Summary Basis of Decision for Xydalba

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 Xydalba is located below.

Recent Activity for Xydalba

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.

Summary Basis of Decision (SBD) for Xydalba

Date SBD issued: 2019-01-08

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

Dalbavancin (supplied as dalbavancin hydrochloride)
500 mg/vial, powder for solution, intravenous

Drug Identification Number (DIN):

  • 02480522

Cipher Pharmaceuticals Inc.

New Drug Submission Control Number: 212390

On September 4, 2018, Health Canada issued a Notice of Compliance to Cipher Pharmaceuticals Inc. for the drug product Xydalba.

The market authorization was based on quality (chemistry and manufacturing), non-clinical (pharmacology and toxicology), and clinical (pharmacology, safety, and efficacy) information submitted. Based on Health Canada's review, the benefit-harm-uncertainty profile of Xydalba is favourable for the treatment of adult patients with acute bacterial skin and skin structure infections, caused by susceptible isolates of the following Gram-positive microorganisms: Staphylococcus aureus (including methicillin-susceptible and methicillin-resistant strains), Streptococcus pyogenes, Streptococcus agalactiae, Streptococcus dysgalactiae, Streptococcus anginosus group (including Streptococcus anginosus, Streptococcus intermedius, Streptococcus constellatus) and Enterococcus faecalis (vancomycin-susceptible strains).

1 What was approved?

Xydalba, an intravenous antibacterial agent, was authorized for the treatment of adult patients with acute bacterial skin and skin structure infections caused by susceptible isolates of the following Gram-positive microorganisms: Staphylococcus aureus (including methicillin-susceptible and methicillin-resistant strains), Streptococcus pyogenes, Streptococcus agalactiae, Streptococcus dysgalactiae, Streptococcus anginosus group (including Streptococcus anginosus, Streptococcus intermedius, Streptococcus constellatus) and Enterococcus faecalis (vancomycin-susceptible strains).

Xydalba has been studied in the treatment of cellulitis/erysipelas, major cutaneous abscesses, or wound infections. Other types of complicated skin infections (including diabetic foot ulcer, necrotizing fasciitis, or decubitus ulcer) have not been studied.

The safety and efficacy of Xydalba in patients younger than 18 years of age have not been established. Therefore, Health Canada has not authorized an indication for pediatric use.

Evidence from clinical studies suggests that use in the geriatric population (aged 65 years and older) is not associated with significant differences in safety or efficacy. The pharmacokinetics of Xydalba was not significantly altered with age. Accordingly, no dosage adjustment is necessary based on age.

Xydalba is contraindicated in patients who are hypersensitive to this drug or to any ingredient in the formulation, including any non-medicinal ingredient, or component of the container. No data are available on cross-reactivity between dalbavancin and other glycopeptides, including vancomycin and telavancin.

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

Xydalba (500 mg dalbavancin per vial, supplied as dalbavancin hydrochloride) is presented as lyophilized powder for solution. Non-medicinal ingredients include mannitol, lactose monohydrate, hydrochloric acid and/or sodium hydroxide (for pH adjustment only).

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

2 Why was Xydalba approved?

Health Canada considers that the benefit-harm-uncertainty profile of Xydalba is favourable for treatment of adult patients with acute bacterial skin and skin structure infections caused by susceptible isolates of the following Gram-positive microorganisms: Staphylococcus aureus (including methicillin-susceptible and methicillin-resistant strains), Streptococcus pyogenes, Streptococcus agalactiae, Streptococcus dysgalactiae, Streptococcus anginosus group (including Streptococcus anginosus, Streptococcus intermedius, Streptococcus constellatus) and Enterococcus faecalis (vancomycin-susceptible strains).

Serious skin infections remain a significant source of morbidity and mortality. Some cases of acute bacterial skin and skin structure infections involve deeper soft tissue and may require significant surgical intervention and parenteral antibiotic therapy. Systemic risk factors which predispose patients to severe forms of infection include diabetes mellitus, malnutrition, immune deficiencies, sensory neuropathies, chronic systemic illness, advanced age and smoking. The etiological agents in such cases are predominately Staphylococcus aureus, Streptococcus pyogenes, Streptococcus agalactiae, and group C and G streptococci, but often involve mixed Gram-positive and Gram-negative aerobic and anaerobic bacteria.

