuppressive anti-neoplastic drugs.

Grastofil is indicated in adult and pediatric patients with cancer receiving myelosuppressive chemotherapy.

A complete blood count (CBC) and platelet count should be obtained prior to chemotherapy and twice per week during Grastofil therapy to avoid leukocytosis and to monitor the neutrophil count. In Phase III clinical studies, filgrastim therapy was discontinued when the absolute neutrophil count (ANC) was >10 × 109/L after expected chemotherapy‑induced nadir.

  • Patients with Acute Myeloid Leukemia

Grastofil is indicated for the reduction in the duration of neutropenia, fever, antibiotic use and hospitalization, following induction and consolidation treatment for acute myeloid leukemia.

  • Cancer Patients Receiving Myeloablative Chemotherapy Followed by Bone Marrow Transplantation

Grastofil is indicated to reduce the duration of neutropenia and neutropenia-related clinical sequelae [for example (e.g.) febrile neutropenia] in patients undergoing myeloablative therapy followed by bone marrow transplantation.

A complete blood count (CBC) and platelet count should be obtained at a minimum of three times per week following marrow infusion to monitor marrow reconstitution.

  • Cancer Patients Undergoing Peripheral Blood Progenitor Cell (PBPC) Collection and Therapy

Grastofil is indicated for the mobilization of autologous peripheral blood progenitor cells in order to accelerate haematopoietic recovery by infusion of such cells, supported by filgrastim after myelosuppressive or myeloablative chemotherapy.

  • Patients with Severe Chronic Neutropenia (SCN)

Grastofil is indicated for chronic administration to increase neutrophil counts and to reduce the incidence and duration of infection in patients with a diagnosis of congenital, cyclic or idiopathic neutropenia.

  • Patients with HIV Infection

Grastofil is indicated in patients with HIV infection for the prevention and treatment of neutropenia, to maintain a normal absolute neutrophil count (ANC) (e.g., between 2 × 109 and 10 × 109/L).

Grastofil therapy reduces the clinical sequelae associated with neutropenia (e.g. bacterial infections) and increases the ability to deliver myelosuppressive medications used for the treatment of human immunodeficiency virus (HIV) and its associated complications. It is recommended that complete blood counts and platelet counts be monitored at regular intervals (e.g., initially twice weekly for two weeks, once weekly for an additional two weeks, then once monthly thereafter, or as clinically indicated) during Grastofil  therapy.

The safety and efficacy of Grastofil have not been established in geriatric patients.

The safety and efficacy of Grastofil have not been established in pediatric patients. The only data available in pediatric patients are the results of studies conducted with the reference product Neupogen.

Grastofil is contraindicated in patients with known hypersensitivity to Escherichia coli (E. coli) derived products, filgrastim, pegfilgrastim, or to any component of the product. Grastofil was approved for use under the conditions stated in the Grastofil Product Monograph taking into consideration the potential risks associated with the administration of this drug product.

Grastofil (300 µg/0.5 mL, filgrastim) is presented as a single-use pre-filled graduated syringe for either subcutaneous or intravenous administration. In addition to the medicinal ingredient filgrastim, the solution also contains the following non-medicinal ingredients: acetate, sodium, sorbitol (E420), polysorbate 80, 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 Grastofil Product Monograph, approved by Health Canada and available through the Drug Product Database.

 

2 Why was Grastofil approved?

 

Health Canada considers that the benefit/risk profile of Grastofil is favourable for:

  • Cancer Patients Receiving Myelosuppressive Chemotherapy

Grastofil (filgrastim) is indicated to decrease the incidence of infection, as manifested by febrile neutropenia, in patients with non-myeloid malignancies receiving myelosuppressive anti-neoplastic drugs.

Grastofil is indicated in adult and pediatric patients with cancer receiving myelosuppressive chemotherapy.

A complete blood count (CBC) and platelet count should be obtained prior to chemotherapy and twice per week during Grastofil therapy to avoid leukocytosis and to monitor the neutrophil count. In Phase III clinical studies, filgrastim therapy was discontinued when the absolute neutrophil count (ANC) was >10 × 109/L after expected chemotherapy-induced nadir.

  • Patients with Acute Myeloid Leukemia

Grastofil is indicated for the reduction in the duration of neutropenia, fever, antibiotic use and hospitalization, following induction and consolidation treatment for acute myeloid leukemia.

  • Cancer Patients Receiving Myeloablative Chemotherapy Followed by Bone Marrow Transplantation

Grastofil is indicated to reduce the duration of neutropenia and neutropenia-related clinical sequelae [for example (e.g.) febrile neutropenia] in patients undergoing myeloablative therapy followed by bone marrow transplantation.

A CBC and platelet count should be obtained at a minimum of three times per week following marrow infusion to monitor marrow reconstitution.

  • Cancer Patients Undergoing Peripheral Blood Progenitor Cell (PBPC) Collection and Therapy

Grastofil is indicated for the mobilization of autologous peripheral blood progenitor cells in order to accelerate haematopoietic recovery by infusion of such cells, supported by filgrastim after myelosuppressive or myeloablative chemotherapy.

  • Patients with Severe Chronic Neutropenia (SCN)

Grastofil is indicated for chronic administration to increase neutrophil counts and to reduce the incidence and duration of infection in patients with a diagnosis of congenital, cyclic or idiopathic neutropenia.

  • Patients with HIV Infection

Grastofil is indicated in patients with human immunodeficiency virus (HIV) infection for the prevention and treatment of neutropenia, to maintain a normal ANC (e.g. between 2 × 109 and 10 × 109/L).

Grastofil therapy reduces the clinical sequelae associated with neutropenia (e.g. bacterial infections) and increases the ability to deliver myelosuppressive medications used for the treatment of HIV and its associated complications. It is recommended that complete blood counts and platelet counts be monitored at regular intervals (e.g. initially twice weekly for 2 weeks, once weekly for an additional 2 weeks, then once monthly thereafter, or as clinically indicated) during Grastofil therapy.

