Summary Basis of Decision for Zontivity
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:
Summary Basis of Decision (SBD) documents provide information related to the original authorization of a product. The SBD for Zontivity is located below.
Recent Activity for Zontivity
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 Zontivity
Updated:
The following table describes post-authorization activity for Zontivity, a product which contains the medicinal ingredient vorapaxar sulfate. 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 02454815 - 2.5 mg vorapaxar sulphate, tablet, oral administration
Post-Authorization Activity Table (PAAT)
| Activity/submission type, control number | Date submitted | Decision and date | Summary of activities |
|---|---|---|---|
| NDS # 267772 | 2022-09-09 | Issued NOC2022-10-28 | Submission filed to transfer ownership of the drug product from Toprol Acquisition, LLC to Xspire Pharma, LLC. An NOC was issued. |
| NDS # 237676 | 2020-03-27 | Issued NOC2020-04-29 | Submission filed to transfer ownership of the drug product from Aralez Pharmaceuticals Trading DAC to Toprol Acquisition, LLC. An NOC was issued. |
| NDS # 198556 | 2016-10-04 | Issued NOC2016-11-16 | Submission filed to transfer ownership of the product from Merck Canada Inc. to Aralez Pharmaceuticals Trading DAC. An NOC was issued. |
| NDS # 179320 | 2014-10-31 | Issued NOC2016-05-13 | Notice of Compliance issued for New Drug Submission |
Summary Basis of Decision (SBD) for Zontivity
Date SBD issued: 2016-07-18
The following information relates to the new drug submission for Zontivity.
Vorapaxar sulfate
2.5 mg, tablet, oral
Drug Identification Number (DIN):
- 02454815
Merck Canada Inc.
New Drug Submission Control Number: 179320
On May 13, 2016, Health Canada issued a Notice of Compliance to Merck Canada Inc. for the drug product Zontivity.
The market authorization was based on the quality (chemistry and manufacturing), non‑clinical (pharmacology and toxicology), and clinical (clinical pharmacology, safety, and efficacy) information submitted. Based on Health Canada’s review, the benefit/risk profile of Zontivity for reduction of atherothrombotic events in adult high-risk patients with a history of myocardial infarction (MI) is favourable when it is co-administered with acetylsalicylic acid (ASA) with or without clopidogrel, according to their standard of care.
1 What was approved?
Zontivity is a platelet aggregation inhibitor. Zontivity, co-administered with acetylsalicylic acid (ASA) with or without clopidogrel, according to their standard of care, was authorized for the reduction of atherothrombotic events in adult high-risk patients with a history of myocardial infarction (MI).
As older patients (≥65 years of age) are generally at a higher risk of bleeding, patient age should be considered before initiating Zontivity.
Safety and effectiveness of Zontivity have not been established in children <18 years of age. Therefore, Zontivity is not indicated in this patient population.
Zontivity is contraindicated in:
- Patients who are hypersensitive to this drug or to any ingredient in the formulation or component of the container.
- Patients with a history of stroke or transient ischemic attack (TIA) or who experience a stroke or TIA while on Zontivity.
- Patients with a history of intracranial hemorrhage(ICH) or who experience an ICH while on Zontivity.
- Patients with active pathological bleeding such as ICH or peptic ulcer.
- Patients with severe hepatic impairment.
Zontivity was approved for use under the conditions stated in the Zontivity Product Monograph taking into consideration the potential risks associated with the administration of this drug product.
Zontivity (2.5 mg vorapaxar sulfate, which is equivalent to 2.08 mg vorapaxar) is presented as tablets. In addition to the medicinal ingredient, the tablet contains croscarmellose sodium, lactose monohydrate, magnesium stearate, microcrystalline cellulose, and povidone. The film coating contains hypromellose, iron oxide yellow, lactose monohydrate, titanium dioxide and triacetin (glycerol triacetate).
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 Zontivity Product Monograph, approved by Health Canada and available through the Drug Product Database.
2 Why was Zontivity approved?
Health Canada considers that the benefit/risk profile of Zontivity when co-administered with acetylsalicylic acid (ASA) with or without clopidogrel, according to their standard of care, is favourable for the reduction of atherothrombotic events in adult high-risk patients with a history of myocardial infarction (MI).
