Summary Basis of Decision for Tresiba

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 Tresiba is located below.

Recent Activity for Tresiba

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 Tresiba

Updated: 2024-02-23

The following table describes post-authorization activity for Tresiba, a product which contains the medicinal ingredient insulin degludec. 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 Numbers (DINs):

DIN 02467860 – 100 U/mL, insulin degludec, Penfill (cartridge), solution, subcutaneous administration

DIN 02467879 – 100 U/mL, insulin degludec, Flextouch (pre-filled pen), solution, subcutaneous administration

DIN 02467887 – 200 U/mL, insulin degludec, Flextouch (pre-filled pen), solution, subcutaneous administration

Post-Authorization Activity Table (PAAT)

Activity/Submission Type, Control Number

Date Submitted

Decision and Date

Summary of Activities

Drug product (DIN 02467860) market notification

Not applicable

Date of first sale: 2023-01-30

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

NC # 268928

2022-10-20

Issued NOL 2023-01-10

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change in the auxiliary materials/reagents of biological origin. The submission was reviewed and considered acceptable, and an NOL was issued.

SNDS # 258642

2021-11-15

Issued NOC 2022-10-27

Submission filed as a Level I – Supplement to update the PM with new safety and efficacy information from the EXPECT clinical trial, related to use of Tresiba in pregnancy. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Warnings and Precautions; Adverse Reactions; Clinical Pharmacology; and Clinical Trials sections of the PM. An NOC was issued.

NC # 256257

2021-08-26

Issued NOL 2021-11-01

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change involving a drug product manufacturer/manufacturing facility. The submission was considered acceptable, and an NOL was issued.

SNDS # 250276

2021-03-08

Issued NOC 2021-07-23

Submission filed as a Level II – Supplement (Safety) to update the PM with new safety information 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 Warnings and Precautions; Adverse Reactions; and Dosage and Administration sections of the PM, and corresponding changes were made to Part III: Patient Medication Information and to the package inserts. An NOC was issued.

NC # 241530

2020-07-10

Issued NOL 2020-07-17

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change in the drug product manufacturing process. The submission was reviewed and considered acceptable, and an NOL was issued.

NC # 230477

2019-08-07

Issued NOL 2019-10-16

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for the addition of a drug product manufacturing site. The submission was reviewed and considered acceptable, and an NOL was issued.

NC # 224986

2019-03-11

Issued NOL 2019-05-07

Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for the modification of a primary container closure system. The submission was reviewed and considered acceptable, and an NOL was issued.

SNDS # 216199

2018-06-04

Issued NOC 2019-04-17

Submission filed as a Level I – Supplement to update the Product Monograph with new clinical data from a dedicated cardiovascular outcome trial (DEVOTE). The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Warnings and Precautions; Adverse Reactions; Dosage and Administration; and Clinical Trials sections of the PM. An NOC was issued.

SNDS # 208917

2017-09-08

Issued NOC 2018-07-17

Submission filed as a Level I – Supplement for new indication: for the treatment of pediatric patients (>2 years old) with Type 1 diabetes mellitus. Regulatory Decision Summary published.

Drug product (DINs 02467879, 02467887) market notification

Not applicable

Date of first sale: 2017-09-15

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

NDS # 198124

2016-09-13

Issued NOC 2017-08-25

Notice of Compliance issued for New Drug Submission.

 
Summary Basis of Decision (SBD) for Tresiba

Date SBD issued: 2017-11-28

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

Insulin Degludec
100 U/mL and 200 U/mL, Solution, Subcutaneous

Drug Identification Number (DIN):

  • DIN 02467860 - 100 U/mL, Penfill (cartridge)
  • DIN 02467879 - 100 U/mL, Flextouch (pre-filled pen)
  • DIN 02467887 - 200 U/mL, Flextouch (pre-filled pen)

Novo Nordisk Canada Inc.

New Drug Submission Control Number: 198124

 

On August 25, 2017, Health Canada issued a Notice of Compliance to Novo Nordisk Canada Inc. for the drug product Tresiba.

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/risk profile of Tresiba is favourable for once-daily treatment of adults with diabetes mellitus to improve glycemic control.

 

1 What was approved?

 

Tresiba, an antidiabetic agent, was authorized for the once-daily treatment of adults with diabetes mellitus to improve glycemic control.

Tresiba (insulin degludec injection) is an ultra-long-acting basal insulin analogue with a duration of action over 42 hours used to lower blood glucose. Insulin degludec is produced by a process that includes expression of recombinant deoxyribonucleic acid (DNA) in Saccharomyces cerevisiae followed by chemical modification.

Tresiba was authorized for the once-daily treatment of adults with diabetes mellitus to improve glycemic control.

Tresiba is not recommended for the treatment of diabetic ketoacidosis.

Tresiba is not indicated for use in the pediatric population.

In patients ≥65 years of age, no overall clinical differences in safety or effectiveness have been observed between elderly and adult patients.

Tresiba is contraindicated in patients who are hypersensitive to Tresiba (insulin degludec injection) or to any ingredient in the formulation or component of the container. Tresiba is also contraindicated during episodes of hypoglycemia. Tresiba was approved for use under the conditions stated in the Tresiba Product Monograph taking into consideration the potential risks associated with the administration of this drug product.

Tresiba is presented as a solution for subcutaneous injection in 3 mL cartridges (100 U/mL insulin degludec) and in a 3 mL pre-filled pen (100 U/mL and 200 U/mL insulin degludec). In addition to the medicinal ingredient insulin degludec, the solution also contains the following non-medicinal ingredients: glycerol, phenol, metacresol, zinc acetate, 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 Tresiba Product Monograph, approved by Health Canada and available through the Drug Product Database.