Grastofil is a subsequent entry biologic (SEB) product that is a recombinant methionyl human granulocyte colony stimulating factor (r-metHuG-CSF) produced by recombinant deoxyribonucleic acid (DNA) technology. Grastofil is comparable to the Canadian authorized drug product Neupogen (active ingredient filgrastim, marketed by Amgen Canada Inc.). Grastofil was filed as a SEB to Neupogen. Similarity between Grastofil and Neupogen was established in accordance with the Guidance for Sponsors: Information and Submission Requirements for Subsequent Entry Biologics (SEBs), for the indications stated above.

The sponsor requested authorization for all of the indications and uses currently authorized to Neupogen. Neupogen is currently authorized for indications and uses in cancer patients undergoing either myelosuppressive chemotherapy, or myeloblative chemotherapy followed by bone marrow transplantation, or peripheral blood progenitor cell collection and therapy. Neupogen is also currently authorized for use in patients with either severe chronic neutropenia, or acute myeloid leukemia, or with HIV infection. Comparability between Grastofil and the reference product was established based on comparative chemistry and manufacturing studies, comparative non-clinical studies, comparative pharmacokinetic (PK) and pharmacodynamics (PD) studies.

The indications were authorized on the basis of demonstrated analytically high similarity; the same final formulation between Grastofil and the reference product; understanding of mechanism of action; demonstrated comparability of pharmacokinetic/pharmacodynamic (PK/PD) parameters in healthy volunteers between Grastofil and the reference; consistency in safety profile with the reference product; and demonstrated linearity with subcutaneous (SC) route of administration and the clinical experience with the reference product with dose range used for both intravenous (IV) and SC routes of administration cross all indications. From all above, the doses and routes of administration for which the Canadian reference product are licensed were granted to Grastofil with proper product labelling and adequate post market long term safety monitoring in large real world patient populations.

Grastofil has been shown to be comparable to the reference product based on three comparative pharmacokinetic/pharmacodynamics Phase I studies (KWI-300-101, KWI-300-102, and KWI-300-103) conducted in 187 healthy volunteers of which 144 subjects received Grastofil. In addition, a non‑comparative single arm safety study in breast cancer patients (KWI-300-104) was conducted in patients with Stage IIA, IIB, or IIIA breast cancer, undergoing taxotere adriamycin cyclophosphamide (TAC) chemotherapy treatment in an adjuvant setting of which 120 patients received Grastofil. In equivalence trials in healthy volunteers, Grastofil was demonstrated to be comparable to Neupogen with respect to its pharmacodynamic effect on ANC following administration.

The safety profile of Grastofil was consistent with that previously reported for the reference product, Neupogen. The most frequently reported ≥5% treatment-emergent adverse events (TEAEs) observed with Grastofil treatment included neck pain, back pain, abdominal pain, pharyngolaryngeal pain, nasopharyngitis, rhinitis, diarrhea, headache, myalgia, fatigue, and injection site hematoma. However, given the reduced package submitted which is consistent to all filings of SEB submission, the assessment of long‑term safety is limited. Therefore, post‑market monitoring of Grastofil for long‑term safety in large patient populations will still be required.

Splenic ruptures, including fatal cases have been reported following the administration of the reference product Neupogen. Severe sickle cell crisis, in some cases resulting in death, have also been associated with the use of Neupogen in patients with sickle cell disorders. As such, these incidences have been included in a Serious Warnings and Precautions Box in the Product Monograph for Grastofil.

A Risk Management Plan (RMP) for Grastofil was submitted by Apotex 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 Grastofil has been deemed acceptable.

Overall, in clinical trials, Grastofil showed an acceptable safety profile which is consistent with the known safety profile of the reference product Neupogen. Comparability in pharmacokinetic/pharmacodynamic (PK/PD) parameters between Grastofil and the reference product has been demonstrated in healthy volunteer studies. Overall benefit of Grastofil therapy is considered to outweigh its risks. The identified safety issues can be managed through labelling and adequate monitoring. Appropriate warnings and precautions are in place in the Grastofil Product Monograph and the RMP.

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 Grastofil?

 

A New Drug Submission (NDS) for Grastofil was filed with Health Canada on July 16, 2012. During the screening of the Grastofil submission, deficiencies were noted in the clinical data package and therefore a Screening Deficiency Notice (SDN) was issued September 7, 2012. In the SDN the sponsor was requested to provide data (or a detailed rationale in the absence of data) to support the extrapolation of all the indications listed in the proposed Product Monograph for Grastofil; and to provide data (bridging) to demonstrate the similarity between the non‑Canadian reference product and the Canadian Product. A satisfactory response to the SDN was received October 1, 2012, and the screening acceptance letter was issued the same day. The clinical review of this submission was initiated on December 14, 2012. A team meeting was held on February 7, 2013, to discuss issues with the submission, mainly, the lack of data to bridge noticeable differences in concentration and presentation between the non-Canadian reference product and the Canadian marketed product. A Notice of Deficiency (NOD) was issued on June 17, 2013 to the sponsor. A clarification meeting was held upon request of the sponsor to further discuss the NOD issues. A response to the NOD was received on June 2, 2014 from the sponsor. On January 28, 2015, the reference product, Neupogen was authorized for a new concentration and presentation in Canada. The bridging data between the non-Canadian reference product and the Canadian product were no longer required. This new regulatory authorization to the reference product along with the satisfactory response to address all other clinical deficiencies; a Notice of Compliance (NOC) for Grastofil was issued to the sponsor on December 7, 2015

 

Submission Milestones: Grastofil

Submission Milestone Date
Submission filed: 2012-07-16
Screening 1  
Screening Deficiency Notice issued: 2012-09-07
Response filed: 2012-10-02
Screening Acceptance Letter issued: 2012-10-31
Review 1  
Quality Evaluation complete: 2013-06-14
Clinical Evaluation complete: 2013-06-14
Notice of Deficiency (NOD) issued by Director, General, Biologics and Genetic Therapies Directorate (quality issues): 2013-06-17
Response filed: 2014-06-02
Screening 2  
Screening Acceptance Letter issued: 2014-07-25
Review 2  
On-Site Evaluation: 2015-01-27 - 2015-02-03
Quality Evaluation complete: 2015-04-10
Clinical Evaluation complete: 2015-05-20
Biostatics Evaluation complete: 2015-05-10
Labelling Review complete: 2015-05-20
Notice of Compliance issued by Director General, General, Biologics and Genetic Therapies Directorate: 2015-12-07

 

The Canadian regulatory decision on the non-clinical and clinical review of Grastofil was based on a critical assessment of the Canadian data package. In addition, a review communication from the European Medicines Agency (EMA) was 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

 

Grastofil was filed as a Subsequent Entry Biologic (SEB) to the Canadian authorized product, Neupogen.

