Summary Basis of Decision for Imfinzi
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 Imfinzi is located below.
Recent Activity for Imfinzi
The SBDs written for eligible drugs (as outlined in Frequently Asked Questions: Summary Basis of Decision [SBD] Project: Phase II) 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. The PAATs will be updated regularly with post-authorization activity throughout the product’s life cycle.
Post-Authorization Activity Table (PAAT) for Imfinzi
Updated: 2024-08-14
The following table describes post-authorization activity for Imfinzi, a product which contains the medicinal ingredient durvalumab. 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 Guidance Document: The Management of Drug Submissions and Applications.
Drug Identification Number (DIN):
- DIN 02468816 - 50 mg/mL, durvalumab, solution, intravenous administration
Post-Authorization Activity Table (PAAT)
|
Activity/Submission Type, Control Number |
Date Submitted |
Decision and Date |
Summary of Activities |
|
SNDS # 282725 |
2024-01-10 |
Issued NOC 2024-05-29 |
Submission filed as a Level II – Supplement (Safety) to update the PM with new safety information. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Dosage and Administration, Warnings and Precautions, and Adverse reactions sections of the PM. An NOC was issued. |
|
NC # 279594 |
2023-09-29 |
Issued NOL 2024-01-03 |
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 # 278423 |
2023-08-22 |
Issued NOC 2023-12-27 |
Submission filed as a Level II – Supplement (Safety) to update the PM with new safety information. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Dosage and Administration, Warnings and Precautions, and Adverse reactions sections of the PM, and corresponding changes were made to Part III: Patient Medication Information. An NOC was issued. |
|
SNDS # 276636 |
2023-08-16 |
Issued NOC 2023-10-25 |
Submission filed as a Level II – Supplement (Safety) to update the PM with new safety information. The submission was reviewed and considered acceptable. The changes were in response to an Advisement Letter issued by Health Canada dated 2023-06-27, requesting AstraZeneca Canada Inc. to update the safety labelling. As a result of the SNDS, modifications were made to the Warnings and Precautions section of the PM. An NOC was issued. |
|
NC # 279474 |
2023-09-27 |
Issued NOL 2023-10-19 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change in the cell bank/seed bank manufacturing site. The submission was considered acceptable, and an NOL was issued. |
|
SNDS # 262057 |
2022-03-03 |
Issued NOC 2023-07-20 |
Submission filed as a Level I – Supplement to add a drug product manufacturing site. The submission was reviewed and considered acceptable. An NOC was issued. |
|
SNDS # 270903 |
2022-12-21 |
Issued NOC 2023-07-07 |
Submission filed as a Level I – Supplement for a change to a drug substance manufacturing facility. The submission was reviewed and considered acceptable. An NOC was issued. |
|
SNDS # 269876 |
2022-11-18 |
Issued NOC 2023-04-21 |
Submission filed as a Level II – Supplement (Safety) to update the PM with new safety information. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Dosage and Administration section of the PM. An NOC was issued. |
|
NC # 272533 |
2023-02-17 |
Issued NOL 2023-02-27 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change in the post‐approval stability protocol of the drug product. The submission was considered acceptable, and an NOL was issued. |
|
SNDS # 262782 |
2022-03-25 |
Issued NOC 2022-09-28 |
Submission filed as a Level I – Supplement for a new indication. The submission was reviewed under the Priority Review of Drug Submissions Policy. The indication authorized was: in combination with a gemcitabine-based chemotherapy, for the treatment of patients with locally advanced or metastatic biliary tract cancer. The submission was reviewed and considered acceptable, and an NOC was issued. A Regulatory Decision Summary was published. |
|
PBRER-C # 265916 |
2022-07-05 |
Filed 2022-09-28 |
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. PBRER-C for the period 2021-05-01 to 2022-04-30. The information was reviewed and considered acceptable. |
|
SNDS-C # 259689 |
2021-12-21 |
Issued NOC under NOC/c Guidance 2022-09-15 |
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance for NDS # 202953. The sponsor requested that the Letter of Undertaking be revised to replace the confirmatory trial DANUBE (study D419BC00001) with NILE (study D933SC00001). The submission was reviewed and considered acceptable, and an NOC was issued under the NOC/c Guidance. |
|
SNDS # 263966 |
2022-05-04 |
Issued NOC 2022-08-18 |
Submission filed as a Level II – Supplement (Safety) to update the PM with new safety information. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Warnings and Precautions and Dosage and Administration sections of the PM. An NOC was issued. |
|
SNDS # 259504 |
2021-12-13 |
Issued NOC 2022-04-04 |
Submission filed as a Level II – Supplement (Safety) to update the PM with new safety information. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Dosage and Administration and Adverse Reactions sections of the PM. An NOC was issued. |
|
SNDS # 251288 |
2021-03-31 |
Issued NOC 2022-02-22 |
Submission filed as a Level I – Supplement for a new dosing regimen of 1500 mg once every four weeks, for the urothelial carcinoma and non-small cell lung cancer indications. The submission was reviewed and considered acceptable, and an NOC was issued. |
|
SNDS # 256843 |
2021-09-21 |
Issued NOC 2022-02-17 |
Submission filed as a Level II – Supplement (Safety) to update the PM with new safety information. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Dosage and Administration and Adverse Reactions sections of the PM. An NOC was issued. |
|
SNDS-C # 249942 |
2021-02-26 |
Issued NOC under NOC/c Guidance 2022-02-08 |
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance for NDS # 202953. The submission filed the final results of studies CD-ON-MEDI4736-1108, PMC 3205-5 and PMC 3205-4. The data were reviewed and considered acceptable, and an NOC was issued under the NOC/c Guidance. |
|
NC # 259049 |
2021-11-26 |
Issued NOL 2022-02-01 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for an extension of the in-use shelf life of the drug product, and to change the drug substance specifications. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