Platelet activation and aggregation play a critical role in thrombosis, a major pathophysiologic event responsible for the acute clinical manifestations of vascular atherothrombotic diseases such as acute coronary syndromes (ACS) (including unstable angina and MI, with or without ST segment elevation in the electrocardiogram [STEMI or non-STEMI, respectively]), ischemic stroke/transient ischemic attack, and symptomatic peripheral artery disease (PAD).
The standard of care of post-ACS patients consists of using antiplatelet agents (ASA in combination with clopidogrel, prasugrel or ticagrelor) to prevent atherothrombosis, thereby decreasing the risk of unstable angina and MI. The molecular mechanisms by which these drugs achieve their effects are various. Low-dose ASA irreversibly reduces platelet production of thromboxane A2 (TXA2), which is released by activated platelets and will in turn activate nearby platelets. The active metabolites of the thienopyridines clopidogrel and prasugrel block the platelets’ P2Y12 receptor, which is the major receptor able to amplify and sustain platelet activation when activated by adenosine diphosphate (ADP).
Zontivity acts on a third platelet activation pathway: it selectively and reversibly blocks the platelet thrombin receptor (protease-activated receptor: PAR-1) which normally allows thrombin to activate platelets.
The market authorization for Zontivity was based on a single pivotal clinical trial, Thrombin Receptor Antagonist in Secondary Prevention of Atherothrombotic Ischemic Events (TRA 2oP-TIMI 50), which was a multicentre, randomized, double-blind, placebo-controlled, fixed-dose trial conducted in patients who had evidence or a history of atherosclerosis involving the coronary, cerebral, or peripheral vascular systems. It included 17,779 patients with a history of MI; a total of 8,898 patients received Zontivity. The primary efficacy endpoint was a composite of cardiovascular (CV) death, MI, stroke and urgent coronary revascularization (UCR), while the key secondary efficacy endpoint was a composite of CV death, MI and stroke. The safety endpoints were measures of bleeding, including composite of moderate and severe bleeding events according to the Global Utilization of Streptokinase and Tissue Plasminogen Activator for Occluded Arteries (GUSTO) classification, and clinically significant bleeding, defined as Thrombolysis in Myocardial Infarction (TIMI) Major or TIMI Minor bleeding, or bleeding that required unplanned medical treatment, surgical treatment or laboratory evaluation.
Zontivity given once daily with ASA, with or without clopidogrel, significantly reduced the primary efficacy composite endpoint (hazard ratio [HR] 0.82; 95% confidence interval [CI] 0.74-0.90; p<0.001) and the key secondary efficacy composite endpoint (HR 0.78; 95% CI 0.70-0.88; p<0.001) compared to placebo. These reductions were mostly driven by a reduction in the rates of MI. These effects were similar regardless of the time from qualifying MI to the start of therapy with Zontivity, and were maintained for the duration of the study. However, there was an attenuation of the effect of Zontivity from Year 2 to Year 3, while the bleeding risk remained and even increased over time with patient age and co‑morbidities. Therefore, given the insufficient evidence to support long-term (life-long) co-treatment with Zontivity, the use of Zontivity is limited to 2 years post-MI. The need for a re-assessment of the risk/benefit balance for each patient after 2 years of treatment is specified in the Dosage and Administration section of the Zontivity Product Monograph.
A major safety concern for Zontivity was bleeding. The bleeding risk was greater for patients who received Zontivity compared to placebo. In particular, patients with a history of stroke or transient ischemic attack (TIA) had an increased risk of intracranial hemorrhage (ICH). Consequently, the use of Zontivity in these patients has been contraindicated. Patients weighing less than 60 kg and patients with severe renal impairment, end-stage renal disease or severe hepatic impairment were also at increased risk of bleeding. Therefore, the increased risks associated with these co-morbidities have been included in the Warnings and Precautions section of the Zontivity Product Monograph. Specifically, the use of Zontivity in patients with severe hepatic impairment has been contraindicated due to their increased inherent risk of bleeding.
A Risk Management Plan (RMP) for Zontivity was submitted by Merck Canada Inc. to Health Canada. Upon review, the RMP was considered to be acceptable. The RMP describes known and potential safety issues, presents the monitoring scheme and when needed, describes 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 Zontivity was accepted.