Three comparability pharmacokinetic/pharmacodynamic (PK/PD) studies in healthy volunteers and a non-comparability single arm safety study in patients with breast cancer were submitted for review.

A critical review was conducted based on the totality of the data submitted. A justification was made which suggests that Grastofil be qualified as an SEB to the Canadian marketed Neupogen based on the following:

  • analytically high similarity and the same final formulation have been demonstrated between Grastofil and the reference product;
  • mechanism of action of granulocyte‑colony stimulating factor (G-CSF) is understood;
  • comparability of PK/PD parameters in healthy volunteers has been demonstrated between Grastofil and the reference product;
  • safety profile of Grastofil is in general consistent with the reference product Neupogen.

Grastofil was filed as a Subsequent Entry Biologic (SEB) to the Canadian authorized product, Neupogen.

Three comparability pharmacokinetic/pharmacodynamic (PK/PD) studies in healthy volunteers and a non-comparability single arm safety study in patients with breast cancer were submitted for review.

A critical review was conducted based on the totality of the data submitted. A justification was made which suggests that Grastofil be qualified as an SEB to the Canadian marketed Neupogen based on the following:

  • analytically high similarity and the same final formulation have been demonstrated between Grastofil and the reference product;
  • mechanism of action of granulocyte colony stimulating factor (G-CSF) is understood;
  • comparability of PK/PD parameters in healthy volunteers has been demonstrated between Grastofil and the reference product;
  • safety profile of Grastofil is in general consistent with the reference product Neupogen.

In addition, based on the demonstrated linearity of the reference product with SC route of administration, and the clinical experience with the reference product with dose range used for  both IV and SC routes of administration cross all indications, doses and routes of administration for which the Canadian reference product are licensed could be considered to be granted to Grastofil with proper product labelling and adequate post market long term safety monitoring in large real world patient populations.

The safety profile of Grastofil is in general, consistent with the known safety profiles of the reference product Neupogen. No new significant safety signals have been observed in healthy volunteers or in breast cancer patients from Grastofil clinical studies. However, long term safety data and safety profile (such as immunogenicity) in different and large patient populations are not available.

Clinical Pharmacology

Filgrastim (the medicinal ingredient in Grastofil) is a human G-CSF produced by recombinant deoxyribonucleic acid (DNA) technology. Granulocyte colony stimulating factor regulates the production of white blood cells. Grastofil stimulates the blood system through the bone marrow to produce white blood cells. Grastofil is used to treat neutropenia, a condition where the body makes too few white blood cells. Neutropenia may be a long‑standing condition where your body does not make enough white blood cells, or it may be caused by drugs used to treat cancer.

Pharmacokinetic/Pharmacodynamic Phase I Studies

Similarity of Grastofil (test product) to that of Neupogen (reference product) was assessed on the basis of the conventional 90% confidence intervals (CIs) for the test/reference ratio in the linear scale from the statistical analysis of the log-transformed area under the concentration‑time curve (AUCT) and maximum plasma concentration (Cmax) parameters for pharmacokinetic (PK).

The first study, KWI-300-101, purported to show biosimilarity between the European reference Neupogen and the test product at a dose of 5 µg/kg body weight, administered by intravenous (IV) infusion. However, when the dose is infused by IV, the rationale for biocomparability depends solely on a mechanical process which does not reflect any biological or chemical properties of the drug or formulation. The second study, KWI‑300-102, administered the dose by subcutaneous (SC) injection, with two cohorts, each at a fixed dose of either 75 µg or 150 µg. Administration via the SC route involves an in vivo absorption process which would reflect the drug’s biological and chemical properties and places any comparability with the reference drug on firmer theoretical grounds. The third study, KWI-300-103, also used the SC route and compared the test and reference products with daily SC injections over a four day period, in the context of a bioequivalence trial.

The comparability between Grastofil and the reference product was demonstrated. Pharmacokinetic parameters (plasma AUCT, Cmax, and terminal half-life [T1/2]) were comparable between Grastofil and the reference product with single or repeat dose SC administration as shown in the Table 1 below, taken from the Grastofil Product Monograph.

Table 1: Pharmacokinetic Parameters, Mean (Standard Deviation)
Single dose IV 5 µg/kg Grastofil (n = 35) Neupogen
(n = 35)
Ratio of Geometric Meana(%) 90% CI (%)

 

a

The ratio of geometric means is the ratio (Grastofil/Neupogen) of the inverse transformation of the least square means.

AUCT (min*ng/mL) 22,047 (4,060) 24,341 (4,530) 90.6 N/A
Cmax
(ng/mL)
103 (15) 112 (16) 92.5 N/A
T1/2
(min)
410 (84) 388 (113) N/A N/A
Clearance
(mL/min)
16.4 (4.1) 14.9 (3.7) N/A N/A
Volume of Distribution
(mL)
9,875 (4,003) 8,575 (4,241) N/A N/A
Single dose cross-over SC 150 µg Grastofil (n = 35) Neupogen (n = 35) Ratio of Geometric Mean (%) 90% CI (%)
AUCT (min*ng/mL) 3,276 (920) 3,415 (1,094) 96.8 91.0 – 103.0
Cmax
(ng/mL)
7.72 (2.35) 8.35 (3.05) 94.6 N/A
T1/2
(min)
519 (154) 551 (197) N/A N/A
Four daily SC 5 µg/kg Grastofil (n = 35) Neupogen (n = 34) Ratio of Geometric Mean (%) 90% CI (%)
AUCT (min*ng/mL) 11,735 (2,737) 11,839 (3,292) 100.2 90.3 – 111.1
Cmax
(ng/mL)
25.9 (7.0) 25.5 (7.8) 102.2 N/A
T1/2
(min)
216 (48) 207 (39) N/A N/A

Absolute neutrophil count (ANC) as the relevant PD marker for the activity of G-CSF were found comparable between Grastofil and the reference product as shown in Table 2 below, taken from the Grastofil Product Monograph.