 

2 Why was Tresiba approved?

 

Health Canada considers that the benefit-risk profile of Tresiba is favourable for once-daily subcutaneous administration in the treatment of adults with diabetes mellitus to improve glycemic control. Insulin degludec, the active ingredient of Tresiba, lowers blood glucose by stimulating peripheral glucose uptake, especially by skeletal muscle and fat, and by inhibiting hepatic glucose production.

Insulin products are life-saving pharmacotherapy for patients with type 1 diabetes mellitus (T1DM) and are useful in controlling hyperglycemia for patients with type 2 diabetes mellitus (T2DM).

The efficacy of Tresiba for the approved indication was supported primarily by nine Phase III trials which evaluated Tresiba in patients with T1DM (studies 3583, 3585, and 3770) and in patients with T2DM (studies 3579, 3672, 3668, 3580, 3586, and 3582). The primary endpoint of the nine clinical trials was the change from baseline hemoglobin A1c (HbA1c) at end-of-treatment. Eight of the nine trials were designed as non-inferiority trials; the primary efficacy analysis was the estimated mean treatment difference in HbA1c reduction from baseline to end-of-study and the non-inferiority criterion was an upper limit 95% confidence interval (CI) <0.4%. One clinical trial (3580) was designed as a superiority trial comparing sitagliptin (an oral anti-diabetic agent) to Tresiba.

Results from all eight non-inferiority trials demonstrated that treatment with Tresiba for up to 52 weeks was non-inferior to treatment with either insulin glargine or insulin detemir. Results from the clinical trial 3580, which compared sitagliptin to Tresiba treatment demonstrated superiority of Tresiba over sitagliptin.

Based on 11 therapeutic confirmatory trials conducted in T1DM and T2DM patients, the overall safety profile of Tresiba was comparable to insulin glargine and insulin detemir. The most common serious adverse event observed was that of hypoglycemia; however, only hypoglycemic events classified as severe events requiring assistance from another person were reported as an adverse event. A warning with regard to the risk of hypoglycemia has been included in a Serious Warnings and Precautions box in the Tresiba Product Monograph.

The most frequently reported adverse events with Tresiba were viral upper respiratory tract infection, upper respiratory tract infection, headache, and diarrhea. The majority of adverse events were considered to be tolerable, reversible, and self-limiting.

A Risk Management Plan (RMP) for Tresiba was submitted by Novo Nordisk 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.

A Look-alike Sound-alike brand name assessment was performed and the proposed name Tresiba was accepted.

Overall, sufficient benefit of Tresiba therapy was demonstrated in the nine Phase III confirmatory trials. Tresiba was considered to have a favourable benefit-risk profile based on non-clinical and clinical trials. The identified safety issues can be managed through labelling and adequate monitoring. Appropriate warnings and precautions are in place in the Tresiba 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 Tresiba?

 

A New Drug Submission (NDS) (control number [no.] 150868) for Tresiba was filed in 2011. Upon review of this NDS, a signal of increased cardiovascular (CV) risk associated with Tresiba was derived from the pooled Phase III clinical program. However, adequate characterization of the cardiovascular safety profile of Tresiba was precluded by deficiencies in the cardiovascular safety database, and in the sponsor's Major Adverse Cardiovascular Event (MACE) meta-analysis. Consequently, a Notice of Deficiency (NOD) was issued to the sponsor on October 3, 2012. To address the identified deficiencies, Health Canada requested several new MACE analyses and an updated cardiovascular safety database. A NOD Response was filed by the sponsor on December 31, 2012 which included the requested post-hoc MACE analyses, but did not exclude a potential increase in the risk of major cardiovascular events associated with Tresiba. A NOD-Withdrawal (NOD-W) was issued by Health Canada on July 12, 2013. In the NOD-W letter issued to the sponsor, Health Canada requested new data based on a long-term cardiovascular outcome trial (CVOT) in diabetic patients with high cardiovascular risk (type 2 diabetes mellitus patients) to rule out the identified cardiovascular safety signal.

The sponsor refiled an NDS (control no. 198124) for Tresiba on September 13, 2016. In this refile submission, the sponsor provided interim data from CVOT 4080 (DEVOTE). Upon review of the NDS control no. 198124; Health Canada considered that the safety issues identified in the NOD-W for NDS 150868 had been adequately addressed. A Notice of Compliance (NOC) was therefore issued on August 25, 2017.

 

Submission Milestones: Tresiba

Submission Milestone Date
New Drug Submission (NDS) Control Number: 150868  
Submission filed: 2011-10-25
Screening 1  
Screening Acceptance Letter issued: 2011-12-09
Review 1  
Notice of Deficiency (NOD) issued by Director General, Biologics and Genetic Therapies Directorate (safety issues): 2012-10-03
Response filed: 2012-12-31
Screening 2  
Screening Acceptance Letter issued: 2013-02-13
Review 2  
Notice of Deficiency-Withdrawal (NOD/W) issued by Director General, Biologics and Genetic Therapies Directorate (safety issues): 2013-07-12
Refile NDS Control Number: 198124  
Submission filed: 2016-09-13
Screening  
Screening Acceptance Letter issued: 2016-10-31
Review  
On-Site Evaluation:  
Biostatistics completed: 2017-08-10
Quality Evaluation completed: 2017-02-15
Clinical Evaluation completed: 2017-08-15
Review of Risk Management Plan completed: 2017-06-22
Labelling Review complete, including Look-alike Sound-alike brand name assessment: 2017-08-24
Notice of Compliance (NOC) issued by Director General, Biologics and Genetic Therapies Directorate: 2017-08-25

 

The Canadian regulatory decision on the quality, non-clinical and clinical review of Trumenba 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 for post-market commitments are outlined in the Food and Drugs Act and Regulations.