In Canada, there is currently one approved drug, Sivextro (tedizolid phosphate), indicated specifically for the treatment of acute bacterial skin and skin structure infections caused by susceptible strains of Gram-positive microorganisms. In addition, there are a number of other antimicrobial agents authorized in Canada for the treatment of complicated and uncomplicated skin and skin structure infections caused by methicillin-resistant Staphylococcus aureus (MRSA) in particular. These include vancomycin and telavancin (glycopeptides), daptomycin (a lipopeptide), clindamycin (a lincosamide), linezolid and tedizolid (oxazolidinones), doxycycline (a tetracycline), and trimethoprim-sulfamethoxazole. For methicillin-sensitive Staphylococcus aureus (MSSA) and group A beta-hemolytic streptococci (GAS) infections, there are various beta-lactam antibiotics available, including penicillins, cephalosporins and carbapenems. Some fluoroquinolones are also indicated for use in the treatment of skin and skin structure infections caused by MSSA and GAS.

Dalbavancin, the medicinal ingredient in Xydalba, is a second generation semi-synthetic lipoglycopeptide antibiotic. Its mechanism of action involves interruption of cell wall synthesis, which leads to bacterial cell death. There are currently no other products on the Canadian market with formulation and dosage/administration options offered by Xydalba. Xydalba has a long terminal elimination half-life allowing for a single-dose (1,500 mg) or a two-dose regimen (1,000 mg followed one week later by 500 mg) with the potential for minimizing patient non-compliance.

Xydalba has been shown to be efficacious in patients with acute bacterial skin and skin structure infections caused by susceptible Gram-positive microorganisms. The market authorization was based on three pivotal Phase III clinical trials (Study DUR001-301, Study DUR001-302 and Study DUR001-303). The efficacy and safety of the two-dose regimen of Xydalba versus the comparator regimen of vancomycin (with optional switch to oral linezolid) have been evaluated in Study DUR001-301 and Study DUR001-302. In addition, the safety and efficacy of a single 1,500 mg dose of Xydalba was compared to the two-dose regimen in Study DUR001-303. A statistical outcome of non-inferiority was demonstrated in all three studies.

Pooled safety data from 2,473 patients treated with Xydalba show that most common adverse reactions in patients treated with any regimen of Xydalba were nausea (4.7%), headache (3.8%), and diarrhea (3.4%). Serious adverse reactions occurred in 4.9% of patients. Main safety concerns for Xydalba included infusion-related reactions, Clostridium difficile-associated disease, hepatic effects, and hypersensitivity reactions, all of which have been highlighted in the Warnings and Precautions section of the approved Xydalba Product Monograph. Overall, the safety and tolerability profile of Xydalba two-dose regimen was comparable to the comparator agents. In addition, the safety and tolerability of the single dose regimen of Xydalba was shown to be similar to that of the two-dose regimen. The identified safety concerns have been adequately addressed in the approved Xydalba Product Monograph.

The efficacy and safety of Xydalba used in single doses greater than 1,500 mg (administered either as a single-dose or a two-dose regimen) have not been established. Similarly, the efficacy and safety of Xydalba in pediatric patients have not been established. Xydalba has not been studied in pregnant and breastfeeding women, or in severely immunocompromised patients. No data is currently available in patients with moderate or severe hepatic impairment (Child-Pugh Class B and C) and therefore, caution should be exercised when prescribing Xydalba to these populations. In addition, information on the use of Xydalba in patients with creatinine clearance less than 30 mL/min is limited. Accordingly, in this population, the recommended dose of Xydalba should be reduced to either 1,000 mg administered as a single infusion or 750 mg followed one week later by 375 mg. Furthermore, in the major trials in patients with acute bacterial skin and skin structure infections, the types of infections treated with Xydalba were confined to cellulitis, abscesses and wound infections only. Other types of skin infections have not been studied. These issues have been addressed through appropriate labelling in the Xydalba Product Monograph.

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

The submitted inner and outer labels, package insert and Patient Medication Information section of the Xydalba Product Monograph meet the necessary regulatory labelling, plain language and design element requirements.

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

Overall, the benefit-harm-uncertainty profile of Xydalba is considered positive for the target patient population. Xydalba could be a useful addition to the armamentarium of antibiotics for acute bacterial skin and skin structure infections, especially in the era of emerging antimicrobial resistance. The identified safety issues can be managed through labelling and adequate monitoring.