Table 2: Pharmacodynamic Parameters, Mean (Standard Deviation)
Single dose IV 5 µg/kg Grastofil (n = 35) Neupogen
(n = 35)
Ratio of Geometric Mean(%) 95% CI (%)
ANC AUCT (cells × 109/L*min) 46,137 (8,608) 46,602 (9,322) 99.1 94.8 – 103.7
ANC Cmax
(cells × 109/L)
19.0 (4.4) 19.3 (5.2) 99.5 92.5 - 107.1
Single dose cross-over SC 150 µg Grastofil (n = 35) Neupogen (n = 35) Ratio of Geometric Mean (%) 95% CI (%)
ANC AUCT (cells × 109/L*min) 43,209 (7,922) 43,980 (6,866) 97.7 92.97 – 102.64
ANC Cmax
(cells × 109/L)
19.0 (3.8) 19.6 (3.3) 96.3 91.02 – 101.93
Single dose cross-over SC 75 µg Grastofil (n = 35) Neupogen (n = 35) Ratio of Geometric Mean (%) 95% CI (%)
ANC AUCT (cells × 109/L*min) 35,077 (6,526) 37,010 (7,623) 95.0 91.1 – 99.0
ANC Cmax
(cells × 109/L)
17.1 (3.7) 18.6 (4.1) 92.0 87.1 – 97.1
Four daily SC 5 µg/kg all Day 1 Grastofil (n = 35) Neupogen (n = 34) Ratio of Geometric Mean (%) 95% CI (%)
ANC AUCT (cells × 109/L*min) 114,232 (19,346) 119,436 (20,700) 95.6 88.0 – 103.8
ANC Cmax
(cells × 109/L)
30.5 (6.2) 32.3 (7.7) 95.2 85.8 – 105.6
Drug-Drug Interactions

No formal drug‑drug interaction studies were performed with Grastofil. Based on the information published for the reference product Neupogen, Grastofil must not be administered from 24 hours before to 24 hours after chemotherapy since concomitant chemotherapy administration may potentiate neutropenia. Lithium, which promotes the release of neutrophils, may potentiate the effects of Grastofil.

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

Clinical Efficacy

Similarity between Grastofil and Neupogen (reference product) was demonstrated with equivalent trials based on three randomized comparative PK/PD Phase I studies (KWI‑300-101, KWI‑300‑102, and KWI‑300-103) previously described in the Clinical Pharmacology section above. In addition to these three PK/PD studies, safety of Grastofil was also assessed in a single-arm, multicenter, repeat dose, non‑comparative safety study (KWI-300-104) conducted in breast cancer patients.

KWI-300-104 was a single-arm, multicenter, repeat dose safety study of Grastofil (5 μg/kg/day, subcutaneous) in female patients, with stage IIA, IIB or IIIA breast cancer receiving taxotere adriamycin cyclophosphamide (TAC) chemotherapy (docetaxel 75 mg/m2 IV, doxorubicin 50 mg/m2 IV, and cyclophosphamide 500 mg/m2 IV) known to induce neutropenia. The study consisted of three treatment periods: screening (up to 3 weeks), treatment period (6 cycles, 3 weeks between each treatment cycle) and safety follow-up period (up to 30 weeks following completion of TAC chemotherapy). During the treatment period, treatment with Grastofil began on day 2 of every chemotherapy cycle (at least 24 hours after chemotherapy) and was continued up to 14 days or until post-nadir absolute neutrophil count (ANC) recovery to normal or near-normal values by laboratory standards, whichever occurred first.

The patient population consisted of 120 Caucasian female patients with a mean age of 49.97 (Standard Deviation: 9.52) and range of 28 to 68 years , with stage IIA, IIB or IIIA breast cancer without neoadjuvant chemotherapy for this breast cancer. There were 39 (32.50%) patients at tumour stage IIA, 44 (36.67%) at stage IIB and 37 (30.83%) at stage IIIA. All patients were chemotherapy naïve and 22 (18.3%) patients had prior radiotherapy. The mean body weight was 71.1 kg), mean body height was 163.4 cm and mean body mass index (BMI) was 26.7 kg/m2).

In study KWI-300-104, 120 subjects were dosed. Overall, 113 patients (94.17%) completed the treatment period, 109 (90.83%) completed the Safety Follow-up period and 11 patients (9.17%) prematurely discontinued the study.

Safety findings were in general consistent with what had been observed with the reference product. The most frequently reported adverse event (AE) was bone pain. Ten serious AEs reported during the treatment and follow-up periods were considered unrelated to Grastofil. Two patients died during the follow-up period due to brain metastases and disease progression. Among the 57 severe AEs considered possibly, probably and definitely related, there were 56 bone pain reports and one abnormal injection site reaction. There were no signs of immunogenicity either detected by the laboratory or by clinical observation. Less frequent, however potentially more serious reactions reported in clinical studies of filgrastim, such as splenic rupture, severe sickle cell crisis, respiratory distress syndrome and Sweet’s syndrome, were not reported in this study. However, the study was powered to detect adverse events occurring with a frequency of more than 3%, and was not powered to detect adverse events that occur with less frequency. 

Overall Analysis of Efficacy

The data provided in this submission supports the biosimilarity of Grastofil and Neupogen. Based on the data package provided, Grastofil was shown to be efficacious and is considered to have a positive benefit‑risk ratio, similar to that of Neupogen. For more information, refer to the Grastofil Product Monograph, approved by Health Canada and available through the Drug Product Database.