PBRER-C # 254621 |
2021-07-07 |
Filed 2021-10-19 |
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. PBRER-C for the period 2020-05-01 to 2021-04-30. The information was reviewed and considered acceptable. |
|
SNDS # 252121 |
2021-04-26 |
Issued NOC 2021-09-21 |
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 and Dosage and Administration sections of the PM. An NOC was issued. |
|
SNDS # 246924 |
2020-12-04 |
Issued NOC 2021-06-14 |
Submission filed as a Level I – Supplement to add an alternate manufacturing site for the drug product. The data were reviewed and considered acceptable, and an NOC was issued. |
|
SNDS # 243395 |
2020-09-02 |
Issued NOC 2021-03-30 |
Submission filed as a Level II – Supplement (Safety) to update the PM with new safety information. The submission was reviewed and considered acceptable. As a result of the SNDS, modifications were made to the Warnings and Precautions section of the PM, and corresponding changes were made to Part III: Patient Medication Information. An NOC was issued. |
|
NC # 244326 |
2020-09-24 |
Issued NOL 2020-12-08 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for changes to the quality control testing of the drug product. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
PBRER-C # 241364 |
2020-07-07 |
Filed 2020-10-26 |
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. PBRER-C for the periods 2019-05-01 to 2019-10-31 and 2019-11-01 to 2020-04-30. The information was reviewed and considered acceptable. |
|
SNDS # 233107 |
2019-11-01 |
Issued NOC 2020-09-21 |
Submission filed as a Level I – Supplement for a new indication. The indication authorized was: in combination with etoposide and either carboplatin or cisplatin for the first-line treatment of adult patients with extensive-stage small cell lung cancer (ES-SCLC). The submission was reviewed and considered acceptable, and an NOC was issued. A Regulatory Decision Summary was published. |
|
NC # 239567 |
2020-05-22 |
Cancellation Letter Received 2020-06-29 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a change to the drug substance fermentation process. Additional information was to be incorporated, so the submission was cancelled administratively by the sponsor before review began. |
|
NC # 236862 |
2020-03-06 |
Issued NOL 2020-05-22 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for a scale-up of the drug product manufacturing process. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
NC # 234268 |
2019-12-09 |
Issued NOL 2020-01-06 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to add a testing site for the drug product. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
PBRER-C # 229553 |
2019-07-09 |
Cleared 2019-12-31 |
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. PBRER-C for the periods 2018-05-01 to 2018-10-31 and 2018-11-01 to 2019-04-30. The information was reviewed and considered acceptable. |
|
NC # 232450 |
2019-10-10 |
Issued NOL 2019-12-13 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for changes related to release and stability testing for the drug substance and drug product. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
NC # 231593 |
2019-09-13 |
Issued NOL 2019-10-28 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to include a list of product categories within the Certified Product Information Document (CPID) for a facility. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
SNDS-C # 222188 |
2018-11-21 |
Issued NOC 2019-08-23 |
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance for NDS # 208834. The submission filed the updated results of the PACIFIC study. The data were reviewed and considered acceptable. As a result of the submission, the conditions were removed from the NOC that had been issued 2018-05-04. A Regulatory Decision Summary was published. |
|
NC # 228581 |
2019-06-12 |
Issued NOL 2019-07-04 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for an extension of the in-use shelf life of the drug product. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
NC # 227900 |
2019-05-17 |
Issued NOL 2019-05-31 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) for changes to a drug substance manufacturing facility. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
New safety review |
Not applicable |
Started between 2019-03-01 and 2019-03-31 |
Health Canada started a safety review for Imfinzi related to hemolytic anemia (increased red cell destruction and a decreased red cell life span). |
|
PSUR-C # 218674 |
2018-07-26 |
Cleared 2019-01-09 |
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. PSUR-C for the period 2017-11-01 to 2018-04-30. The information was reviewed and found acceptable.
|
|
NC # 212868 |
2018-11-13 |
Issued NOL 2019-01-07 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to add a testing site for the drug product, and to add a manufacturing site for the drug product. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
NDS # 208834 |
2017-08-29 |
Issued NOC under NOC/c Guidance 2018-05-04 |
Submission filed to obtain market authorization to treat patients with locally advanced unresectable non-small cell lung cancer (NSCLC) whose disease has not progressed following platinum-based chemoradiation therapy. Regulatory Decision Summary published. |
|
NC # 214856 |
2018-03-26 |
Issued NOL 2018-04-26 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to change testing procedures for the drug substance and drug product. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
NC # 212947 |
2018-01-19 |
Issued NOL 2018-02-23 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to extend the shelf-life of the drug substance. The submission was reviewed and considered acceptable, and an NOL was issued.
|
|
NC # 212046 |
2017-12-12 |
Issued NOL 2018-01-16 |
Submission filed as a Level II (90 day) Notifiable Change (Moderate Quality Changes) to change the drug substance fermentation process. The submission was reviewed and considered acceptable, and an NOL was issued. |
|
Drug product (DIN 02468816) market notification |
Not applicable |
Date of first sale: 2017-11-20 |
The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations. |
|
NDS # 202953 |
2017-02-16 |
Issued NOC under NOC/c Guidance 2017-11-03 |
Notice of Compliance issued under the NOC/c Guidance for New Drug Submission. |
Summary Basis of Decision (SBD) for Imfinzi
Date SBD issued: 2018-02-22
The following information relates to the New Drug Submission for Imfinzi.