 

6 What other information is available about drugs?

 

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

 

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

 

Clinical Pharmacology

The primary activity of insulin degludec (IDeg), the medicinal ingredient of Tresiba, is regulation of glucose metabolism. Insulin and its analogues lower blood glucose by stimulating peripheral glucose uptake, especially by skeletal muscle and fat, and by inhibiting hepatic glucose production. Insulin also inhibits lipolysis and proteolysis, and enhances protein synthesis.

The clinical pharmacology program of insulin degludec was comprised of 25 clinical studies conducted in patients with Type 1 diabetes mellitus (T1DM), Type 2 diabetes mellitus (T2DM), or healthy subjects and 7 in vitro studies conducted using human biomaterials (human cell lines, plasma, or tissues).

Two dosage forms were proposed: 100 U/mL and 200 U/mL. Results from studies (i.e., Study 3579 and 3672) comparing total glucose-lowering effect at steady-state demonstrated that there is no clinically relevant difference between 100 U/mL and 200 U/mL dosage forms when the same U/kg dose was administered.

The pharmacodynamic properties of IDeg in patients with T1DM or T2DM following subcutaneous administration were evaluated by the glucose-lowering effect measured by glucose infusion rate (GIR) using the glucose clamp technique. Time to maximum GIR was approximately 12 hours (range 11 to 14 hours) following subcutaneous dosing. The glucose-lowering effect of IDeg extends beyond 42 hours (the entire clamp period) following subcutaneous administration in patients with T1DM. At steady-state, the day-to-day variability of IDeg for glucose-lowering effect was about 20%. At dose levels of 0.4, 0.6, and 0.8 U/kg, the glucose-lowering effects of insulin degludec increased with increasing doses.

In single subcutaneous dose studies conducted in special populations, the systemic exposure (measured by the area under the curve from zero to 120 hours [AUC 0-120h]) decreased with increasing degree of hepatic impairment. The total exposure (AUC 0-120h) of IDeg slightly increased with severity of impaired renal function. As with all insulin products, IDeg should be initiated with caution in patients with hepatic or renal impairment with frequent glucose monitoring, and dosage should be adjusted on an individual basis.

The sponsor did not conduct clinical trials to investigate drug-drug interactions. In vitro drug-drug interactions studies showed that common protein-bound drugs (ibuprofen, warfarin, acetylsalicylate, salicylate), frequently used antidiabetic agents (glimepiride, metformin, sitagliptin, liraglutide) or fatty acids (palmitate, oleate, linoleate) did not affect IDeg binding to human serum albumin at therapeutically relevant drug concentrations. The potential insulin degludec drug-drug interaction (if any) is expected to be similar to that of regular human insulin products.

Overall, the clinical pharmacological data support the use of Tresiba for the specified indication.

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

Clinical Efficacy

Evaluation of the clinical efficacy of Tresiba was primarily based on three Phase III confirmatory clinical trials (3583, 3585, and 3770) conducted in patients with type 1 diabetes mellitus (T1DM), and five Phase III confirmatory clinical trials (3579, 3672, 3668, 3586, and 3582) conducted in patients with type 2 diabetes mellitus (T2DM). All eight clinical trials were randomised controlled open-label trials with a 'treat-to-target' approach using a predefined target fasting plasma glucose of <5 mmol/L. The primary endpoint in these trials was the change from baseline HbA1c at end-of-treatment. All eight trials were designed as non-inferiority trials; the non-inferiority criterion for the primary efficacy analysis (estimated mean treatment difference in HbA1c reduction from baseline to end-of-study) was an upper limit 95% confidence interval (CI) <0.4%.

In addition to these eight clinical trials, one additional Phase III confirmatory trial (3580) provided a superiority comparison of Tresiba with sitagliptin (an oral antidiabetic agent [OAD]).

Two additional therapeutic confirmatory trials evaluating Tresiba dosed three-times weekly were performed in T2DM patients (Trials 3718 and 3724), but failed to achieve non-inferiority of Tresiba versus insulin glargine (IGlar) with respect to hemoglobin A1c (HbA1c) reduction, and were not used in support of any aspect of the proposed dosing regimen.

Detailed descriptions of each of the nine Phase III confirmatory trials are as follows:

Type 1 Diabetes Mellitus Trials

In all three clinical trials (3583, 3585, and 3770) conducted in type 1 diabetes mellitus (T1DM) patients, study basal insulin was evaluated in combination with insulin aspart (IAsp) as mealtime insulin. All patients enrolled had previously been treated with a basal-bolus insulin regimen and had HbA1c ≤10%. The 100 U/mL formulation of Tresiba was evaluated in these trials

Trial 3583

Clinical trial 3583 was a 52-week randomized, controlled, multinational, open-label trial comparing the efficacy and safety of Tresiba and IGlar in patients with T1DM.

The trial design included a screening visit to assess eligibility, followed approximately one week later by a randomization visit (Week 0) to assign treatment groups. A total of 629 patients were randomized in a 3:1 ratio to a treat-to-target basal/bolus insulin regimen with either Tresiba or IGlar, both in combination with IAsp as mealtime insulin. Tresiba was administered once daily with the evening meal. IGlar was administered once daily at any consistent time of day that was in accordance with local labelling.