Clinical Safety

The clinical safety of Grastofil was primarily evaluated based on a pooled analysis derived from the three comparative single‑centre Phase I studies in healthy volunteers and one non‑comparative multicentre study in patients with breast cancer previously described in the Clinical Pharmacology and Clinical Efficacy sections, respectively. Standard safety assessments within these studies included treatment emergent adverse events (TEAEs), laboratory parameters, physical examinations, and vital signs assessment.

Adverse Drug Reaction Overview
Pharmacokinetic/Pharmacodynamic Phase I Studies

Of the 144 subjects exposed to filgrastim across the three pharmacokinetic/ pharmacodynamic studies (KWI‑300-101, KWI‑300‑102, and KWI‑300-103), 75 (52.04%) experienced TEAEs, and 50 (34.72%) had at least one possibly drug-related TEAE. Six subjects (4.17%) experienced TEAEs of severe intensity, but no serious TEAEs occurred. No TEAEs resulted in withdrawal of study subjects and no deaths occurred. Most common TEAEs under Grastofil treatment were headache, back pain, and rhinitis. Incidence of severe TEAEs was numerically higher in the Grastofil arm (4.17%) versus (vs.) Neupogen (1.39%). Incidence of gastrointestinal TEAEs (diarrhea, abdominal pain and nausea) was numerically higher in the Grastofil arm. The incidence of  study drug‑related or possibly drug related TEAEs included back pain, fatigue, arthralgia, feeling hot, neck pain, bone pain, dyspnea, and pyrexia were found to be similar between Grastofil and Neupogen. It is noted that in the repeated dose study (Study KWI-300-103, 5 μg/kg/day SC for 4 days), incidence of back pain was numerically higher in the Grastofil arm than in the Neupogen arm (20% vs. 14.4%).

Clinical Study KWI‑300‑104 in Breast Cancer

There were 1,216 TEAEs reported during the course of the KWI‑300‑104 study, with 964 (79.28%) assessed as not related to filgrastim. The most frequently reported AE was bone pain, with a total of 267 events reported in 80 (66.67%) patients. It was described as mild in 105 (39.33%), moderate in 99 (37.08%) and severe in 63 (23.60%) cases. Nine patients reported 10 serious adverse events (SAEs). All 10 SAEs reported during the treatment and follow-up periods were considered unrelated to filgrastim. Two patients (1.67%) died during the follow-up period due to brain metastasis and disease progression. There were 99 severe AEs, 42 of which were considered not related, 5 possibly, 30 probably and 22 definitely related to filgrastim. Among the 57 severe AEs considered possibly, probably and definitely related, there were 56 bone pain reports and 1 abnormal injection site reaction (ISR).

Antibodies were detected on the screening antibody assay in 4 patients. None of the samples were confirmed as positive on the confirmatory assay. Neutralization assay was not performed as no positive samples were detected. No samples tested positive for anti‑GCSF antibodies on the confirmatory antibody assay. 

Less frequent, however potentially more serious reactions reported in clinical studies of filgrastim, such as splenic rupture, severe sickle cell crisis, respiratory distress syndrome and Sweet’s syndrome, were not reported in this study. Nevertheless, the study was powered to detect adverse events occurring with a frequency of more than 3%, and was not powered to detect adverse events that occur with less frequency.

There were 93 abnormal ECG findings in 48 (40.00%) patients over the course of the study. Two of the findings were assessed as clinically significant (supraventricular/ventricular extrasystoles and cardiomyopathy). Both of these findings were reported as clinically significant following completion of study treatment at week 20, and both were assessed as unrelated to the study drug. Prolongation of QTc interval above 500 msec was observed in 3 patients following filgrastim treatment, at cycle 4 (n = 1), week 20 (n = 1) and week 21 (n = 1).

Specific Safety Issues

Pharmacological class effects related to granulocyte colony stimulating factor (G-CSF) include spleen enlargement/splenic rupture, sickle cell crisis, acute respiratory distress syndrome (ARDS), and capillary leak syndrome (CLS).

Spleen Enlargement/Rupture

Rare cases of splenic rupture have been reported following the administration of filgrastim. In the healthy volunteer studies, no subject was reported to experience spleen enlargement or splenic rupture. In the breast cancer study with Grastofil, one patient did report spleen pain in his patient diary. However, according to the investigator, no clinical sign of splenomegaly could be detected after physical examination or in the computed tomography (CT) scan performed few months later. Yet, splenic ruptures, including fatal cases have been reported following the administration of filgrastim. Therefore, a Black Box Warning identifying this risk has been included under the Serious Warnings and Precautions section of the Grastofil Product Monograph. Patients receiving Grastofil who report left upper abdominal and/or shoulder tip pain should be evaluated for an enlarged spleen or splenic rupture.

Sickle Cell Disorders

Severe sickle cell crisis, in some cases resulting in death, have been associated with the administration of filgrastim in patients with sickle cell disorders. Given this risk, a Black Box Warning has also been included under the Serious Warnings and Precautions section of the Grastofil Product Monograph to highlight this risk. In addition, only physicians qualified by specialized training or experience in the treatment of patients with sickle cell trait and sickle cell disease should prescribe Grastofil for such patients, and only after careful consideration of the potential risks and benefits.

Acute Respiratory Distress Syndrome

Acute respiratory distress syndrome (ARDS) has been reported in patients receiving filgrastim and is postulated to be secondary to an influx of neutrophils to sites of inflammation in the lungs. Patients receiving Grastofil treatment who develop fever, lung infiltrates, or respiratory distress should be evaluated for the possibility of ARDS.

Alveolar hemorrhage manifesting as pulmonary infiltrates and hemoptysis requiring hospitalization has been reported in healthy donors undergoing peripheral blood progenitor cell (PBPC) mobilization. Hemoptysis resolved with discontinuation of Grastofil. The use of Grastofil for PBPC mobilization in healthy donors is not an approved indication.