Overall, the benefits of Zontivity seen in the pivotal study are considered to outweigh the potential risks. Zontivity, co-administered with ASA with or without clopidogrel, has an acceptable safety profile based on the non-clinical and clinical studies. The identified safety issues can be managed through labelling, and can be adequately monitored clinically. Appropriate warnings and precautions are in place in the Zontivity 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 Zontivity?
The original New Drug Submission (NDS) for Zontivity was filed with Health Canada on October 31, 2014. Due to issues with labelling in the Product Monograph, a Notice of Non-Compliance (NON) was issued on October 6, 2015. The sponsor submitted a response to the NON and all of the concerns that led to the NON were subsequently satisfactorily addressed. A Notice of Compliance for Zontivity was issued on May 13, 2016.
Submission Milestones: Zontivity
| Submission Milestone | Date |
|---|---|
| Pre-submission meeting: | 2013-08-27 |
| Submission filed: | 2014-10-31 |
| Screening 1 | |
| Screening Acceptance Letter issued: | 2014-12-09 |
| Review 1 | |
| Biopharmaceutics Evaluation complete: | 2015-08-06 |
| Quality Evaluation complete: | 2015-10-01 |
| Clinical Evaluation complete: | 2015-10-05 |
| Notice of Non-Compliance (NON) issued by Director General, Therapeutic Products Directorate (safety issues): | 2015-10-06 |
| Response filed: | 2015-11-23 |
| Screening 2 | |
| Screening Acceptance Letter issued: | 2015-12-15 |
| Review 2 | |
| Quality Evaluation complete: | 2016-04-27 |
| Clinical Evaluation complete: | 2016-05-10 |
| Labelling Review complete: | 2016-05-04 |
| Notice of Compliance issued by Director General, Therapeutic Products Directorate/Biologics and Genetic Therapies Directorate: | 2016-05-13 |
The Canadian regulatory decision on the non-clinical and clinical review of Zontivity was based on a critical assessment of the Canadian data package. The foreign reviews completed by the European Medicines Agency (EMA) and the United States Food and Drug Administration (FDA) were used as a reference for labelling in the Product Monograph.
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:
- See MedEffect Canada for the latest advisories, warnings and recalls for marketed products.
- See the Notice of Compliance (NOC) Database for a listing of the authorization dates for all drugs that have been issued an NOC since 1994.
- See the Drug Product Database (DPD) for the most recent Product Monograph. The DPD contains product-specific information on drugs that have been approved for use in Canada and have been market notified (that is, the company has told Health Canada the product is being marketed).
- See the Notice of Compliance with Conditions (NOC/c)-related documents for the latest fact sheets and notices for products which were issued an NOC under the Notice of Compliance with Conditions (NOC/c) Guidance Document, if applicable. Clicking on a product name links to (as applicable) the Fact Sheet, Qualifying Notice, and Dear Health Care Professional Letter.
- See the Patent Register for patents associated with medicinal ingredients, if applicable.
- See the Register of Innovative Drugs for a list of drugs that are eligible for data protection under C.08.004.1 of the Food and Drug Regulations, if applicable.
7 What was the scientific rationale for Health Canada's decision?
7.1 Clinical basis for decision
Clinical Pharmacology
Vorapaxar, the medicinal ingredient of Zontivity, is a selective and reversible inhibitor of the protease-activated receptor-1 (PAR-1) on platelets. Vorapaxar inhibits thrombin-induced platelet aggregation in in vitro studies. In addition, vorapaxar inhibits thrombin receptor agonist peptide (TRAP)-induced platelet aggregation without affecting coagulation parameters. Vorapaxar does not inhibit platelet aggregation induced by other agonists such as adenosine diphosphate (ADP), collagen or a thromboxane mimetic.
The clinical pharmacology included reports on the human pharmacodynamic and pharmacokinetic studies.
A population pharmacokinetic and exposure-response modelling of vorapaxar indicated that a 2.5 mg dose of vorapaxar was the lowest dose likely to provide ≥80% inhibition of TRAP-induced platelet aggregation in most patients; efficacy could be reduced at doses <2.5 mg. This study supported the proposed market dose of 2.5 mg once daily.