Beginning at Week 1, the patient's basal insulin dose was titrated weekly, based on pre-breakfast self-measured plasma glucose values. After 8 weeks, bolus insulin doses could be optimized based on pre-meal self-measured plasma glucose values. After 26 weeks, a less intensive bi-weekly visit schedule was introduced. The total treatment period was 52 weeks. At the end of treatment with Tresiba or IGlar, the basal insulin was switched to twice daily neutral protamine Hagedorn (NPH) insulin. A follow-up visit was scheduled one week after the end of treatment to assess patients for any safety issues and to measure insulin antibodies.

Trial 3585

Clinical trial 3585 was a 26-week randomized, controlled, multinational open-label trial comparing the efficacy and safety of Tresiba and insulin detemir (IDet) in patients with T1DM.

The trial design included a screening visit followed approximately one week later by a randomization visit (Week 0) to assign treatment groups. A total of 456 patients were randomized in a 2:1 ratio to a treat-to-target basal/bolus insulin regimen with either Tresiba or IDet, both in combination with IAsp as mealtime insulin. Tresiba was administered once daily with the evening meal. IDet was administered once daily at any consistent time of day that was in accordance with local labelling.

Beginning at Week 1, the patient's basal insulin dose was titrated weekly, based on pre-breakfast self-measured plasma glucose values. After 8 weeks, bolus insulin doses could be optimized based on pre-meal self-measured plasma glucose values. If glycemic control was inadequate after at least 8 weeks of treatment, IDet could be given twice daily. The total treatment period was 26 weeks. At the end of treatment with Tresiba or IDet, the basal insulin was switched to twice daily NPH insulin. A follow-up visit was scheduled one week after the end of treatment to assess patients for any safety issues and to measure insulin antibodies.

Trial 3770

Clinical trial 3770 was a 26 week randomized, controlled, multinational open-label trial comparing the safety and efficacy of Tresiba and IGlar in patients with T1DM. This study provided an evaluation of "flexible" Tresiba dosing.

The trial design included a screening visit followed approximately one week later by a randomization visit (Week 0) to assign treatment groups. A total of 493 patients were randomized in a 1:1:1 ratio to a treat-to-target basal/bolus insulin regimen with either Tresiba administered once daily with the evening meal (Tresiba OD), Tresiba administered once daily at alternating narrow (8 to 12 hours) and wide (36 to 40 hours) dosing intervals (Tresiba Flex) or IGlar administered once daily at any consistent time of day that was in accordance with local labelling.

During the 26 week treatment period, both basal and bolus insulin doses were self-titrated by patients, according to a titration guideline. Further guidance for insulin self-titration was provided at weekly visits or phone contacts with the trial site. Basal insulin dose was to be adjusted on Mondays, Wednesdays and Fridays, based on pre-breakfast self-measured plasma glucose values. Bolus insulin doses were adjusted based on pre-meal values. At the end of treatment with Tresiba or IGlar, the basal insulin was switched to twice daily NPH insulin. A follow-up visit was scheduled one week after the end of treatment to assess patients for any safety issues and to measure insulin antibodies.

Efficacy Results

With respect to change in HbA1c from baseline, and with a non-inferiority margin of 0.4%, treatment with Tresiba was non-inferior to treatment with control basal insulin. Estimated treatment differences (Tresiba - control insulin) were:

  • Trial 3583          -0.01 % (95% CI -0.14; 0.11)
  • Trial 3585          -0.09 % (95% CI -0.23; 0.05)
  • Trial 3770          +0.17% (95% CI +0.04; 0.30)

Analysis of change from baseline fasting plasma glucose was a confirmatory efficacy endpoint for Trials 3583 and 3585; however, statistical significance could not be inferred due to failure of the preceding endpoint in the hierarchical testing strategy that was used to control type 1 error in the confirmatory statistical analyses.

Type 2 Diabetes Mellitus Trials

The T2DM review was based primarily on six Phase III trials. Five of the six trials (3579, 3672, 3668, 3586, and 3582) compared Tresiba with IGlar and were designed as non-inferiority trials. The sixth trial (3580) was a superiority trial comparing Tresiba with sitagliptin. All patients enrolled had been diagnosed with T2DM for at least six months and had been treated with antidiabetic therapy for at least 3 months. A baseline body mass index (BMI) ≤ 40 kg/m2 was required. The 100 U/mL formulation of Tresiba was evaluated in these trials, except for study 3672 which allowed for a higher BMI (<45 kg/m2) and evaluated the 200 U/mL formulation of Tresiba. Trial sites were located in Asia, Europe, North America, South Africa and South America.

Trial 3579

Clinical trial 3579 was a 52-week randomized, controlled, multinational open-label trial comparing the efficacy and safety of Tresiba and IGlar in insulin-naive patients with T2DM treated with metformin, with or without additional OAD treatment, and with HbA1c 7.0 to 10.0%.

The trial design included a screening visit to assess eligibility followed one week later by a randomization visit (Week 0). At the randomization visit, the patient's current antidiabetic treatment was discontinued, except for metformin and (if applicable) dipeptidyl peptidase 4 (DPP-4) inhibitor. A total of 1,030 patients were randomized in a 3:1 ratio to treatment with either 10 units of Tresiba or 10 units of IGlar. Tresiba was administered once daily with the evening meal. IGlar was administered once daily at any consistent time of day that was in accordance with local labelling.