Capillary Leak Syndrome

Capillary Leak Syndrome (CLS) has been reported after the administration of filgrastim. Capillary Leak Syndrome may cause circulatory shock and may be fatal, and is characterized by hypotension, hypoalbuminemia, edema, and hemoconcentration. Episodes vary in frequency, severity, and maybe life-threatening if treatment is delayed. Patients who develop symptoms of capillary leak syndrome should be closely monitored and receive treatment, which may include a need for intensive care.

Safety Issues of Interest
Simultaneous Use with Chemotherapy

The safety and efficacy of Grastofil given simultaneously with cytotoxic chemotherapy have not been established. Studies in adult patients showed that an interaction between concurrent filgrastim and 5-fluorouracil (5-FU) is possible and can result in a paradoxical fall in the absolute neutrophil count. Given the potential sensitivity of rapidly dividing myeloid cells to cytotoxic chemotherapy, do not use Grastofil in the period 24 hours before through 24 hours after the administration of cytotoxic chemotherapy.

The efficacy of Grastofil has not been evaluated in patients receiving chemotherapy associated with delayed myelosuppression (for example [e.g.] nitrosoureas) or with mitomycin C or with myelosuppressive doses of anti-metabolites such as fluorouracil (5‑FU) or cytosine arabinoside.

The safety and efficacy of Grastofil have not been evaluated in patients receiving concurrent radiation therapy. Simultaneous use of Grastofil with chemotherapy and radiation therapy should be avoided.

Carcinogenesis and Mutagenesis

The carcinogenic potential of Grastofil has not been studied. Filgrastim failed to induce bacterial gene mutations in either the presence or absence of a drug metabolizing enzyme system. Filgrastim had no observed effect on the fertility of male or female rats or on gestation at doses up to 500 µg/kg.

Growth Factor Potential

 

 

Grastofil is a growth factor that primarily stimulates production of neutrophils. However, the possibility that Grastofil can act as a growth factor for certain tumor types cannot be excluded. Randomized studies have demonstrated that treatment with filgrastim following chemotherapy for acute myeloid leukemia does not adversely influence the outcome of treatment. The use of Grastofil in chronic myeloid leukemia (CML) and myelodysplasia (MDS) has not been fully investigated, and caution should be exercised in using this drug for patients with CML or MDS.

Tumor cells may be collected in the leukapheresis product, following peripheral blood progenitor collection (PBPC) mobilization by filgrastim. The clinical significance and the effect of reinfusion of tumor cells with the leukapheresis product are still unknown and the possible contribution of clonogenic tumor cells to an eventual relapse has not been determined.

Acute myeloid leukemia (AML) has been reported to occur in the natural history of severe chronic neutropenia without cytokine therapy. It is not known what, if any, additional risk may be imposed by Grastofil therapy.

Cardiovascular

Cardiac events (myocardial infarctions, arrhythmias) have been reported in 11 of 375 cancer patients receiving filgrastim in clinical studies, the relationship to Grastofil therapy is unknown. However, patients with pre-existing cardiac conditions receiving Grastofil should be monitored closely.

Hematologic
Leukocytosis

Cancer Patients Receiving Myelosuppressive Chemotherapy

White blood cell (WBC) counts of 100 × 109/L or greater were observed in approximately 2% of patients at doses above 5 and up to 115 µg/kg/day in studies conducted with filgrastim. There were no reports of adverse events associated with this degree of leukocytosis. In order to avoid the potential complications of excessive leukocytosis, a complete blood count (CBC) is recommended twice per week during Grastofil therapy.

Cancer Patients Undergoing Peripheral Blood Progenitor (PBPC) Collection and Therapy

During the period of administration of Grastofil for PBPC mobilization in cancer patients, discontinuation of Grastofil is appropriate if the leukocyte count rises to >100 × 109/L.

Thrombocytopenia

Thrombocytopenia has been reported in patients receiving filgrastim. Platelet counts should be monitored closely.

Hypersensitivity/ Allergic Reactions

Hypersensitivity, including serious allergic-type reactions and anaphylaxis occurring on initial or subsequent treatment have been reported in < 1 in 4,000 patients treated with filgrastim. These reactions generally involved at least two body systems, most often skin (rash, urticarial, facial edema), respiratory (wheezing, dyspnea), and cardiovascular (hypotension, tachycardia) events. Some reactions even occurred on initial exposure. Reactions usually arose within the first 30 minutes following administration and appeared to occur more frequently in patients receiving filgrastim intravenously. Rapid resolution of symptoms occurred in most cases after administration of antihistamines, steroids, bronchodilators, and/or epinephrine. Symptoms recurred in more than half the patients who were re‑challenged. Do not administer Grastofil to patients with a history of allergic reactions to filgrastim or pegfilgrastim.

Cutaneous Vasculitis

Cutaneous vasculitis has been reported in patients treated with filgrastim. In most cases, the severity of cutaneous vasculitis was moderate or severe. Most of the reports involved patients with subcutaneous nodules (SCN) receiving long-term filgrastim therapy. Symptoms of vasculitis generally developed simultaneously with an increase in the ANC and abated when the ANC decreased. Many patients were able to continue filgrastim at a reduced dose.

Immune

As with all therapeutic proteins, there is a potential for immunogenicity.

For the single arm safety study in breast cancer patients (KWI-300-104) with Grastofil, anti-drug antibodies were detected in the Screening antibody assay in 4 patients. None of the samples were confirmed as positive in the Confirmatory assay. In addition, there were no clinical manifestations of antibody formation, such as either hypersensitivity reactions or decreased ANC after completion of the treatment period.

The incidence of antibody development in patients receiving the reference product (Neupogen) has not been adequately determined. While available data suggest that a small proportion of patients developed binding antibodies to filgrastim, the nature and specificity of these antibodies has not been adequately studied. In clinical studies comparing filgrastim and pegfilgrastim, the incidence of antibodies binding to filgrastim was 3% (11/333). In these 11 patients, no evidence of neutralizing response was observed using a cell-based assay. The detection of antibody formation is highly dependent on the sensitivity and specificity of the assay, and the observed incidence of antibody positivity in an assay may be influenced by several factors including timing of sampling, sample handling, concomitant medication, and underlying disease. Therefore, comparison of the incidence of antibodies to filgrastim with the incidence of antibodies to other products may be misleading.