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 Xydalba?

The drug submission for Xydalba was granted a Priority Review status in accordance with the Priority Review Policy. Xydalba is indicated for use in the treatment of a serious disease, and is considered to provide an improved benefit-risk profile over therapies currently approved by Health Canada and available on the Canadian market.

Submission Milestones: Xydalba

Submission MilestoneDate
Request for priority status
Filed:2017-10-13
Approval issued by Director, Bureau of Medical Sciences:2017-11-15
Submission filed:2017-12-21
Screening
Screening Deficiency Notice issued:2018-01-15
Response filed:2018-02-27
Screening Acceptance Letter issued:2018-03-08
Review
Quality Evaluation complete:2018-08-31
Clinical Evaluation complete:2018-08-31
Review of Risk Management Plan complete:2018-08-02
Labelling Review complete, including Look-alike Sound-alike brand name assessment:2018-08-31
Notice of Compliance issued by Director General, Therapeutic Products Directorate:2018-09-04

Health Canada made a decision to use the foreign reviews conducted by the European Medicines Agency (EMA) and the United States Food and Drug Administration (FDA) for most parts of its evaluation of the clinical and non-clinical components of this submission, in accordance with the Draft Guidance Document: The Use of Foreign Reviews by Health Canada. The portions of the Canadian data package were consulted as necessary.

The EMA reviews were available for both the two-dose regimen (1,000 mg/500 mg, administered one week apart) and the single-dose regimen (1,500 mg administered as a single dose). The FDA review was provided for the two-dose regimen accompanied by several relevant documents for the single-dose administration of Xydalba.

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

Dalbavancin, the medicinal ingredient in Xydalba, is a semi-synthetic bactericidal lipoglycopeptide antibiotic active against susceptible strains of Gram-positive bacteria. This antibiotic interferes with cell wall synthesis by binding to the D-alanyl-D-alanine terminus of the stem pentapeptide in nascent cell wall peptidoglycan, thereby preventing cross-linking (transpeptidation and transglycosylation) of disaccharide subunits. Such disruption of the cell wall leads to bacterial cell death. Dalbavancin is bactericidal in vitro against Staphylococcus aureus and Streptococcus pyogenes at concentrations similar to those sustained throughout treatment in humans according to the recommended dosage regimen.

Dalbavancin has a long terminal elimination half-life (t1/2 = 346 hours) and mean plasma protein binding is approximately 93%. It is excreted in urine and feces.

Dalbavancin clearance was reduced and the area under the concentration-time curve (AUC) increased in patients with renal impairment. Hemodialysis did not appreciably remove dalbavancin after 3 hours. In patients with severe renal impairment (creatinine clearance less than 30 mL/min) and not receiving regular hemodialysis, the recommended dose should be reduced to either 1,000 mg dalbavancin administered as a single infusion or 750 mg dalbavancin followed one week later by 375 mg dalbavancin.

Dalbavancin pharmacokinetics in patients with mild hepatic impairment (Child-Pugh Class A) was similar to that observed in subjects with normal hepatic function. Therefore, no dose adjustment is recommended for patients with mild hepatic impairment. Mean values of area under the plasma concentration-time curve extrapolated through infinity (AUC0-∞) were lower in patients with moderate and severe hepatic impairment (Child-Pugh Class B and C). There are insufficient data to recommend an appropriate dosing regimen in these patients. Accordingly, caution should be exercised when prescribing Xydalba to patients with moderate or severe hepatic impairment.

No clinical drug-drug interaction studies have been conducted with Xydalba. There is minimal potential for drug-drug interactions between dalbavancin and cytochrome P450 (CYP450) substrates, inhibitors or inducers.

In the thorough QT study conducted, there was no apparent significant QTc prolongation effect of dalbavancin under the conditions tested.

The clinical pharmacological data support the use of Xydalba for the recommended indication.

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

Clinical Efficacy

The efficacy of Xydalba was supported by data derived from three pivotal Phase III clinical studies in patients with acute bacterial skin and skin structure infections (Study DUR001-301, Study DUR001-302 and Study DUR001-303).