Beginning at Week 1, the patient's basal insulin dose was titrated weekly, based on pre-breakfast self-measured plasma glucose values. The total treatment period was 52 weeks. At the end of treatment with Tresiba or IGlar, the basal insulin was switched to twice daily NPH insulin. A follow-up visit was scheduled one week after the end of treatment to assess patients for any safety issues and to measure insulin antibodies.

Trial 3672

Clinical trial 3672 was a 26-week randomized, controlled, multinational open-label trial comparing the efficacy and safety of Tresiba 200 U/mL and IGlar in insulin-naïve patients T2DM treated with metformin, with or without additional OAD treatment, and with HbA1c 7.0 to 10.0%.

The trial design included a screening visit to assess eligibility followed one week later by a randomization visit (Week 0). At the randomization visit, the patient's current antidiabetic treatment was discontinued, except for metformin and (if applicable) DPP-4 inhibitor. A total of 460 patients were randomized in a 1:1 ratio to treatment with either 10 units of Tresiba or 10 units of IGlar. Tresiba was administered once daily with the evening meal. IGlar was administered once daily at any consistent time of day that was in accordance with local labelling.

Beginning at Week 1, the patient's basal insulin dose was titrated weekly, based on pre-breakfast self-measured plasma glucose values. The total treatment period was 26 weeks. At the end of treatment with Tresiba or IGlar, the basal insulin was switched to twice daily NPH insulin. A follow-up visit was scheduled one week after the end of treatment to assess patients for any safety issues and to measure insulin antibodies.

Trial 3668

Clinical trial 3668 was a 26-week randomized, controlled, multinational open-label trial comparing the efficacy and safety of Tresiba and IGlar in patients with T2DM treated with either OADs alone, OADs in combination with basal insulin or with basal insulin alone, and with HbA1c 7.0 to 11.0%. Permitted OADs were any combination of metformin, sulfonylureas, glinides and/or pioglitazone. This study assessed a flexible Tresiba dosing regimen (alternating narrow [8 - 12 hours] and wide [36 - 40 hours] dosing intervals) in T2DM patients.

The trial design included a screening visit to assess eligibility, followed one week later by a randomization visit (Week 0). At the randomization visit, the patient's current antidiabetic treatment was discontinued, except for up to three previous OADs (metformin, sulfonylureas, glinides and pioglitazone, as applicable). A total of 687 patients were randomized in a 1:1:1 ratio to either 10 units of Tresiba administered once daily with the evening meal (Tresiba OD), 10 units of Tresiba administered once daily with a flexible dosing regimen (Tresiba Flex) or 10 units of IGlar administered once daily at any consistent time of day that was in accordance with local labelling.

Beginning at Week 1, the patient's basal insulin dose was titrated weekly, based on pre-breakfast self-measured plasma glucose values. The total treatment period was 26 weeks. At the end of treatment with Tresiba or IGlar, the basal insulin was switched to twice daily NPH insulin. A follow-up visit was scheduled one week after the end of treatment to assess patients for any safety issues and to measure insulin antibodies.

Trial 3586

Clinical trial 3586 was a 26-week randomized, controlled, multinational open-label trial comparing the efficacy and safety of Tresiba and IGlar, in insulin-naïve patients with T2DM treated with metformin and/or a sulfonylurea or glinide, with or without an alpha-glucosidase inhibitor or DPP-4 inhibitor, and with HbA1c 7.0 to 10.0%. This study was conducted in Asia only.

The trial design included a screening visit to assess eligibility, followed one week later by a randomization visit (week 0). At the randomization visit, the patient's current OAD treatment was continued, except for DPP-4 inhibitors. A total of 435 patients were randomized in a 2:1 ratio to treatment with either 10 units of Tresiba or 10 units of IGlar. Tresiba was administered once daily with the evening meal. IGlar was administered once daily at any consistent time of day that was in accordance with local labelling.

Beginning at Week 1, the patient's basal insulin dose was titrated weekly, based on pre-breakfast self-measured plasma glucose. The total treatment period was 26 weeks. At the end of treatment with Tresiba or IGlar, the basal insulin was switched to twice daily NPH insulin. A follow-up visit was scheduled one week after the end of treatment to assess patients for any safety issues and to measure insulin antibodies.

Trial 3582

Clinical trial 3582 was a 52-week randomized, controlled, multinational open-label trial comparing the efficacy and safety of Tresiba and IGlar in patients with T2DM treated with any insulin regimen with or without OADs, and with HbA1c 7.0 to 10.0%.

The trial design included a screening visit to assess eligibility, followed one week later by a randomization visit (week 0). At the randomization visit, the patient's current antidiabetic treatment was discontinued, except for metformin and pioglitazone (if applicable). A total of 1,006 patients were randomized in a 2:1 ratio to treatment with either Tresiba or IGlar, both in combination with IAsp as mealtime insulin. Tresiba was administered once daily with the evening meal. IGlar was administered once daily at any consistent time of day that was in accordance with local labelling.

Beginning at Week 1, the patient's basal insulin dose was titrated weekly, based on pre-breakfast self-measured plasma glucose values. After 8 weeks, bolus insulin doses could be optimized based on pre-meal self-measured plasma glucose values. The total treatment period was 52 weeks. At the end of treatment with Tresiba or IGlar, the basal insulin was switched to twice daily NPH insulin. A follow-up visit was scheduled one week after the end of treatment to assess patients for any safety issues.