Cytopenias resulting from an antibody response to exogenous growth factors have been reported on rare occasions in patients treated with other recombinant growth factors. There is a theoretical possibility that an antibody directed against filgrastim may crossreact with endogenous G-CSF, resulting in immune-mediated neutropenia; however, this has not been reported in clinical studies or in post-marketing experience with filgrastim. Patients who develop hypersensitivity to filgrastim may have allergic or hypersensitivity reactions to other E.coli-derived proteins.

Other
Cancer Patients Receiving Myelosuppressive Chemotherapy

Premature Discontinuation of Filgrastim Therapy

A transient increase in neutrophil counts is typically seen 1-2 days after initiation of filgrastim therapy. However, for a sustained therapeutic response, Grastofil therapy should be continued following chemotherapy until the post nadir ANC reaches 10 × 109/L. Therefore, the premature discontinuation of filgrastim therapy (that is [i.e.]), prior to the time of recovery from the expected neutrophil nadir, is generally not recommended.

Intensified doses of chemotherapeutic agents may lead to increased toxicities associated with these agents, including cardiac, pulmonary, neurologic, and dermatologic effects (please refer to the product monograph of the specific chemotherapy agents used). Increased exposure to alkylating agents particularly if combined with radiotherapy is known to be associated with the genesis of secondary malignancies. When considering chemotherapy dose intensification with Grastofil support, clinicians should weigh the risk of secondary malignancy against the potential benefits of improved primary disease outcome.

Patients with Severe Chronic Neutropenia

Diagnosis of Congenital, Cyclic or Idiopathic Neutropenia

Care should be taken to confirm the diagnosis of congenital, cyclic or idiopathic neutropenia, which may be difficult to distinguish from myelodysplasia before initiating Grastofil therapy. The safety and efficacy of Grastofil in the treatment of neutropenia or pancytopenia due to other haematopoietic disorders (for example [e.g.] myelodysplastic syndrome) has not been established.

It is therefore essential that serial complete blood counts with differential and platelet counts and an evaluation of bone marrow morphology and karyotype, be performed prior to initiation of Grastofil therapy.

Myelodysplasia (MDS) and acute myeloid leukemia (AML) have been reported to occur in the natural history of congenital neutropenia without cytokine therapy. Cytogenetic abnormalities, transformation to MDS and AML have been observed in patients treated with filgrastim for aplastic anemia and severe chronic neutropenia (SCN). Based on available data, the risk of developing MDS and AML has been confined to the subset of patients with congenital neutropenia. Abnormal cytogenetics has been associated with the eventual development of myeloid leukemia. The effect of continued filgrastim administration in patients with abnormal cytogenetics is unknown. If a patient with SCN develops abnormal cytogenetics, the risks and benefits of continuing filgrastim should be carefully considered.

Chronic Administration

The safety and efficacy of the chronic administration of Grastofil have not been studied. The safety and efficacy of chronic daily administration of the reference product (Neupogen) in patients with SCN have been established in Phase I/II clinical trials of 74 patients treated for up to 4.5 years, and in a Phase III trial of 123 patients treated for up to 3.5 years.

Although the relationship to the reference product (Neupogen) is unclear, osteoporosis has been reported in approximately 7% of patients receiving filgrastim therapy for up to 4.5 years in clinical trials in patients with SCN. Decreased bone density and osteoporosis have also been seen in the pediatric patients with SCN in the post-market setting. Patients with SCN, particularly those patients with congenital neutropenia and those with underlying osteoporotic bone disease, should be monitored for the possible occurrence of bone density changes while on long-term filgrastim therapy. Other infrequently observed adverse events included exacerbation of some pre-existing skin disorders (e.g. psoriasis), cutaneous vasculitis (leukocytoclastic), alopecia, haematuria/proteinurea, thrombocytopenia (platelets <0 × 109/L).

Patients with HIV Infection

Risks Associated with Increased Doses of Myelosuppressive Medications 

Treatment with filgrastim alone does not preclude thrombocytopenia and anemia due to myelosuppressive medications. As a result of the potential to receive higher doses or a greater number of these medications with filgrastim therapy, the patient may be at a higher risk of developing thrombocytopenia and anemia. Regular monitoring of blood counts is recommended.

Infections Causing Myelosuppression

Neutropenia may be due to bone marrow infiltrating opportunistic infections such as Mycobacterium avium complex or malignancies such as lymphoma. In patients with known bone marrow infiltrating infection or malignancy, consideration should be given to appropriate therapy for treatment of the underlying condition, in addition to administration of Grastofil for treatment of neutropenia.

Special Populations
Pregnancy and Nursing Women

Filgrastim has been shown to cause adverse effects in pregnant rabbits when given in doses 2 to 10 times the human dose.

In rabbits, increased abortion and embryolethality were observed in animals treated with filgrastim at 80 µg/kg/day. Filgrastim administered to pregnant rabbits at doses of 80 µg/kg/day during the period of organogenesis was associated with increased fetal resorption, genitourinary bleeding, developmental abnormalities and decreased body weight, live births and food consumption. External abnormalities were not observed in the fetuses of dams treated at 80 µg/kg/day. Reproductive studies in pregnant rats have shown that filgrastim was not associated with lethal, teratogenic, or behavioural effects on fetuses when administered by daily intravenous injection during the period of organogenesis at dose levels up to 575 µg/kg/day.

In Segment III studies in rats, offspring of dams treated at greater than 20 µg/kg/day exhibited a delay in external differentiation (detachment of auricles and descent of testes and slight growth retardation possibly due to lower body weight of females during rearing and nursing). Offspring of dams treated at 100 µg/kg/day exhibited decreased body weights at birth and a slightly reduced 4 day survival rate.