Durvalumab
50 mg/mL, solution, intravenous
Drug Identification Number (DIN): 02468816
AstraZeneca Canada Inc.
New Drug Submission Control Number: 202953
On November 3, 2017, Health Canada issued a Notice of Compliance under the Notice of Compliance with Conditions (NOC/c) Guidance to AstraZeneca Canada Inc. for the drug product Imfinzi. The product was authorized under the NOC/c Guidance on the basis of the promising nature of the clinical evidence, and the need for further follow-up to confirm the clinical benefit. Patients should be advised of the fact that the market authorization was issued with conditions.
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 Imfinzi is favourable for the treatment of patients with locally advanced or metastatic urothelial carcinoma who:
- have disease progression during or following platinum-containing chemotherapy
- have disease progression within 12 months of neoadjuvant or adjuvant treatment with platinum-containing chemotherapy
1 What was approved?
Imfinzi, an antineoplastic agent, was authorized for the treatment of patients with locally advanced or metastatic urothelial carcinoma who:
- have disease progression during or following platinum-containing chemotherapy
- have disease progression within 12 months of neoadjuvant or adjuvant treatment with platinum-containing chemotherapy
Marketing authorization with conditions was based on a promising tumour response rate and durability of response. An improvement in survival or disease-related symptoms has not been established.
No overall differences in safety or efficacy were reported between elderly patients (≥65 years of age) and younger patients (<65 years of age).
The safety and efficacy of Imfinzi in patients younger than 18 years of age have not been established.
Imfinzi is contraindicated for patients with a known hypersensitivity to durvalumab or to any ingredient in the formulation or component of the container. Imfinzi was approved for use under the conditions stated in the Imfinzi Product Monograph taking into consideration the potential risks associated with the administration of this drug product.
Imfinzi (50 mg/mL, durvalumab) is presented as a concentrate for solution for intravenous infusion. In addition to the medicinal ingredient, the solution contains L-histidine, L-histidine hydrochloride monohydrate, α,α-trehalose dihydrate, polysorbate 80, and water for injection.
For more information, refer to the Clinical, Non-clinical, and Quality (Chemistry and Manufacturing) Basis for Decision sections.
Additional information may be found in the Imfinzi Product Monograph, approved by Health Canada and available through the Drug Product Database.
2 Why was Imfinzi approved?
Health Canada considers that the benefit-risk profile of Imfinzi is favourable for the treatment of patients with locally advanced or metastatic urothelial carcinoma who:
- have disease progression during or following platinum-containing chemotherapy
- have disease progression within 12 months of neoadjuvant or adjuvant treatment with platinum-containing chemotherapy
Imfinzi was authorized under the NOC/c Guidance on the basis of the promising nature of the clinical evidence, and the need for further follow-up to confirm the clinical benefit.
In Canada, urothelial carcinoma is the fourth most common cancer among men and the twelfth most common cancer among women. Patients diagnosed with locally advanced or metastatic urothelial carcinoma have poor prognoses with approximately only 5.5% surviving at least 5 years. At the time advanced consideration under the NOC/c policy was granted, there were no authorized agents available to patients that have locally advanced or metastatic urothelial carcinoma who fail or progress after first-line platinum-based chemotherapy. Therefore, new treatment options are needed for patients with this life-threatening disease.
The market authorization with conditions was based primarily on a Phase I/II, global, multicentre, multi-cohort, open-label, single-arm trial, CD-ON-MEDI4736 -1108. For the purposes of this submission, the population of interest with respect to anti-tumour activity was the cohort of patients with locally advanced or metastatic urothelial carcinoma who had previously received platinum-based chemotherapy (number of patients = 182). Overall response rate (ORR) was the primary efficacy outcome. Overall response rate by programmed cell death ligand 1 (PD-L1) status (high versus low), based on the sponsor's pre-defined threshold, was also explored. Results observed in the urothelial carcinoma cohort demonstrated that Imfinzi was associated with a modest ORR of 17.6%. Patients classified as PD-L1 high were associated with a numerically greater ORR (27.4%) compared to those classified as PD-L1 low (4.1%). The observed responses were durable compared to previously reported responses obtained using cytotoxic salvage chemotherapies.
The safety profile of Imfinzi was well characterized in the clinical setting and is consistent with other authorized products that target the programmed cell death protein 1 (PD-1) and PD-L1 signaling pathway. A range of immune-mediated adverse events were observed with use of Imfinzi including: pneumonitis, hepatitis, colitis and diarrhea, renal and urinary disorders, and skin and subcutaneous tissue disorders. Immune-mediated endocrine disorders such as hypothyroidism and hyperthyroidism, adrenal insufficiency, hypopituitarism, diabetes insipidus and Type 1 diabetes mellitus were also observed in the overall program for Imfinzi. The observed immune-mediated adverse events were generally manageable with the use of corticosteroids, dose interruptions or discontinuation, and/or symptomatic management.
As part of the marketing authorization under the NOC/c Guidance for Imfinzi, Health Canada requested that the sponsor agree to several commitments to be addressed post-market. Commitments include (but are not limited to) submitting a Supplemental New Drug Submission - Confirmatory (SNDS-C), containing the final clinical report for the confirmatory trial D419BC00001 (DANUBE) along with an updated clinical report for the trial CD-ON-MEDI4736-1108. In addition, the sponsor is also to submit annual status reports on the progress of ongoing confirmatory trials along with maintaining the requested post-market safety monitoring commitments.
