Summary Basis of Decision for Rydapt

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 Rydapt is located below.

Recent Activity for Rydapt

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 Rydapt

Updated:

2019-03-21

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

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

Drug Identification Numbers (DIN):

  • DIN 02466236 - 25 mg midostaurin, capsule, oral administration

Post-Authorization Activity Table (PAAT)

Activity/submission type, control numberDate submittedDecision and dateSummary of activities
SNDS # 2104962017-10-25Issued NOC
2018-10-03
Submission filed as a Level I - Supplement was filed to obtain market authorization for Rydapt for the treatment of adult patients with advanced systemic mastocytosis. Upon review, the following indication was recommended: Rydapt is indicated for the treatment of adult patients with aggressive systemic mastocytosis, systemic mastocytosis with associated hematological neoplasm, or mast cell leukemia. Regulatory Decision Summary published.
NC # 2131612018-01-26Issued NOL
2018-04-16
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 Drug Interactions 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.
NDS # 2011012016-12-09Issued NOC
2017-07-21
Notice of Compliance issued for New Drug Submission.
Summary Basis of Decision (SBD) for Rydapt

Date SBD issued: 2017-09-27

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

Midostaurin
25 mg capsule, oral

Drug Identification Number (DIN):

  • 02466236

Novartis Pharmaceuticals Canada Inc.

New Drug Submission Control Number: 201101

On July 21, 2017, Health Canada issued a Notice of Compliance to Novartis Pharmaceuticals Canada Inc. for the drug product Rydapt.

The market authorization was based on quality (chemistry and manufacturing), non-clinical (pharmacology and toxicology), and clinical (pharmacology, safety, and effectiveness) information submitted. Based on Health Canada's review, the benefit-harm-uncertainty profile of Rydapt in combination with standard cytarabine and daunorubicin induction and cytarabine consolidation chemotherapy is favourable for the treatment of adult patients with newly diagnosed FLT3-mutated acute myeloid leukemia (AML).

1 What was approved?

Rydapt (midostaurin) in combination with standard cytarabine and daunorubicin induction and cytarabine consolidation chemotherapy was authorized for the treatment of adult patients with newly diagnosed FLT3 -mutated acute myeloid leukemia (AML). Rydapt is an antineoplastic agent.

A validated test is required to confirm the FLT3 mutation status of AML.

Clinical studies in AML with Rydapt did not include sufficient numbers of patients aged 60 years and over to determine whether they respond differently from younger patients.

The safety and efficacy of Rydapt in pediatric patients (0 to less than 18 years) have not been established.

Rydapt is contraindicated for patients with hypersensitivity to midostaurin or to any of the excipients.

Rydapt was approved for use under the conditions stated in its Product Monograph taking into consideration the potential risks associated with the administration of this drug product.

Rydapt (25 mg midostaurin) is presented as a capsule. In addition to the medicinal ingredient, the capsule contains all-rac-α-tocopherol (vitamin E), corn oil mono-di-triglycerides, ethanol anhydrous, gelatin, glycerol, iron oxide red, iron oxide yellow, macrogol 400, macrogolglycerol hydroxystearate, purified water, red pharmaceutical ink, and titanium dioxide.

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

2 Why was Rydapt approved?

Health Canada considers that the benefit-harm-uncertainty profile of Rydapt in combination with standard cytarabine and daunorubicin induction and cytarabine consolidation chemotherapy is favourable for the treatment of adult patients with newly diagnosed FLT3-mutated acute myeloid leukemia (AML).

Acute myeloid leukemia is the most common type of acute leukemia in adults. The majority of patients with AML die from the disease. In approximately 28% of patients with newly diagnosed AML, the leukemic cells carry a FLT3 gene mutation. Mutations in the FLT3 gene have been shown to be associated with inferior disease-free survival (DFS) and overall survival (OS) or with a higher risk of relapse.

Current AML management relies largely on intensive chemotherapy and allogeneic hematopoietic stem cell transplantation (SCT). Given the adverse prognostic impact of FLT3 gene mutations and the limited efficacy of the available treatment options, there is an unmet medical need in patients with FLT3 -mutated AML. Rydapt (midostaurin) is a new active substance and is the first of its class to be recommended for approval in Canada. It is an orally bioavailable staurosporine analog, which inhibits multiple receptor tyrosine kinases, including FLT3 and KIT kinase.