The clinical pharmacological data support the use of Zontivity for the recommended indication.
For further details, please refer to the Zontivity Product Monograph, approved by Health Canada and available through the Drug Product Database.
Clinical Efficacy
The efficacy of Zontivity in reducing atherothrombotic events in stable patients with a history of myocardial infarction (MI) was demonstrated through a single pivotal clinical trial, Thrombin Receptor Antagonist in Secondary Prevention of Atherothrombotic Ischemic Events (TRA 2oP-TIMI 50), which was a randomized, double-blind, placebo‑controlled, fixed-dose, events-driven trial.
To participate in the TRA 2oP-TIMI 50 trial, patients had to have evidence or a history of atherosclerosis involving the coronary, cerebrovascular or peripheral vascular systems as follows:
- Coronary artery disease (CAD) as indicated by a history of presumed spontaneous MI that occurred ≥2 weeks but ≤12 months before initiation of therapy;
- Ischemic (presumed thrombotic) cerebrovascular disease (CVD) as indicated by a history of ischemic stroke that occurred ≥2 weeks but ≤12 months before initiation of therapy; or
- Peripheral artery disease (PAD) as indicated by a history of intermittent claudication and a resting ankle brachial index (ABI) of <0.85 or amputation, peripheral bypass or peripheral angioplasty of the extremities secondary to ischemia.
The primary efficacy endpoint was a composite of cardiovascular death, MI, stroke and urgent coronary revascularization, while the key secondary efficacy endpoint was a composite of cardiovascular death, MI and stroke.
A total of 26,449 patients were randomized to receive orally either 2.5 mg vorapaxar sulfate (number of patients [n] = 13,224) or placebo (n = 13,225) once daily, in addition to acetylsalicylic acid (ASA), with or without clopidogrel. Of these 26,449 patients, 17,779 (67.2%) were assigned to the CAD stratum, 4,883 (18.5%) to the CVD stratum and 3,787 (14.3%) to the PAD stratum. The median duration of treatment was just over 2 years. However, following safety concerns (increased risk of intracranial hemorrhage [ICH]) identified in a double-blind, placebo-controlled Phase III trial, TRA-CER (Thrombin Receptor Antagonist for Clinical Event Reduction in Acute Coronary Syndrome [ACS]), patients with a history of stroke were excluded from the TRA 2oP-TIMI 50 trial. Those encompassed 4,510 patients (2,948 receiving placebo and 2,262 receiving Zontivity) that had either a prior history of stroke (CVD stratum) or experienced a stroke endpoint during the study. Also excluded were all patients with a history of transient ischemic attack (TIA) and those who experienced a TIA during the trial.
The analysis of the treated PAD patients in the TRA 2oP-TIMI 50 trial found insufficient statistical evidence of efficacy in the primary and key secondary efficacy endpoints, potentially due to the relatively low number of patients in this stratum of the trial.
In the CAD patients with no history of stroke or TIA, Zontivity added to ASA, with or without clopidogrel, significantly reduced the primary efficacy composite endpoint [HR 0.82; 95% CI 0.74-0.90; p<0.001] and the key secondary efficacy composite endpoint [HR 0.78; 95% CI 0.70-0.88; p<0.001]. The rate of reduction of MI was the major component that contributed to this reduction. The effect was similar regardless of the time from qualifying MI to the start of therapy with Zontivity and was maintained for the duration of the trial. However, there was an attenuation of the effect of Zontivity from Year 2 to Year 3, while bleeding risk remained and even increased over time with patient age and co-morbidities. Therefore, there is insufficient evidence to support long-term (life-long) treatment with Zontivity. Zontivity was also associated with a reduction in the incidence of recurrent events and definite stent thrombosis. There was a consistency of effect with Zontivity among subgroups that included age, sex, hypertension, use of antiplatelet agents and diabetes mellitus.