A Risk Management Plan (RMP) for Imfinzi was submitted by AstraZeneca 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 Imfinzi was accepted.
Overall, the promising evidence of efficacy is considered to outweigh the potential risks of Imfinzi in the context of a disease for which no other treatment is available. The safety profile of Imfinzi has been well characterized in non-clinical and clinical studies and is usually manageable with close monitoring and prompt intervention, where necessary. Appropriate warnings and precautions are in place in the Imfinzi Product Monograph to address the identified safety concerns and provide guidance on the management of potential adverse reactions. As described within the framework of the NOC/c Guidance, safety monitoring on the use of Imfinzi will be ongoing. Further evaluation will take place upon the submission of the requested studies after they become available.
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 Imfinzi?
The sponsor filed a request for Advance Consideration under the Notice of Compliance with Conditions (NOC/c) Guidance for the review of the new drug submission (NDS) for Imfinzi. An assessment was conducted and it was determined there was promising evidence of clinical effectiveness that the drug has the potential to provide effective treatment, prevention or diagnosis of a disease or condition for which no drug is presently marketed in Canada.
Submission Milestones: Imfinzi
| Submission Milestone | Date |
|---|---|
| Pre-submission meeting for Quality: | 2016-11-04 |
| Pre-submission meeting for Clinical: | 2016-09-29 |
| Acceptance of Advance Consideration under the Notice of Compliance with Conditions (NOC/c) Guidance: | 2016-12-28 |
| Submission filed: | 2017-02-16 |
| Screening | |
| Screening Acceptance Letter issued: | 2017-03-17 |
| Review | |
| On-Site Evaluation: | 2017-06-12 - 2017-06-16 |
| Review of Risk Management Plan complete: | 2017-09-07 |
| Quality Evaluation complete: | 2017-09-27 |
| Labelling Review complete, including Look-alike Sound-alike brand name assessment: | 2017-09-17 |
| Notice of Compliance with Conditions Qualifying Notice (NOC/c-QN) issued: | 2017-10-03 |
| Review of Response to NOC/c-QN: | |
| Response filed (Letter of Undertaking): | 2017-10-06 |
| Clinical Evaluation complete: | 2017-11-03 |
| Biostatistics Evaluation complete: | 2017-11-03 |
| Notice of Compliance (NOC) issued by Director General, Biologics and Genetic Therapies Directorate under the Notice of Compliance with Conditions (NOC/c) Guidance: | 2017-11-03 |
The Canadian regulatory decision on the quality, non-clinical, and clinical review of Imfinzi was based on a critical assessment of the data package submitted to Health Canada. The foreign reviews completed by 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?
In addition to requirements outlined in the Food and Drugs Act and Regulations, and in keeping with the provisions outlined in the Notice of Compliance with Conditions (NOC/c) Guidance, the sponsor has agreed to:
- Submit, as a Supplemental New Drug Submission-Confirmatory (SNDS-C), the final study report for the confirmatory trial D419BC00001 (DANUBE) entitled: A Phase III randomized, open-label, controlled, multicentre, global study of first-line MEDI4736 monotherapy and MEDI4736 in combination with tremelimumab versus standard of care chemotherapy in patients with unresectable stage IV urothelial cancer. This study is designed to evaluate the effect on overall survival of durvalumab monotherapy and durvalumab in combination with tremelimumab versus standard of care chemotherapy.
- The anticipated trial completion date for DANUBE is the third quarter of 2019 and the clinical study report for DANUBE will be available for submission by second quarter of 2020.
- Acknowledge that the indication for Imfinzi may be withdrawn if study D419BC00001 does not demonstrate that Imfinzi monotherapy is associated with an overall survival (OS) benefit that is both statistically and clinically significant (compared to standard of care).
- Treatment outcomes by programmed cell death ligand 1 (PD-L1) expression level as assessed by the Ventana PD-L1 (SP263 clone) Assay in DANUBE will be explored, specifically the predictive value of PD-L1 expression on both tumour infiltrating immune cells and tumour cells.
- Submit an updated clinical study report for trial CD-ON-MEDI4736-1108: A Phase I-II Study to Evaluate the Safety, Tolerability, and Pharmacokinetics of MEDI4736 in Subjects with Advanced Solid Tumours. The anticipated trial completion date for this clinical trial is the fourth quarter of 2017, with the final clinical study report with updated analyses of the duration of response for patients with urothelial carcinoma who have received prior platinum-based therapy, available for submission in the third quarter of 2018.
- Other Ongoing Studies
AstraZeneca has committed to completing a study to demonstrate the adequacy of the anti-drug antibodies (ADA) methods for detection of binding and neutralizing ADA in the presence of trough concentration of Imfinzi at steady state (Ctrough, ss). A final report will be available for submission in the second quarter of 2018.
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.
- 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
Durvalumab (the medicinal ingredient in Imfinzi) is a recombinant human immunoglobulin G1 kappa (IgG1κ) monoclonal antibody produced in Chinese hamster ovary (CHO) cells. Durvalumab binds to human programmed cell death ligand 1 (PD-L1) residing on tumour-infiltrating immune cells and tumour cells, thereby inhibiting interactions between PD-L1 and programmed cell death protein 1 (PD-1) and PD-L1 and CD80 (B7.1). Both of these interactions can provide inhibitory signals to T cells resulting in T-cell anergy and an attenuated anti-tumour response. By removing these inhibitory signals, the T-cell response against malignant cells can be enhanced, resulting in immune-mediated tumour cell death.