Rydapt in combination with standard cytarabine and daunorubicin induction and cytarabine consolidation chemotherapy has been shown to be efficacious in adult patients with newly diagnosed FLT3-mutated AML. The market authorization was based on a pivotal, randomized, double-blind, Phase III study of Rydapt versus placebo, both in combination with standard cytarabine and daunorubicin induction and high-dose cytarabine consolidation chemotherapy. The study was conducted in 717 patients (18 to 60 years of age) with newly diagnosed FLT3 -mutated AML. The analysis of the primary endpoint, OS, was conducted after a minimum follow-up of approximately 3.5 years after the randomization of the last patient. A statistically significant improvement in OS was observed with a 23% risk reduction of death for Rydapt plus standard chemotherapy compared to placebo plus standard chemotherapy. Secondary efficacy endpoints also supported the benefit of adding Rydapt to the chemotherapy.

The pivotal study only included patients 18 to <60 years old. The Rydapt Product Monograph indicates that there is limited data for patients 60-70 years old and no data is available in patients >70 years old. It recommends that for patients ≥60 years of age, Rydapt should be used only in patients eligible to receive intensive induction chemotherapy with adequate performance status and without significant comorbidities.

Serious adverse drug reactions (ADRs) occurred in 32.3% of patients in the Rydapt plus standard chemotherapy group versus (vs.) 30.1% in the placebo plus standard chemotherapy group. The most frequent serious ADR in patients treated with Rydapt plus standard chemotherapy was febrile neutropenia (16.2%) and this occurred at a similar rate in the placebo group (15.9%). Less frequent serious ADRs included pyrexia (3.1% vs. 4.0%), device-related infection (7.4% vs. 4.4%), exfoliative dermatitis (2.6% vs. 1.8%), and hypotension (2.6% vs. 1.3%).

Neutropenia and infection, pulmonary toxicity (interstitial lung disease and pneumonitis), cardiac toxicity (cardiac failure) and an increased frequency of QT prolongation were observed in patients treated with Rydapt. Warnings for these adverse events have been included in the Rydapt Product Monograph and recommendations for monitoring and appropriate actions to take in the occurrence of these events have also been included.

The medicinal ingredient, midostaurin, is primarily metabolized by the cytochrome P450 (CYP) enzyme 3A4. Drug-drug interaction warnings for concomitant use with strong CYP3A4 inhibitors and inducers are in place in the Rydapt Product Monograph.

No studies have been conducted in patients with severe hepatic impairment and clinical experience in patients with severe renal impairment is limited. Also, there are no adequate and well-controlled studies in pregnant women. Appropriate warnings have been included in the Rydapt Product Monograph to inform of the risk of using Rydapt in these subgroups of patients.

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

The proposed brand name (Rydapt) has been evaluated and is considered acceptable.

Overall, the combination of Rydapt with standard cytarabine and daunorubicin induction and cytarabine consolidation chemotherapy is an effective treatment for adult patients with newly diagnosed FLT3-mutated AML. The toxicity of the combination treatment is considered tolerable and manageable. Based on the data reviewed, the benefit-harm-uncertainty assessment is considered to be positive.

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 Rydapt?

The drug submission for Rydapt was reviewed under the Priority Review Policy. Sufficient evidence was submitted demonstrating that Rydapt provided an effective treatment for a disease or condition for which no drug is presently marketed in Canada.

Submission Milestones: Rydapt

Submission MilestoneDate
Pre-submission meeting:2016-10-14
Request for priority status
Filed:2016-10-20
Approval issued by Director, Bureau of Metabolism, Oncology, and Reproductive Sciences:2016-11-28
Submission filed:2016-12-09
Screening
Screening Acceptance Letter issued:2017-01-06
Review
Biopharmaceutics Evaluation complete:2017-05-26
Review of Risk Management Plan complete:2017-06-07
Look-alike Sound-alike brand name assessment:2017-06-19
Quality Evaluation complete:2017-06-28
Labelling Review complete:2017-07-18
Clinical Evaluation complete:2017-07-21
Notice of Compliance issued by Director General, Therapeutic Products Directorate:2017-07-21

The Canadian regulatory decision on the non-clinical and clinical review of Rydapt was based on a critical assessment of the data package submitted to Health Canada. The foreign reviews completed by the European Medicines Agency (EMA) and the United States Food and Drug Administration (FDA) were used as added references.

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 outlined in the Food and Drugs Act and Regulations.

6 What other information is available about drugs?

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

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

Clinical Pharmacology

The medicinal ingredient of Rydapt, midostaurin, inhibits multiple receptor tyrosine kinases, including FLT3 and KIT kinase. Midostaurin inhibits FLT3 receptor signalling and induces cell cycle arrest and apoptosis in leukemic cells expressing internal tandem duplication (ITD) and tyrosine kinase domain (TKD) mutant receptors or overexpressing wild-type receptors. Midostaurin inhibits both the wild-type and D816V mutant KIT, leading to interference with the aberrant signaling of KIT and inhibits mast cell proliferation and survival, and histamine release.