Efficacy Results

With respect to change in HbA1c from baseline, and with a non-inferiority margin of 0.4%, treatment with Tresiba was non-inferior to treatment with IGlar in all five non-inferiority trials (3579, 3672, 3586, 3582, and 3668) conducted in T2DM patients. Estimated treatment differences (IDeg - IGlar) were:

  • Trial 3579:          +0.09 % (95% CI -0.04; 0.22)
  • Trial 3672:          +0.04 % (95% CI -0.11; 0.19)
  • Trial 3668:          +0.04% (95% CI -0.12; 0.20)
  • Trial 3586:          +0.11 % (95% CI -0.03; 0.24)
  • Trial 3582:          +0.08 % (95% CI -0.05; 0.21)

Some studies (3579, 3572, 3586 and 3582) included change from baseline in centrally measured fasting plasma glucose as a confirmatory efficacy endpoint; however, statistical significance could not be inferred for these analyses due to failure of a preceding endpoint in the hierarchical testing strategy that was used to control type 1 error in the confirmatory statistical analyses.

Trial 3580

Clinical trial 3580 was a 26-week randomized, controlled, multinational open-label trial comparing the efficacy and safety of Tresiba and sitagliptin in insulin-naïve patients with T2DM treated with 1 to 2 OADs (metformin, sulphonylurea [SU], glinides and/or pioglitazone) and with HbA1c 7.0 to 10.0%.

The trial design included a screening visit to assess eligibility, followed one week later by a randomization visit (Week 0). A total of 458 patients were randomized in a 1:1 ratio to treatment with either 10 units of Tresiba or 100 mg of sitagliptin, in combination with the previous OAD(s). Tresiba was administered once daily when preferred by the subject, during waking hours and within a dosing window of a minimum of 8 hours and a maximum of 40 hours between injections. Sitagliptin was administered once daily. A follow-up visit was scheduled one week after the end of treatment to assess patients for any safety issues.

Beginning at Week 1, for patients randomized to Tresiba, the basal insulin dose was titrated weekly based on pre breakfast self-measured plasma glucose values. The dose of sitaglitpin was fixed. The total treatment period was 26 weeks.

Efficacy Results

Trial 3580 conducted in T2DM patients provided a superiority comparison of Tresiba versus sitagliptin. With respect to change in HbA1c from baseline, treatment with Tresiba was superior to treatment with sitaglitpin. The estimated treatment difference (IDeg - sitagliptin) was -0.43% (95% CI -0.61; -0.24).

 

 

Indication

The sponsor proposed the following indication for Tresiba: "Tresiba (insulin degludec) is an ultra-long-acting basal insulin analogue indicated for once daily subcutaneous administration for the treatment of adults with diabetes mellitus to improve glycemic control."

Following review of the NDS, Health Canada recommended the following indication: "Tresiba is indicated for once-daily treatment of adults with diabetes mellitus to improve glycemic control."

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

Clinical Safety

The safety of Tresiba was based primarily on the critical analysis of data derived from 11 therapeutic confirmatory trials. These 11 confirmatory trials consisted of nine Phase III clinical trials previously described in the Clinical Efficacy section and two additional therapeutic confirmatory trials (trials 3718 and 3724) which evaluated Tresiba dosed three times weekly in T2DM patients. Although the clinical trials 3718 and 3724 failed to achieve non-inferiority and were not used in support of any aspect of the proposed dosing regimen, these two trials where included as part of the safety data analysis.

In patients with T1DM, 1,102 patients were exposed to Tresiba and 467 patients were exposed to comparators. Patients enrolled in these studies were most frequently white (80.4%), males (56.3%), with a mean age of 42.7 years. Patients had a mean body mass index (BMI) of 25.8 kg/m2, a mean duration of diabetes of 17.3 years, a baseline mean HbA1c of 7.8%, and a baseline mean fasting plasma glucose level of 9.6 mmol/L.

In patients with T2DM, 3,173 were exposed to Tresiba and 1,802 were exposed to comparators. Patients were most frequently white (73.1%), males (56.5%), with a mean age of 57.9 years. Patients had a mean BMI of 30.9 kg/m2, a mean duration of diabetes of 10.2 years, a baseline mean HbA1c of 8.3%, and a baseline mean fasting plasma glucose level of 9.4 mmol/L.

The most commonly observed serious and severe adverse event in patients using insulin preparations, including Tresiba, was that of hypoglycemia. The actual frequency of hypoglycemic adverse events with use of Tresiba can be difficult to assess given identification of this adverse event depends on several factors. These factors may include: the applied definition of hypoglycemia, diabetes type, insulin dose, intensity of glucose control, background therapies, and other intrinsic and extrinsic patient factors. Therefore, caution is warranted if comparing rates of hypoglycemia between products, as this may be misleading and not representative of rates to be expected in clinical practice.

Based on therapeutic confirmatory trials conducted in patients with T1DM and T2DM, hypoglycemic episodes reported as adverse events were restricted to events of severe hypoglycemia. Severe hypoglycemia was defined as an episode requiring assistance of another person to actively administer carbohydrate, glucagon, or other resuscitative actions. The therapeutic confirmatory trials also assessed the occurrence of confirmed hypoglycemia, which comprised episodes of severe hypoglycemia as well as minor hypoglycemic episodes with a plasma glucose <3.1 mmol/L. The percentage of patients with T1DM randomized to Tresiba who experienced at least one episode of severe hypoglycemia and confirmed hypoglycemia, respectively, was as follows:

  • Trial 3583 + IAsp 52 weeks, 12.3% and 95.6%.
  • Trial 3585 + IAsp 26 weeks, 10.6% and 93.0%.
  • Trial 3770 + IAsp 26 weeks; Tresiba being administered at the same time each day, 12.7% and 99.4%.
  • Trial 3770 + IAsp 26 weeks; Tresiba being administered at alternating times, 10.4% and 93.9%.