The pharmacokinetics (PK) of Imfinzi was studied in 1,324 patients with solid tumours with doses ranging from 0.1 to 20 mg/kg administered once every two, three or four weeks. Pharmacokinetic exposure increased more than dose-proportionally (non-linear PK) at doses <3 mg/kg and dose proportionally (linear PK) at doses ≥3 mg/kg. Steady state was achieved at approximately 16 weeks.
Based on the population pharmacokinetics analysis that included 1, 310 patients (dose ≥10 mg/kg), the covariate of age (19-96 years), body weight (34-149 Kg), gender, positive anti-drug antibody (ADA) status, albumin levels, lactate dehydrogenase (LDH) levels, creatinine levels, soluble PD-L1, tumour type, race, mild renal impairment (creatinine clearance [CrCL] 60 to 89 mL/min), moderate renal impairment (CrCL 30 to 59 mL/min), mild hepatic impairment (bilirubin ≤ upper limit of normal (ULN) and aspartate aminotransferase (AST) > ULN or bilirubin >1.0 to 1.5 × ULN and any AST), or Eastern Cooperative Oncology Group (ECOG) status were shown to have no clinically significant effect on the pharmacokinetics parameters.
The effect of moderate hepatic impairment (bilirubin >1.5 to 3 times ULN and any AST) or severe hepatic impairment (bilirubin >3.0 x ULN and any AST) on the pharmacokinetics of durvalumab is unknown.
The effect of severe renal impairment (CrCL 15 to 29 mL/min) on the pharmacokinetics of durvalumab is unknown.
Overall, the clinical pharmacological data submitted by the sponsor supports the use of Imfinzi for the recommended indication.
For further details, please refer to the Imfinzi Product Monograph, approved by Health Canada and available through the Drug Product Database.
Clinical Efficacy
The clinical efficacy of Imfinzi (durvalumab), in terms of tumour response rate, was evaluated primarily in one Phase I/II, global, multicenter, multi-cohort, open-label, single-arm clinical trial, CD-ON-MEDI4736-1108. The main objective of this trial was to determine the safety profile and the anti-tumour activity of Imfinzi monotherapy in a variety of advanced and malignant solid tumour types. For the purposes of this submission, the population of interest with respect to anti-tumour activity was the cohort of patients with locally advanced and metastatic urothelial carcinoma who had previously received platinum-based chemotherapy. A total of 191 patients were enrolled in this cohort. The evaluation of efficacy was based on 182 patients with locally advanced or metastatic urothelial carcinoma whose disease had progressed during or after a platinum-based therapy, including those patients whose disease had progressed within 12 months of receiving therapy in a neo-adjuvant or adjuvant setting (second line or greater urothelial carcinoma cohort). The remaining 9 patients were treatment naïve (or first line patients) and thereby excluded from the efficacy analysis.
Trial CD-ON-MEDI4736-1108
Clinical trial CD-ON-MEDI4736-1108 (hereafter referred to as trial 1108) was a Phase I/II, global, multicentre, multi-cohort, open-label, single-arm clinical trial which enrolled, in the urothelial carcinoma cohort, a total of 191 patients with locally advanced or metastatic urothelial carcinoma whose disease recurred or progressed after receiving platinum based chemotherapy.
Patients were administered Imfinzi 10 mg/kg intravenously over 60 minutes once every two weeks. Patients were followed for at least 16 weeks as of the data cut-off date and had tumour assessments at Weeks 6, 12, and 16 followed by every 8 weeks thereafter. Patients continued to receive Imfinzi for up to 12 months or until unacceptable toxicity or confirmed disease progression. In the absence of clinical deterioration, patients were permitted to continue to receive Imfinzi after confirmed progression of disease if investigators considered that they continued to derive a clinical benefit.
The median duration of follow-up for the 182 patients who had received prior platinum based chemotherapy was 5.57 months (range: 0.4 to 25.9 months). Overall, the enrolled patients represented a typical advanced urothelial carcinoma population that was predominantly male (72%) and of advanced age (median = 67 years). The majority of patients were considered to have advanced disease with poor prognoses (visceral and/or liver metastases present).
The primary efficacy endpoint was objective response rate based on Response Evaluation Criteria In Solid Tumours (RECIST v1.1) as assessed by a blinded independent central review group. The trial excluded patients with a history of immunodeficiency; medical conditions that required systemic immunosuppression; history of severe immune-mediated adverse reactions; untreated central nervous system metastases; human immunodeficiency virus; active tuberculosis, or hepatitis B or C infection. Additional efficacy endpoints included Duration of Response, Disease-Control Rate and Overall Survival.
In trial 1108, tumour specimens were evaluated for PD-L1 expression using the VENTANA PD-L1 (SP263 clone) immunohistochemical assay. Testing was performed prospectively at a central laboratory by pathologists trained in the use of the SP263 assay for the evaluation of PD-L1 expression. The test detects membrane and cytoplasmic PD-L1 expression by tumour cells and tumour associated immune cells (IC). Programmed cell death ligand 1 (PD-L1) status was determined by the percentage of tumour cells with any membrane PD-L1 staining above background or by the percentage of immune cells with PD-L1 staining (IC+) at any intensity above background. The percent of tumour area occupied by any tumour-associated immune cells (Immune Cells Present, ICP) was used to determine IC+, which is the percent area of ICP exhibiting PD-L1 positive immune cell staining. PD-L1 status is considered high if any of the following are met:
- ≥25% of tumour cells exhibit membrane staining; or,
- ICP >1% and IC+ ≥25%; or,
- ICP ≤1% and IC+ = 100%
If none of these criteria were met, PD-L1 status was considered low or negative.