Midostaurin is primarily eliminated by hepatic metabolism. A dedicated hepatic impairment study and population pharmacokinetic analyses indicated that mild to moderate hepatic impairment had no clinically relevant effects on the pharmacokinetics of midostaurin or its active metabolites. The pharmacokinetics of midostaurin has not been assessed in patients with severe hepatic impairment (Child-Pugh Class C).

No dedicated renal impairment study has been conducted. Population pharmacokinetic analyses indicated that mild and moderate renal impairment had no impact on the pharmacokinetics of midostaurin or its active metabolites. There is limited clinical data for patients with severe renal impairment.

Midostaurin is primarily metabolized by the cytochrome P450 (CYP) enzyme 3A4. Drug interactions were observed when Rydapt was coadministered with a strong CYP3A4 inhibitor, and a strong CYP3A4 inducer. Exposure of midostaurin also increased when midostaurin was administered with food.

Overall, the clinical pharmacological data support the use of Rydapt for the specified indication. Adequate warnings and precautions for the identified safety concerns are in place within the Rydapt Product Monograph.

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

Clinical Efficacy

The clinical efficacy and safety of Rydapt, in combination with standard chemotherapy versus (vs.) placebo plus standard chemotherapy, and as single agent maintenance therapy was investigated in 717 patients (18 to 60 years of age) in a randomized, double-blind, pivotal, Phase III study. Patients with newly diagnosed FLT3-mutated acute myeloid leukemia (AML) as determined by a clinical trial assay were randomized (1:1) to receive Rydapt 50 mg twice daily (number of patients [n] = 360) or placebo (n = 357) sequentially (Days 8 to 21) in combination with standard daunorubicin (60 mg/m2 daily on Days 1 to 3) / cytarabine (200 mg/m2 daily on Days 1 to 7) for up to two cycles of induction and high dose cytarabine (3 g/m2 every 12 hours on Days 1, 3, 5) for up to four cycles of consolidation. The dosing regimen was followed by continuous Rydapt or placebo treatment according to initial assignment for up to 12 additional 28-day cycles as maintenance. There was no re-randomization at the start of maintenance therapy. Patients who proceeded to hematopoietic stem cell transplant (SCT) stopped receiving study treatment before the SCT conditioning regimen.

Patients with acute promyelocytic leukemia (M3) or therapy-related AML were excluded. Patients were stratified by FLT3 mutation status: TKD, ITD with allelic ratio <0.7, and ITD with allelic ratio ≥0.7.

The two treatment groups were generally balanced with respect to the baseline demographics and disease characteristics, except that the placebo plus standard chemotherapy group had a higher percentage of females than in the Rydapt plus standard chemotherapy group.

Of the 717 patients, 25% had a second course of induction, 62% initiated at least one cycle of consolidation, 29% initiated maintenance, and 17% completed all 12 planned cycles of maintenance. The overall rate of SCT was 59.4% (214/360) of patients in the Rydapt plus standard chemotherapy group vs. 55.2% (197/357) in the placebo plus standard chemotherapy group. Twenty-one percent of all the patients in the study underwent SCT in the first complete remission. All patients were followed for survival.

The primary endpoint of the study was overall survival (OS), measured from the date of randomization until death by any cause. The primary analysis was conducted after a minimum follow-up of approximately 3.5 years after the randomization of the last patient. The key secondary endpoint was event-free survival (EFS; defined as a failure to obtain a complete remission [CR] within 60 days of initiation of protocol therapy, or relapse, or death from any cause). Another secondary endpoint was disease-free survival (DFS) which was measured from the date of the first CR to the date of relapse or death from any cause, whichever occurred first.

A statistically significant improvement in OS was observed with a 23% risk reduction of death for Rydapt plus standard chemotherapy over placebo plus standard chemotherapy (hazard ratio [HR] of 0.77 [95% confidence interval [CI]: 0.629, 0.953; one-sided p value = 0.0078]). Median OS could not be reliably estimated.

The key secondary efficacy endpoint EFS non-censored at the time of SCT, also demonstrated the benefits of Rydapt plus standard chemotherapy over placebo plus standard chemotherapy. The median EFS was 8.2 months (95% CI: 5.4, 10.7) vs. 3.0 months (95% CI: 1.9, 5.9) respectively, with a HR of 0.78 (95% CI: 0.66, 0.93, p = 0.0024, one-sided).