The percentage of patients with T2DM randomized to Tresiba who experienced at least one episode of severe hypoglycemia and confirmed hypoglycemia, respectively, was as follows:

  • Trial 3579 + 1 to 2 OADs insulin naïve 52 weeks, 0.3% and 46.5%.
  • Trial 3672 + 1 to 2 OADs insulin naïve 26 weeks, 0% and 28.5%.
  • Trial 3668 T2DM ± 0 to 3 OADs 26 weeks; Tresiba being administered at the same time each day, 0.9% and 43.8%.
  • Trial 3668 T2DM ± 0 to 3 OADs 26 weeks; Tresiba being administered at alternating times, 0.4% and 50.9%.
  • Trial 3582 T2DM ± 0-2 OADs + IAsp 26 weeks, 4.5% and 80.9%.

Other frequently reported adverse events with use of Tresiba included viral upper respiratory tract infections, upper respiratory tract infections, headache, and diarrhea. Viral upper respiratory infections in T1DM patients were observed in 24.0% of patients treated with Tresiba versus 22.5% in patients treated with a comparator. For T2DM patients, viral upper respiratory infections were reported in 12.0% Tresiba-treated patients versus 9.7% in comparator-treated patients. Upper respiratory tract infections reported by T1DM patients was 11.9% in patients treated with Tresiba versus 10.1% in patients treated with a comparator. Headaches in T1DM patients were reported in 11.8% Tresiba-treated patients versus 10.5% in comparator-treated patients. Type 2 diabetes mellitus patients noted headaches with 8.8% in Tresiba-treatment group versus 6.7% in the comparator group. Diarrhea was reported in T1DM patients in 4.1% Tresiba-treated patients versus 4.9% in comparator-treated patients. Type 2 diabetes mellitus patients reported diarrhea in 6.2% Tresiba-treated patients versus 7.2% in comparator-treated patients.

The most frequently reported adverse events leading to treatment withdrawal included hypoglycemia, weight increase, and major adverse cardiovascular events.

Based on the 11 therapeutic confirmatory trials, it was demonstrated that there was a greater frequency and rate of medication errors in patients exposed to Tresiba compared to the comparator. Serious adverse events due to medication errors were relatively infrequent; however, they were exclusively reported in patients exposed to Tresiba. All reported serious adverse events occurred when bolus insulin was injected instead of basal insulin. Similarly, medication errors of moderate to severe intensity were reported at a markedly higher frequency in patients exposed to Tresiba (Number of patients [n]) = 25; 2.3%; 3.6 events per 100 patient years of exposure [PYE]) compared to comparator (n = 2; 0.4%; 0.7 events per 100 PYE). Overall, medication errors associated with Tresiba were similarly reported in patients with T1DM or T2DM. To minimize potential accidental medication errors, patients must visually check the Tresiba label and verify the correct dialed dosage units on the delivery device before each injection. These instructions have also been included in the Tresiba Product Monograph. As for patients who are blind or visually impaired, it is recommended these patients obtain assistance from another person who has good vision and is trained in using the delivery device.

As part of the safety analysis for Tresiba, the sponsor conducted a Major Adverse Cardiovascular Event (MACE) meta-analysis based on the pooled Phase III clinical trial data. During review of this data, a signal of increased cardiovascular risk was identified. However, adequate characterization of the cardiovascular safety profile of Tresiba was precluded by deficiencies in both the cardiovascular safety database and the sponsor's MACE meta-analysis. Therefore, Health Canada issued a Notice of Deficiency (NOD) to the sponsor on October 3, 2012 requesting several new MACE analyses based on an updated cardiovascular safety database. The sponsor submitted additional post-hoc MACE analyses in a NOD Response, but these did not exclude a potential increase in the risk of major cardiovascular events associated with Tresiba. As a result, a NOD-Withdrawal (NOD-W) was issued by Health Canada to the sponsor on July 12, 2013. In the NOD-W letter issued to the sponsor, Health Canada requested new data based on a long-term cardiovascular outcome trial (CVOT) to be conducted in T2DM patients at high cardiovascular risk, in order to rule out the identified cardiovascular safety signal.

To address the identified cardiovascular safety risk, the sponsor subsequently developed the DEVOTE (4080) trial. The DEVOTE trial was a prospective, long-term, multicentre, multi-national, randomized, double-blinded, parallel-group, active-controlled trial designed to assess cardiovascular safety of Tresiba compared to IGlar in patients with T2DM at high risk of cardiovascular events.

Following analysis of the interim results of the DEVOTE trial, Health Canada concluded that the DEVOTE interim results were statistically valid and demonstrated no evidence of increased cardiovascular risk associated with Tresiba. Definitive conclusions regarding the cardiovascular risk of Tresiba (including in select subpopulations) will be deferred until the final report analysis of the DEVOTE trial has been comprehensively evaluated. The sponsor has committed to filing the final report for DEVOTE to Health Canada as a supplemental New Drug Submission in early 2018.

As seen with other insulin products, another risk factor associated with the administration of Tresiba is the possible formation of anti-insulin antibodies. The detection of antibody formation is highly dependent on the sensitivity and specificity of the assay and may be influenced by several factors such as: assay methodology, sample handling, timing of sample collection, concomitant medication, and underlying disease. For these reasons, comparison of the incidence of antibodies to Tresiba with the incidence of antibodies in other studies or to other products may be misleading. As such, caution should be used when interpreting these results.