Of the 182 patients that had received prior platinum based chemotherapy, 95 patients were classified as PD-L1 high, 73 patients as PD-L1 low or negative and 14 patients were not evaluable for PD-L1 status.
Efficacy results
Trial 1108 reported an objective response rate, for the previously treated (with platinum) urothelial carcinoma cohort of 17.6% (32/182; 95% confidence interval [CI]: 12.3%, 23.9%). The lower-bound of the 95% CI exceeded the pre-defined benchmark of 10%, which was based on a random effect meta-analysis of a variety of studies in which urothelial carcinoma patients, previously treated with platinum-based chemotherapy, were treated with single-agent salvage therapy. Thus, based on this endpoint, the study succeeded in meeting its primary efficacy endpoint. In exploratory assessments of objective response rate among patients with high or low/negative (low/neg) levels of PD-L1 expression, the objective response rates by the blinded independent central review group were 27.4% (95% CI : 18.7%, 37.5%) and 4.1% (0.9%, 11.5%), respectively. While not statistically significant, the data suggest there is a clinically meaningful difference in the rate of response between PD-L1 high and low/neg expressers. These data have been fully described in the Clinical Trials section of the Imfinzi Product Monograph in order to inform health care providers that certain PD-L1 expression subgroups may be more likely to respond to treatment than others.
The key secondary outcome was duration of response. Duration of response is a key secondary endpoint in trials of response rates for checkpoint inhibitors, mainly due to observations that responses achieved on checkpoint therapy are generally more durable than those observed with traditional chemotherapy regimens. The duration of response results are not mature; however, the results suggest that responses to durvalumab are prolonged. The median duration of response was reached only among the group of 4 responders classified as PD-L1 low/neg (12.25 months). Median duration of response was not reached among responders having high PD-L1 expression or in the overall group of responders. The lower bounds of the 95% CI for both the overall and PD-L1 high groups were estimated to be 6.1 months. The overall range of duration of response was 0.9+ to 19.9+ months (+ denotes ongoing response).
Time-to-event endpoints including progression free survival and overall survival were included in the submission; however, given the trial design (single-arm study), these endpoints were not considered in the assessment of benefit-risk profile. The sponsor has committed to characterize these endpoints further in at least one randomized controlled clinical study in patients with locally advanced or metastatic urothelial carcinoma.
In summary, Imfinzi, an immunotherapy designed to enhance the immune system's ability to mount an anti-tumour response, was studied as monotherapy in a single-arm study designed to evaluate the safety and anti-tumour effect. Imfinzi was associated with a modest overall response rate in a difficult-to-treat patient population. The observed responses were durable compared to previously reported responses obtained using cytotoxic salvage chemotherapies.
Given the lack of therapeutic options available to patients within the approved indication, the evidence provided in support of the efficacy of Imfinzi is considered promising such that the preliminary assessment of benefit-risk can be considered favourable. Confirmation of efficacy in a well-controlled, randomized clinical study is necessary to confirm the benefit-risk balance for Imfinzi and is a condition of authorization. Imfinzi has been granted -marketing authorization with conditions, pending further results to verify its clinical benefit. See question 4 What follow-up measures will the company take? Patients should be advised of the nature of the authorization.
Indication
The New Drug Submission for Imfinzi was filed by the sponsor with the following indication:
- Imfinzi (durvalumab) is indicated for the treatment of patients with locally advanced or metastatic urothelial carcinoma whose disease has progressed during or after platinum-based chemotherapy.
To ensure safe and effective use of the product, Health Canada approved the following indication:
- Imfinzi is indicated for the treatment of patients with locally advanced or metastatic urothelial carcinoma who:
- Have disease progression during or following platinum-containing chemotherapy
- Have disease progression within 12 months of neoadjuvant or adjuvant treatment with platinum-containing chemotherapy
For more information, refer to the Imfinzi Product Monograph, approved by Health Canada and available through the Drug Product Database.
Clinical Safety
The clinical safety of Imfinzi (durvalumab) was primarily evaluated in the urothelial carcinoma cohort of trial 1108 described in the Clinical Efficacy section. This cohort enrolled 191 patients with locally advanced or metastatic urothelial carcinoma. Of the 191 patients enrolled, 182 patients had urothelial carcinoma that had progressed during or after platinum-based chemotherapy or had progressed within 12 months of platinum-based neoadjuvant or adjuvant chemotherapy.
In general, Imfinzi monotherapy 10 mg/kg administered intravenously every two weeks was well-tolerated. Adverse reactions were generally manageable and reversible with interruption of dosing and treatment with immunosuppressants, such as corticosteroids.
Overall, and regardless of relationship to treatment, an adverse event was experienced by 99.0% (189/191) of treated patients. At least one serious adverse event (SAE) was reported in 54.5% (104/191) of patients (for 12 of these patients, disease progression was reported as an SAE) and 9 (4.7%) patients had treatment-related SAE. The most common SAEs (occurring in ≥2% of patients) were back pain (4.7%), urinary tract infection (4.2%), acute kidney injury (4.2%), general physical health deterioration (3.7%), sepsis (3.1%), abdominal pain (2.6%), vomiting (2.6%), hypercalcemia (2.6%), and pyrexia (2.1%). Of the 191 enrolled urothelial carcinoma patients, 15 (7.9%) had adverse events that resulted in death, including cardio respiratory arrest, subileus, general physical deterioration, immune-mediated hepatitis, chronic hepatic failure, sepsis, cerebrovascular accident, acute kidney injury and pneumonitis. Of these, investigators considered one Grade 5 event each of pneumonitis and immune-mediated hepatitis to be related to treatment with durvalumab.