Other secondary efficacy endpoints also supported the benefit of adding Rydapt to chemotherapy. Rates of CR by Day 60 were also numerically higher in patients treated with Rydapt (58.9% vs. 53.5%) although the difference was not statistically significant. Median DFS (not censored at the time of SCT) was 26.7 months in the Rydapt group and 15.5 months in the placebo group (HR = 0.71; 95% CI: 0.55, 0.92; p = 0.0051, one-sided).

The impact of SCT on the efficacy endpoints were analyzed by censoring at the time of SCT for OS, EFS and DFS analyses, and the results were supportive of the primary OS analysis.

Subgroup analyses showed a consistent OS benefit across most investigated subgroups, except for the analysis by gender which showed no apparent OS advantage in female patients treated with Rydapt where the HR was 1.01 (95% CI: 0.76, 1.34). The HR for male patients was 0.53 (95% CI: 0.39, 0.72). This gender effect was not observed with the secondary efficacy endpoints (EFS, DFS and CR rate). Collectively, the available data are not sufficient to conclude that there is a difference in treatment benefit for males and females, especially when the subgroup analyses are not powered to demonstrate statistically significant differences between treatment groups. The observed difference in OS by gender has been communicated in the Clinical Trial section of the Rydapt Product Monograph.

The submission also included eight supportive studies. Two supportive studies (A2106 and ADE02T) evaluated the use of Rydapt in combination with standard chemotherapy in patients with FLT3-mutated AML. In the other six supportive studies (A2104, A2104E1, A2104E2, A2114, D2201, and A2213), Rydapt was administered as a single agent in patients with AML or other types of hematological malignancies (myelodyplastic syndrome, aggressive systemic mastocytosis, and mast cell leukemia).

Indication

The New Drug Submission for Rydapt was filed by the sponsor with the following indication:

  • Rydapt is indicated in combination with standard induction and consolidation chemotherapy followed by single agent maintenance therapy for adult patients with newly diagnosed acute myeloid leukemia (AML) who are FLT3 mutation-positive.

The indication proposed by the sponsor included a maintenance phase with Rydapt monotherapy following the consolidation therapy. Health Canada did not approve this indication because the sponsor failed to provide convincing evidence of the benefit of maintenance therapy. Although maintenance therapy was an integral part of the pivotal study, the patients were not re-randomized prior to the start of the maintenance phase. When the small number of patients who entered this phase was considered, it was difficult to assess the contribution of this phase to the OS benefit.

To ensure safe and effective use of the product, Health Canada approved the following indication:

  • Rydapt is indicated in combination with standard cytarabine and daunorubicin induction and cytarabine consolidation chemotherapy for the treatment of adult patients with newly diagnosed FLT3-mutated acute myeloid leukemia (AML).
  • A validated test is required to confirm the FLT3 mutation status of AML.

Overall Analysis of Efficacy

Based on the data reviewed, the combination of Rydapt with standard cytarabine and daunorubicin induction and cytarabine consolidation is an effective treatment for adult patients with newly diagnosed FLT3-mutated AML.

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

Clinical Safety

The safety evaluation of Rydapt (50 mg twice daily) in patients with newly diagnosed FLT3-mutated AML was based on the pivotal Phase III, randomized, double-blind, placebo-controlled study described in the Clinical Efficacy section.

All patients in the pivotal study experienced at least one adverse event of any grade and all but one patient in the Rydapt group experienced at least one Grade 3/4 adverse event.

The most frequent adverse drug reactions (ADRs, incidence ≥20% and ≥2% more in the Rydapt group) were febrile neutropenia, lymphopenia, device- related infection, and exfoliative dermatitis.

Serious ADRs occurred in 32.3% of patients in the Rydapt group vs. 30.1% in the placebo group. The most frequent serious ADR in the Rydapt group was febrile neutropenia (16.2%) and this occurred at a similar rate in the placebo group (15.9%); less frequent serious ADRs (>2%) included pyrexia (3.1% vs. 4.0%), device-related infection (7.4% vs. 4.4%), exfoliative dermatitis (2.6% vs. 1.8%), and hypotension (2.6% vs. 1.3%), respectively.

There were fewer patients who died during treatment in the Rydapt group than in the placebo group, 15 patients (4.3%) vs. 21 patients (6.3%), respectively.