In clinical trials conducted in T1DM patients, 95.9% of patients who received Tresiba OD were positive for anti-insulin antibodies at least once during the clinical trials, including 89.7% that were positive at baseline. In clinical trials conducted in T2DM patients, 31.5% of patients who received Tresiba OD were positive for anti-insulin antibodies at least once during the studies, including 14.5% that were positive at baseline. The antibody incidence rates for T2DM may be under reported due to potential assay interference by endogenous insulin in samples in these patients. The presence of antibodies that affect clinical efficacy may necessitate dose adjustments to correct for tendencies, toward hyper- or hypoglycemia. As for the incidence of anti-insulin degludec antibodies, this has not yet been established.

Other possible risks associated with the use of Tresiba are as follows:

Hyperglycemia

Inadequate dosing and/or discontinuation of treatment in patients requiring insulin may lead to hyperglycemia and potentially to diabetic ketoacidosis. Furthermore, concomitant illness, especially infections, may lead to hyperglycemia and thereby cause an increased insulin requirement.

Hypokalemia

Hypokalemia is among the potential clinical adverse effects associated with the use of all insulin therapies. This potential clinical adverse effect may be relevant in patients who are on potassium lowering drugs or losing potassium through other means (e.g., diarrhea). Untreated hypokalemia may cause respiratory paralysis, ventricular arrhythmia, and death. As such, it is recommended that potassium levels be monitored in patients at risk for hypokalemia, if indicated (e.g., patients using potassium-lowering medications, patients taking medications sensitive to serum potassium concentrations).

Allergic Reactions

Severe, life-threatening, generalized allergy, including anaphylaxis, generalized skin reactions, angioedema, bronchospasm, hypotension, and shock may occur with any insulin, including Tresiba and may be life threatening. Hypersensitivity (manifested with swelling of tongue and lips, diarrhea, nausea, tiredness, and itching) and urticaria were rare and reported in 0.9% of patients treated with Tresiba.

Lipodystrophy

Long-term use of insulin, including Tresiba, can cause lipodystrophy at the site of repeated insulin injections. Lipodystrophy includes lipohypertrophy (thickening of adipose tissue) and lipoatrophy (thinning of adipose tissue) and may affect insulin absorption. It is therefore recommended to rotate insulin injection sites within the same region to reduce the risk of lipodystrophy. In the clinical program, lipodystrophy, lipohypertrophy, or lipoatrophy was rare and reported in 0.3% of patients treated with Tresiba.

Injection Site Reactions

Patients taking Tresiba may experience injection site reactions, including injection site hematoma, pain, hemorrhage, erythema, nodules, swelling, discoloration, pruritus, warmth, and injection site mass. In the clinical program, injection site reactions occurred rarely, i.e., in 3.8% of patients treated with Tresiba.

Weight Gain

Weight gain can occur with insulin therapy, including Tresiba, and has been attributed to the anabolic effects of insulin. In the clinical program after 52 weeks of treatment, patients with T1DM treated with Tresiba gained an average of 1.8 kg and patients with T2DM treated with Tresiba gained an average of 3.0 kg.

Peripheral Edema

Insulin, including Tresiba, may cause sodium retention and edema. In the clinical program, peripheral edema occurred in 0.9% of patients with T1DM and 3.0% of patients with T2DM treated with Tresiba.

Conclusion:

Overall, based on the critical analysis of the pooled safety data derived from the Phase III clinical trials, there is no pronounced trend suggestive of a clinically relevant safety risk associated with Tresiba in patients with T1DM or T2DM. These results are supported by additional extension studies, interim analysis of the cardiovascular outcome trial (DEVOTE), and international post-market experience, providing supplementary evidence suggestive of an overall favourable safety profile for Tresiba.

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

 

 

7.2 Non-Clinical Basis for Decision

 

The non-clinical pharmacology, pharmacokinetic, and toxicology studies have characterized the non-clinical profile of insulin degludec (the medicinal ingredient in Tresiba), in sufficient detail to support the intended clinical indication. In view of the intended use of Tresiba, the non-clinical data provided was considered adequate in support for its use for treatment of diabetes mellitus in humans.

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

 

 

7.3 Quality Basis for Decision

 

Characterization of the Drug Substance

Detailed characterization studies were performed to provide assurance that insulin degludec proposed for commercial use consistently exhibits the desired characteristics. 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

Process validation studies for insulin degludec were successfully performed to support commercial scale manufacture. The process consists of fermentation, recovery, modification, and purification.

Process validation and aseptic processing studies for Tresiba 100U/mL and 200 U/mL were successfully performed to support commercial scale manufacture. The processes consist of buffer preparation, mixing, filter sterilization and aseptic filling into cartridges.

The method of manufacturing and the controls used during the manufacturing process for both the drug substance and drug product Tresiba are valid and 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 insulin degludec 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 International Council for Harmonisation (ICH) guidelines.

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

The results for all of the batches were within the proposed specification limits.

In-house laboratory targeted testing results were in agreement with those provided on the Certificates of Analysis provided with the lots.

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 30-month shelf life when stored at 5°C ± 3°C for Tresiba 100 U/mL and 200 U/mL is considered acceptable.

The in-use stability data provided supports a 56 day in-use period at room temperature (below 30°C) for both strengths.

The proposed packaging and components are considered acceptable.

Facilities and Equipment

An On-Site Evaluation (OSE) of the facilities involved in the manufacture and testing of Tresiba drug substance and drug product was waived.

Adventitious Agents Safety Evaluation

Materials of biological origin are properly sourced and tested.