The most common adverse events observed regardless of relationship to treatment (any Grade; occurring in ≥10% of patients) were fatigue (35.6%), constipation (25.7%), decreased appetite (22.5%), nausea (22.0%), anemia (18.3%), diarrhea (16.8%), back pain (16.8%), urinary tract infection (16.2%), fever (15.7%), peripheral edema (14.1%), vomiting (13.1%), cough (11.5%), dyspnea (11.5%), increased blood creatinine (11.0%), arthralgia (10.5%) and asthenia (10.5%). The majority of adverse events were Grade 1 or 2 (mild to moderate) in severity; Grade 3 or 4 adverse events were reported in 52 (27.2%) patients. The most common Grade 3 or 4 adverse events (>3% of patients) were anemia (9.9%), hyponatremia (5.8%), acute kidney injury (4.7%), urinary tract infection (4.2%), back pain (4.2%), fatigue, sepsis, hypercalcemia and asthenia (3.1% each). Treatment-related Grade 3 or 4 adverse events were reported in 6.8% of patients; the most common (≥1%) were increased aspartate aminotransferase (1.6%), increased alanine aminotransferase (1.0%), and increased gamma-glutamyl transferase (1.0%), all of which were generally manageable and reversible.
Adverse events (excluding disease progression) leading to the delay, interruption or discontinuation of Imfinzi occurred in 68 (35.6%), 3 (1.6%), and 9 (4.7%) patients, respectively. The most common reasons for dose delay (occurring in >1% of patients) were back pain (3.7%), urinary tract infection (2.6%), acute kidney injury (1.6%), aspartate aminotransferase increased (1.6%), gamma-glutamyl transferase increased (1.6%), and pneumonia (1.6%). The most common reason for dose discontinuation (occurring in ≥1% of patients) was general physical health deterioration in 2 (1.0%) patients.
In the urothelial carcinoma cohort (number of patients = 191) of trial 1108, a range of immune-mediated adverse events occurred. Immune mediated adverse events were defined as requiring the use of systemic corticosteroids/hormone replacement therapy with no clear alternate etiology. The types of immune-mediated adverse events observed were consistent with those observed in other clinical trials with products targeting programmed cell death protein 1 (PD-1) or PD-L1 and include: pneumonitis, hepatitis, colitis and diarrhea, renal and urinary disorders, and skin and subcutaneous tissue disorders.
For further information on immune-mediated adverse reactions (e.g., pneumonitis, hepatitis, colitis, endocrinopathies, nephritis, and rash/dermatitis) and frequency observed in the urothelial carcinoma cohort and overall trial population, refer to the Imfinzi Product Monograph.
Overall, the safety profile of Imfinzi was well characterized in the clinical setting and is considered consistent with other authorized products which target PD-1 and PD-L1 signaling pathway. Appropriate warnings and precautions are in place in the approved Imfinzi Product Monograph to address the identified safety concerns. In addition, a Risk Management Plan for Imfinzi has also been put in place to minimize risks associated with the product. As such, in view of the intended use of Imfinzi, currently there are no foreseen issues within this submission which preclude authorization of the product.
For more information, refer to the Imfinzi Product Monograph, approved by Health Canada and available through the Drug Product Database.
7.2 Non-Clinical Basis for Decision
The non-clinical development program included investigations of mechanism of action, anti-tumour activity, pharmacodynamics, pharmacokinetics, and toxicological profile. Non-clinical pharmacology was investigated in in vitro studies that used both biochemical and human immune cell-based experimental systems. Anti tumour activity was investigated in vivo using mouse models of human cancer and surrogate anti-mouse antibodies.
The non-clinical pharmacology studies indicate that durvalumab (the medicinal ingredient in Imfinzi) binds PD-L1 specifically and enhances T cell activation and function in the presence of a T cell activation signal. The data indicate that durvalumab requires human T cells to be present to inhibit the growth of tumors in mouse models of human cancer, and this supports the proposal that durvalumab modulates existing, antigen-specific, T cell receptor signals and that this enhancement of T cell activation is important to the mechanism of action.
The toxicological profile was investigated by tissue cross-reactivity studies (normal human and normal cynomolgus monkey), a pharmacokinetic/pharmacodynamic and dose range finding study in cynomolgus monkeys, and repeat-dose toxicity studies of up to 13 weeks duration in cynomolgus monkeys. An enhanced pre- and postnatal development study in cynomolgus monkeys was also submitted. The cynomolgus monkey was deemed the only relevant non-clinical species for evaluation of local and systemic toxicities of durvalumab primarily based on the observed high amino acid sequence identity between the PD-L1 in cynomolgus monkeys (cynoPD-L1) and the human PD-L1 (hPD-L1) and a similar affinity for binding of durvalumab.
Generally, there was no unexpected binding of durvalumab to human or monkey tissues, and there were no adverse clinical signs, changes in body weights, clinical pathology parameters, hematology parameters, or gross and microscopic pathology findings that were considered new or unexpected, and of clinical relevance to humans.