Compared to placebo, Zontivity prevented 71 cardiovascular death, non-fatal MI or ischemic stroke events per 10,000 patient-years, while causing 31 additional Global Utilization of Streptokinase and Tissue Plasminogen Activator for Occluded Arteries (GUSTO) Moderate bleeding events, 1 additional GUSTO Severe non-fatal non-ICH event and no fatal bleeding. From a number needed to treated (NNT) or number needed to harm (NNH) perspective, 140 patients would need to be treated for 1 year with Zontivity to prevent 1 non-bleeding cardiovascular death, MI or stroke event, while 1 in every 7,488 patients and 1 in every 325 patients treated for 1 year with Zontivity would have a GUSTO Severe non-fatal non-ICH event and a GUSTO Moderate bleeding event, respectively.
Indication
The original New Drug Submisssion (NDS) for Zontivity was filed with the following proposed indication:
“Zontivity (vorapaxar sulfate) is indicated for the reduction of atherothrombotic events in patients with a history of myocardial infarction (MI) or with peripheral arterial disease (PAD). Zontivity has been shown to reduce the rate of a combined endpoint of cardiovascular death, MI, stroke, and urgent coronary revascularization (UCR).”
The originally proposed dosage and administration statement referred to the use of Zontivity in combination with acetylsalicylic acid (ASA), with or without clopidogrel, with no specific recommendation on its combined use with prasugrel or ticagrelor due to lack of evidence. This lack of evidence, combined with a potentially increased risk of bleeding with these agents, led to the Health Canada’s decision to restrict the use of Zontivity with ASA, with or without clopidogrel.
Also, as the analysis of the treated PAD patients in the pivotal trial TRA 2oP-TIMI 50 showed insufficient statistical evidence of efficacy, Health Canada only accepted the proposed indication for the reduction of atherothrombotic events in the post-MI patients. Hence, Health Canada approved the following indication:
Zontivity (vorapaxar sulfate), co-administered with acetylsalicylic acid (ASA) with or without clopidogrel, according to their standard of care, is indicated for the reduction of atherothrombotic events in adult high-risk patients with a history of myocardial infarction (MI).
All of the issues impacting the indication, contraindications, dosage and safety information for Zontivity, which led to issuing a Notice of Non-Compliance (NON) on October 6, 2015, were subsequently satisfactorily resolved and reflected appropriately in the various sections of the Zontivity Product Monograph. The submission was found to be in compliance with the Food and Drugs Act and Regulations and a Notice of Compliance (NOC) was issued.
For more information, refer to the Zontivity Product Monograph, approved by Health Canada and available through the Drug Product Database.
Clinical Safety
Zontivity was evaluated for safety in the Phase III clinical trial TRA 2°P‑TIMI 50 (described in the Clinical Efficacy section). Patients randomized to Zontivity received treatment for a median of 2.3 years with 2,187 patients treated for >3 years.
The safety analysis of the coronary artery disease (CAD) patients with no history of stroke or transient ischemic attack (TIA) included 16,856 patients. Of those, 8,412 received placebo and 8,444 received Zontivity. More than half of the patients (62.7% for placebo-treated and 61.9% for Zontivity-treated) were on treatment for ≥2 years. The duration of participation within each group was nearly identical between placebo- and Zontivity-treated patients. Of the 26,352 patients treated, 6,093 patients (23.0%) discontinued treatment (2,948 in the placebo group and 3,145 in the Zontivity group). More patients in the Zontivity group (n = 1,381) than in the placebo group (n = 1,299) discontinued treatment due to adverse experiences. Of the patients who discontinued treatment, approximately half (48.1% for the placebo group and 49.5% for the Zontivity group) discontinued treatment after ≥1 year.
The safety endpoints evaluated in the pivotal trial were measures of bleeding, including a composite of moderate and severe bleeding events according to the Global Utilization of Streptokinase and Tissue Plasminogen Activator for Occluded Arteries (GUSTO) classification, and clinically significant bleeding, defined as Thrombolysis in Myocardial Infarction (TIMI) Major or TIMI Minor bleeding, or bleeding that required unplanned medical treatment, surgical treatment or laboratory evaluation.
Bleeding Adverse Events
Bleeding risk was considered the major potential safety concern for Zontivity. Bleeding risk was found to be greater for patients in the Zontivity group as compared with patients in the placebo group. However, the rate of intracranial hemorrhage (ICH) was equivalent (0.5%) in both treatment groups. This was in contrast to patients with a history of stroke or TIA who had an increased risk of ICH. Zontivity did not significantly increase the rate of GUSTO Severe bleeding, TIMI Major bleeding, non-CABG (coronary artery bypass graft surgery)‑related major bleeding and ICH. The overall incidence of fatal bleeding was low and similar between Zontivity and placebo (0.1%). There was no increase in the risk of any of the bleeding endpoints in patients ≥65 years versus (vs.) <65 years and ≥75 years vs. <75 years.