Of the laboratory abnormalities, the following parameters were observed at a higher frequency in the Rydapt group compared to the placebo group: aspartate aminotransferase (AST) (73.9% vs. 65.4%), Grade 3/4 alanine aminotransferase (ALT) (19.4% vs. 14.9%), hypercalcemia (6.7% vs. 3.6%), and hypernatremia (20% vs. 14.9%), respectively.

QT prolongation, cardiac toxicity (cardiac failure), neutropenia and infection, and pulmonary toxicity (interstitial lung disease and pneumonitis) were observed in patients treated with Rydapt. Appropriate warnings are included in the Rydapt Product Monograph. Inclusion of these adverse events within a Serious Warnings and Precautions box was not required as causality could not be established given the available data. The recommendations to monitor for these adverse events and the actions to take upon their occurrence are included in the Rydapt Product Monograph.

The clinical studies with Rydapt did not include sufficient numbers of patients aged 60 years and over to determine whether they respond differently from younger patients. Therefore, it is stated under the Warning and Precautions section of the Rydapt Product Monograph that there is limited experience with the indicated use of Rydapt in AML patients aged 60-70 years and no experience in AML patients above 70 years. That section also indicates that, in patients aged ≥60 years, Rydapt should be used only in patients eligible to receive intensive induction chemotherapy with adequate performance status and without significant comorbidities.

Overall, the safety data show that while there is toxicity associated with the treatment combinations used in the pivotal study, the addition of Rydapt to the standard chemotherapy regimen did not appear to considerably increase the toxicity of the treatment combination (compared to the addition of placebo in the comparator arm). The safety profile of Rydapt and risk mitigation recommendations for the specified indication and clinical use are appropriately captured in the Rydapt Product Monograph.

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

7.2 Non-Clinical Basis for Decision

Administration of midostaurin, the medicinal ingredient of Rydapt, in combination with daunorubicin and cytarabine in repeat-dose animal studies led to more pronounced adverse effects than midostaurin alone. The main target organs for toxicity were the thymus, the spleen, the bone marrow, the small intestine, and the liver. A marked effect on reticulocyte counts, platelet counts, erythrocyte counts, hemoglobin concentration and a decreased myeloid/erythroid ratio were noted. Lymphocyte and neutrophil counts were also affected by the drug.

Midostaurin was found to be fetotoxic at a relatively low dose of 3 mg/kg in rats (corresponding to an exposure multiple relative to human exposures at steady state of only 0.004). In the same study, no effect was observed on dams up to 30 mg/kg. Rydapt can thus be considered highly fetotoxic in animals and may present a risk in humans. A warning was added in the Warning and Precautions section of the Rydapt Product Monograph stating that Rydapt can cause fetal harm when administered to a pregnant woman. Adequate warnings for females of reproductive potential regarding the need to conduct pregnancy test prior to starting Rydapt treatment have also been included in the PM. Appropriate recommendations for the use of effective contraceptives for female and male patients are included in the Rydapt Product Monograph.

It is unknown whether midostaurin or its active metabolites are excreted in human milk. Non-clinical studies show that orally administered midostaurin and its active metabolites pass into the milk of lactating rats. A recommendation for nursing women to discontinue breast-feeding during treatment with Rydapt and for at least 4 months after stopping treatment has been included in the Rydapt Product Monograph.

The main targets for toxicity identified in the non-clinical studies have been labelled in the Toxicology section of the Rydapt Product Monograph. However, because of differences in the biotransformation of midostaurin between humans and animal models, non-clinical exposure to midostaurin and its metabolites was much lower than clinical exposure. The major metabolites observed in humans were noted in the tested animal models, although important quantitative differences were observed. One of the major metabolites in humans is a minor metabolite in all the tested animal models. Therefore, the animal models provided little information on its potential toxicity. Furthermore, compared to animal models, relatively high exposure to unbound metabolites could be expected at high doses of Rydapt in humans. These differences represent important uncertainties on the relevance of some of the toxicological findings found in the non-clinical studies. The lack of safety issues in non-clinical studies results cannot be used to support the safety of Rydapt in humans.

For more information, refer to the Rydapt 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 Rydapt 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 36 months is acceptable. The package should not be stored above 30°C.

Proposed limits of drug-related impurities are considered adequately qualified (i.e. within International Council for Harmonisation 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.

There are no materials subject to transmissible spongiform encephalopathy (TSE) risk used in the manufacture of Rydapt.

The gelatin used in the Rydapt capsule is of porcine origin; the origin is from European countries.

Carmine in the printing ink is produced from carminic acid derived from insects, such as the cochenille louse; the origin is South America.

No other materials of animal origin are part of or used in the manufacturing process of Rydapt.