In the 4-week study, findings of reduced size of the thymus, and weight at the highest dose tested, were noted. This appeared to correlate with a reduction in the cellularity of the thymic cortex in individual animals; following the 8 week treatment-free period, there were no changes observed. In the 13 week study, an increase in incidence and/or severity of thymic involution or atrophy was observed in both sexes, but changes were reversed following an 8-week treatment-free period. Adverse findings observed in the dose-range finding and 4 week study were considered consistent with anti drug antibodies (ADA)-associated morbidity and mortality. The majority of monkeys in all studies tested positive for ADAs, but in the 4- and 13- week studies exposure was maintained in most animals throughout the dosing period.
An enhanced pre- and postnatal development study in cynomolgus monkeys was conducted to assess the potential effects of durvalumab on reproduction. The PD-1/PD-L1 pathway is known to play a central role in preserving pregnancy by maintaining maternal immune tolerance to the fetus. In this study, administration of durvalumab from the confirmation of pregnancy through to delivery at exposure levels approximately 6 to 20 times higher than those observed at the clinical dose of 10 mg/kg (based on AUC), was associated with premature delivery, fetal loss (abortion and stillbirth) and an increase in neonatal deaths relative to concurrent controls.
Overall, the non-clinical findings are regarded as consistent with the mechanism of action as a PD-L1 inhibitor, and there are no findings which are considered to preclude the authorization of durvalumab for use in patients, when appropriate labelling is in place.
For more information, refer to the Imfinzi Product Monograph, approved by Health Canada and available through the Drug Product Database.
7.3 Quality Basis for Decision
Expression of programmed cell death ligand-1 (PD-L1) protein is an adaptive immune response that helps tumours evade detection and elimination by the immune system. Programmed cell death ligand-1 (PD-L1) expression can be induced by inflammatory signals (e.g., interferon-gamma) and can be expressed on both tumour cells and tumour-associated immune cells present in the tumour microenvironment. Through its interactions with PD-1 and CD80 (B7.1), PD-L1 reduces cytotoxic T cell activity, proliferation, and cytokine production.
Durvalumab is a recombinant human immunoglobulin G1 kappa (IgG1κ) monoclonal antibody produced in Chinese hamster ovary (CHO) cells. Durvalumab acts by selectively blocking the interaction of PD-L1 with PD-1 and CD80 (B7.1) while leaving PD-1/PD-L2 interaction intact. The interaction of PD-L1 with PD-1 and CD80 (B7.1) can provide inhibitory signals to T cells resulting in T-cell anergy and an attenuated anti-tumour response. By removing these inhibitory signals through use of durvalumab, the T cell response against malignant cells can be enhanced, resulting in immune mediated tumour cell death.
Imfinzi (durvalumab) is supplied as a 50 mg/mL sterile solution for intravenous infusion in two presentations, 500 mg/vial and 120 mg/vial.
Characterization of the Drug Substance
Extensive characterization of the physicochemical, biological, and immunological properties of durvalumab and confirmation of its purity were performed using methods selected in accordance with International Council for Harmonisation (ICH) guidelines (ICH Q6B). These studies and the formal validation studies demonstrated that the drug substance manufacturing facility is able to consistently manufacture durvalumab of acceptable quality.
Manufacturing Process and Process Controls of the Drug Substance and Drug Product
The drug substance, durvalumab, is manufactured using CHO cells. The cell culture manufacturing process consists of expansion in seed bioreactors followed by inoculation of the production bioreactor. Upon completion of the production culture, durvalumab in the cell culture fluid is physically separated from the CHO cells by harvesting via centrifugation and filtration. After harvesting, durvalumab is purified by column chromatography, two viral reduction steps, as well as concentration and diafiltration to create the final drug product formulation.
The drug product manufacturing process consists of pre-filtration, sterile filtration, as well as aseptic fill and finish of the formulated drug substance. The sponsor has demonstrated the ability of the drug product manufacturing site to consistently produce drug product of acceptable quality.
The method of manufacturing and the controls used during the manufacturing process for both the drug substance and drug product are valid and considered to be adequately controlled within justified limits.
Control of the Drug Substance and Drug Product
Through Health Canada's lot release testing and evaluation program, consecutively manufactured final product lots were tested using a subset of release methods. The testing process confirmed that the methods used in-house are acceptable for their intended use and positively supported the quality review recommendation.
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 24-month shelf life at 2°C to 8°C for Imfinzi is considered acceptable when the product is protected from light and freezing and stored in the original package until time of use.
The proposed packaging and components are considered acceptable.
Facilities and Equipment
An On Site Evaluation (OSE) of the manufacturing facility for the drug substance was conducted from June 12 to 16, 2017. During the evaluation, four minor observations were noted which were subsequently resolved. As a result, the information obtained through the OSE supports the issuance of a Notice of Compliance (NOC).
An OSE for the drug product manufacturing facility was not conducted. An OSE for this facility will be conducted in the near future in conjunction with another similar submission. Given the timelines for the review of Imfinzi, it was not possible to conduct this OSE during the Imfinzi review period.
Adventitious Agents Safety Evaluation
The drug substance manufacturing process incorporates adequate control measures to prevent contamination and maintain microbial control. Pre-harvest culture fluid from each lot is tested to ensure freedom from adventitious microorganisms (bioburden, mycoplasma, and viruses). Purification process steps designed to remove and inactivate viruses are adequately validated.
Related Drug Products
| Product name | DIN | Company name | Active ingredient(s) & strength |
|---|---|---|---|
| IMFINZI | 02468816 | ASTRAZENECA CANADA INC | DURVALUMAB 50 MG / ML |