In the overall population, the proportions of patients requiring transfusions following a bleeding event, a CABG surgery, or a non-CABG cardiac or vascular surgery were higher in the Zontivity group compared to the placebo group. However, in totality, Zontivity did not appear to be associated with any increased perioperative bleeding risk.
There were small percentages of serious bleeding events reported during treatment. More patients reported serious bleeding events in the Zontivity group compared to the placebo group. Gastrointestinal-related bleeding events were the most frequently reported serious bleeding events.
Discontinuation of treatment due to bleeding events was low, but higher in the Zontivity group compared to the placebo group. Epistaxis (nosebleed) was the most frequently reported bleeding event and was reported twice as often in the Zontivity group compared to the placebo group (7.2% vs. 3.6%). It was also the most frequently reported bleeding event that led to treatment discontinuation.
The lack of appropriate labelling to mitigate the increased risk of bleeding associated with Zontivity was the major safety concern that led to a NON for the original drug submission. In post-MI patients, the pivotal trial showed an attenuation of the efficacy of Zontivity after 2 years of treatment, while the bleeding risk in these patients remained high. The pivotal trial also showed that, in post-MI patients, relatively more bleeding events were seen in: patients weighing <60 kg vs. those weighing ≥60 kg; patients ≥65 years of age vs. those <65 years of age; patients with reduced renal function; and patients with reduced hepatic function. Appropriate measures were taken to mitigate these risks, including the need for a re-assessment of the risk/benefit balance for each patient after 2 years of treatment with Zontivity (stated in the Dosage and Administration section of the Product Monograph). The bleeding risks have been reflected appropriately in the Contraindications and Warnings and Precautions sections of the Zontivity Product Monograph.
Low body weight
In the TRA 2oP‑TIMI 50 trial, patients weighing <60 kg had a higher rate of bleeding (measured by GUSTO Moderate or Severe, clinically significant, and ICH) compared to patients weighing ≥60 kg. For all bleeding endpoints, hazard ratios for patients <60 kg (n = 857) were higher by 18% ‑ 37% than those for patients ≥60 kg (n = 15,977). Although the numbers of events were small (≤76 events), this indicated an increased risk of bleeding for patients weighing <60 kg. Therefore, the Warnings and Precautions Section of the Product Monograph contains a warning that Zontivity should be used with caution in patients with a body weight <60 kg.
Older Age (≥65 years)
In the TRA 2°P‑TIMI 50 trial, 28.9% of post-MI patients without a history of stroke or TIA were ≥65 years of age and 7.3% were ≥75 years of age. Older subjects (≥65 years) had greater bleeding event rates in the placebo and Zontivity trial arms than did younger subjects (<65 years). The same observation was made for subjects aged ≥75 years vs. <75 years. Older patients are generally at a higher risk of bleeding and this intrinsic bleeding risk has been included in the Warnings and Precautions section of the Zontivity Product Monograph.
Renal impairment
Reduced renal function is a known risk factor for bleeding. In the TRA 2oP-TIMI 50 trial, out of 16,987 CAD patients with no history of stroke or TIA randomized, only 101 patients had estimated Glomerular Filtration Rate (eGFR) <30 mL/min/1.73 m2. Therefore, the underlying bleeding risk in patients with reduced renal function and the limited experience in patients with severe renal impairment or end-stage renal disease have been pointed out in the Warnings and Precautions section of the Zontivity Product Monograph.
Hepatic impairment
Severe hepatic impairment is a known risk factor for bleeding. In the TRA 2oP-TIMI 50 trial, 98.2% of coronary artery disease (CAD) patients with no history of stroke or TIA had no prior history of hepatic disease. In addition, in a Phase I study to determine the effects of hepatic impairment on the pharmacokinetics of Zontivity, only 4 instead of 6 subjects with severe hepatic impairment were enrolled because one subject experienced a serious adverse event of gastrointestinal hemorrhage secondary to ruptured esophageal varices; this event was considered possibly related to the study drug. The Warnings and Precautions section of the Zontivity Product Monograph has included the underlying bleeding risk in patients with reduced hepatic function. Furthermore, Zontivity has been contraindicated in patients with severe hepatic impairment.