There are cases in the literature where the transplacental passage of filgrastim has been demonstrated. Grastofil should be used during pregnancy only if the potential benefit justifies any potential risk to the fetus.

It is not known whether filgrastim is excreted in human milk, therefore Grastofil is not recommended for use in nursing women.

Pediatrics

Grastofil has not been studies in children under the age of 18, patients with moderate or severe hepatic impairment, or in patients with severe renal impairment. These issues have been addressed through appropriate labelling in the Grastofil Product Monograph.

Safety Conclusion

The safety profile of Grastofil is in general consistent with the known safety profile of the reference product Neupogen. Based on the Grastofil clinical studies, no new significant safety signals were observed in either healthy volunteers or in breast cancer patients. In addition, with the reference product Neupogen being known as a relatively safe drug product with an acceptable safety profile, this further contributes to the overall safety profile of Grastofil. However, given the reduced clinical package submitted which is consistent with all filings of SEB submissions, data for identifying all potential differences between a Subsequent Entry Biologic (SEB) and its reference product regarding long‑term safety is limited. As a result, post‑marketing monitoring of Grastofil for long‑term safety in large patient populations will still be required.

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

 

 

7.2 Non-Clinical Basis for Decision

 

The non-clinical database submitted for Grastofil was in compliance with the Subsequent Entry Biologic data requirements for non-clinical studies, as presented in the Guidance for Sponsors: Information and Submission Requirements for Subsequent Entry Biologics (SEBs).

In non-clinical studies Grastofil showed comparable ability, like that of the reference product Neupogen, to interact with the G-CSF receptor in an in vitro NFS-60 cell assay. In normal and neutropenic rodents, Grastofil resulted in a dose-dependent increase of ANC similar to that of Neupogen. Similar pharmacodynamic responses were noted when comparing the two compounds in comparative animal studies.

The carcinogenic potential of Grastofil has not been studied. Filgrastim (the medicinal ingredient in Grastofil) failed to induce bacterial gene mutations in either the presence or absence of a drug metabolizing enzyme system. Filgrastim had no observed effect on the fertility of male or female rats or on gestation at doses up to 500 µg/kg.

The results of the non-clinical studies as well as the potential risks to humans have been included in the Grastofil Product Monograph. In view of the intended use of Grastofil, there are no pharmacological/toxicological issues within this submission which preclude authorization of the product. Appropriate warnings and precautionary measures are in place in the Grastofil Product Monograph to address the identified safety concerns.

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

 

 

7.3 Quality Basis for Decision

 

Grastofil (filgrastim) is a human granulocyte colony stimulating factor (G‑CSF) produced by recombinant deoxyribonucleic acid (DNA) technology. Granulocyte colony stimulating factor regulates the production of neutrophils within the bone marrow.

Grastofil was developed as a Subsequent Entry Biologic (SEB) to the filgrastim drug product, Neupogen. The biological activity of Grastofil is considered to be representative of the mechanism of action, and pharmacological effect of Neupogen. The quality review pertained to the Neupogen drug substance and drug product. In addition, comparability of Grastofil to the reference product, Neupogen was reviewed in order to evaluate Grastofil as an SEB.

The sponsor has used a combination of in-depth characterisation, stability, accelerated stability and forced degradation studies to compare filgrastim drug substance and drug product to the chosen comparator, Neupogen. These studies have established a high degree of similarity in the primary, secondary and tertiary structure, as well as the purity, biological activity, and the stability and forced degradation profiles of filgrastim and Neupogen. Taken together, these studies suggest a high degree of comparability of filgrastim and Neupogen.

Characterization of the Drug Substance

Detailed characterization studies were performed to provide assurance that filgrastim, the drug substance, consistently 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. The impurities that were reported and characterized were found to be within established limits.

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

The drug substance, filgrastim, is produced in Escherichia coli (E. coli) cells through use of standard recombinant deoxyribonucleic acid (DNA) technology. The manufacture of filgrastim is based E. coli master and working cell bank system, where the master and working cell banks have been thoroughly characterized and tested for adventitious contaminants in accordance with International Council for Harmonisation (ICH) guidelines. Results from genetic characterization studies also demonstrated stability of these cell banks.

The manufacturing of filgrastim comprises of a series of steps which include cell culture, harvest, purification stages, and formulation. The materials used in the manufacture of the drug substance are considered suitable and/or meet standards appropriate for their intended use.

The drug product, Grastofil, is supplied as single‑use, pre‑filled syringe for parental administration that contains 300 µg/0.5 mL of filgrastim formulated in a sodium acetate buffer at pH 4.0 (acetate 0.295 mg; sodium 0.0175 mg), containing sorbitol (25.00 mg), polysorbate 80 (0.004% w/v) and water for injection. 

The Grastofil drug product manufacturing process includes eight steps: preparation of filtered formulation buffer, preparation of formulated bulk solution, sterile filtration of formulated bulk solution, filling, visual inspection, labelling, and packaging.

Changes to the manufacturing process and formulation made throughout the pharmaceutical development are considered acceptable upon review.

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 (including biological‑sourced materials) 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 filgrastim 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 and in compliance with ICH guidelines.

Each lot of Grastofil drug product is tested for appearance, content, identity, potency, purity, and impurities. Established test specifications and validated analytical test methods are considered acceptable.

Through Health Canada’s lot release testing and evaluation program, consecutively manufactured final product lots were tested, evaluated, and found to meet the specifications of the drug product and demonstrate consistency in manufacturing.

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 shelf‑life of 36 months for the drug product Grastofil when stored at the recommended condition of 5°C ± 3°C is considered acceptable.

The compatibility of the drug product with the container closure system was demonstrated through compendial testing and stability studies. The container closure system met all validation test acceptance criteria.

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 facilities involved in the manufacture and testing of the drug substance (filgrastim) and of the drug product (Grastofil) has been successfully conducted by the Biologics and Genetic Therapies Directorate, Health Canada. The production site is compliant with Good Manufacturing Practices.

Adventitious Agents Safety Evaluation

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

The excipients used in the drug product formulation are not of animal or human origin.