Concomitant use with other P2Y12 inhibitors – prasugrel or ticagrelor
In the TRA 2oP‑TIMI 50 trial, only 0.2% (n = 38) of CAD patients with no history of stroke or TIA took prasugrel; no subject took ticagrelor. In addition, prasugrel and ticagrelor are more potent than clopidogrel and as such are expected to increase the risk of bleeding. Given the paucity of evidence of efficacy and safety of co-administering Zontivity with ASA and ticagrelor, or with ASA and prasugrel, Health Canada restricted its indication to co-administration with ASA, with or without clopidogrel.
Concomitant use with warfarin, other oral anticoagulants and heparin
There is very limited clinical experience with the concomitant use of Zontivity with warfarin, other oral anticoagulants and heparin, including low molecular weight heparin, but their concomitant use may increase the risk of bleeding. Therefore, an appropriate warning has been included in the Warnings and Precautions section of the Zontivity Product Monograph.
Non-bleeding Adverse Events
The pivotal TRA 2°P‑TIMI 50 trial showed no significant differences in non-bleeding adverse events between the two treatment groups. Anemia was reported slightly more frequently in the Zontivity group (2.5%) compared to the placebo group (1.9%); there was no evidence of an association between Zontivity treatment and non-bleeding causes of anemia, such as bone marrow suppression. Anemia was also the most frequently reported other adverse event that led to treatment discontinuation. The numbers of events that resulted in discontinuation of treatment were similar between the two treatment groups.
Conclusion
All of the issues impacting the indication, contraindications, dosage and safety information for Zontivity, which led to issuing a Notice of Non-Compliance (NON) on October 6, 2015, were subsequently satisfactorily resolved and reflected appropriately in the various sections of the Zontivity Product Monograph.
Based on the information provided for this submission, the benefit/risk ratio of Zontivity, co-administered with acetylsalicylic acid (ASA) with or without clopidogrel, for the reduction of atherothrombotic events in adult high-risk patients with a history of myocardial infarction (MI) is considered to be favorable. Appropriate warnings and precautions are in place in the approved Zontivity Product Monograph to address the identified safety concerns.
For more information, refer to the Zontivity Product Monograph, approved by Health Canada and available through the Drug Product Database.
7.2 Non-Clinical Basis for Decision
The non-clinical pharmacology and toxicology studies support the use of Zontivity for the specified indication.
In non-clinical studies, vorapaxar had no effects on mating, fertility and embryo-fetal development. The overall no effect level for pre- and post-natal development in rats was 5 mg/kg (more than 6 times human steady-state exposure). Vorapaxar was excreted via rat milk and was retrieved from the plasma of pups.
There was no evidence for any potential carcinogenic effects following 2-year mice and rat studies.
Phospholipidosis was seen in mice and cynomolgus monkeys at high doses and at lower doses in rats. In addition, in some non-clinical studies, there were signs of liver disease (elevated alanine aminotransferase [ALT], aspartate aminotransferase [AST], gamma-glutamyl transferase [GGT]).
The results of the non-clinical studies as well as the potential risks to humans have been included in the Zontivity Product Monograph. In view of the intended use of Zontivity, there are no pharmacological/toxicological issues within this submission which preclude authorization of the product.
For more information, refer to the Zontivity 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 Zontivity 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 of 24 months is acceptable for the drug product when stored in aluminum blisters at 15-30ºC.
Proposed limits of drug-related impurities are considered adequately qualified (that is, within International Council for Harmonisation (ICH) limits and/or qualified from toxicological studies).
All sites involved in production are compliant with Good Manufacturing Practices.
All non-medicinal ingredients (described earlier) found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations.
Related Drug Products
| Product name | DIN | Company name | Active ingredient(s) & strength |
|---|---|---|---|
| ZONTIVITY | 02454815 | XSPIRE PHARMA, LLC | VORAPAXAR SULFATE 2.5 MG |