Two-dose regimen of Xydalba (1,000 mg followed one week later by 500 mg)

The two-dose regimen of Xydalba was evaluated in 1,312 adult patients with acute bacterial skin and skin structure infections in two Phase III, randomized, double-blind, double-dummy, non-inferiority clinical studies of similar design, Study DUR001-301 and Study DUR001-302. Patients were treated for two weeks with either a two-dose regimen of intravenous Xydalba (1,000 mg Day 1; 500 mg Day 8) or intravenous vancomycin (1,000 mg or 15 mg/kg every 12 hours, with the option to switch to oral linezolid after 3 days). The total treatment duration ranged from 10 to 14 days. Xydalba-treated patients with creatinine clearance of less than 30 mL/min received 750 mg followed one week later by 375 mg. Approximately 5% of patients also received a protocol-specified empiric course of treatment with intravenous aztreonam for coverage of Gram-negative pathogens. The specific infections in these trials included: cellulitis (approximately 50% of patients across treatment groups), major abscesses (approximately 30%), and wound infections (approximately 20%). The median lesion area at baseline was 341 cm2. In addition to local signs and symptoms of infection, patients were also required to have at least one systemic sign of disease at baseline, defined as temperature 38°C or higher (approximately 85% of patients), white blood cell count greater than 12,000 cells/mm3 (approximately 40%), or 10% or more band forms on white blood cell differential (approximately 23%). The demographic and baseline characteristics were similar between the treatment and comparator arms in both trials.

In both studies, the primary endpoint was the clinical response rate where responders were defined as patients who had no increase from baseline in lesion area 48 to 72 hours after initiation of therapy, and had a temperature consistently at or below 37.6°C upon repeated measurement. The non-inferiority margin was -10%.

The primary endpoint analysis in both studies demonstrated that Xydalba was non-inferior to the regimen of vancomycin/linezolid. In Study DUR001-301, the clinical response rate was 240/288 (83.3%) in the Xydalba-treated group and 233/285 (81.8%) in the comparator group. The clinical response rates in Study DUR001-302 were 285/371 (76.8%) and 288/368 (78.3%) in the Xydalba-treated patients and the comparator-treated patients, respectively. Since the lower bound of the 95% confidence interval (CI) for the treatment difference was above -10% (-4.6% in Study DUR001-301 and -7.4% in Study DUR001-302), both studies met their primary objectives.

Single-dose regimen of Xydalba (1,500 mg)

The single-dose regimen of Xydalba (1,500 mg) was evaluated in a Phase IIIb, double-blind, non-inferiority clinical study (Study DUR001-303). The study included 698 adult patients with acute bacterial skin and skin structure infections who were treated with either a single 1,500 mg dose of Xydalba or a two-dose regimen of 1,000 mg followed one week later by 500 mg. Patients with creatinine clearance less than 30 mL/min had their dose adjusted. Approximately 5% of patients also received a protocol-specified empiric course of treatment with intravenous aztreonam for coverage of Gram-negative pathogens. The specific infections and other patient characteristics in this trial were similar to those in Study DUR001-301 and Study DUR001-302.

The primary endpoint was the clinical response rate where responders were defined as patients who had at least a 20% decrease from baseline in lesion area 48 to 72 hours after randomization without receiving any rescue antibacterial therapy. The results from this trial demonstrated that a single 1,500 mg dose of Xydalba was non-inferior to the two-dose regimen. The clinical response rate was 284/349 (81.4%) in the single-dose arm and 294/349 (84.2%) in the two-dose regimen arm, with a lower bound of the 95% CI of -8.5%.

Indication

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

  • Xydalba (dalbavancin for injection) is a lipoglycopeptide indicated for treatment of adult patients with acute bacterial skin and skin structure infections (ABSSSI) including treatment of bacteremia associated with these infections.

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

  • Xydalba (dalbavancin for injection) is indicated for treatment of adult patients with acute bacterial skin and skin structure infections (ABSSSI), caused by susceptible isolates of the following Gram-positive microorganisms: Staphylococcus aureus (including methicillin-susceptible and methicillin-resistant strains), Streptococcus pyogenes, Streptococcus agalactiae, Streptococcus dysgalactiae, Streptococcus anginosus group (including Streptococcus anginosus, Streptococcus intermedius, Streptococcus constellatus) and Enterococcus faecalis (vancomycin susceptible strains).

The following caveat statements have also been included in the approved indication:

  • Xydalba is not active against Gram-negative bacteria; therefore, combination therapy may be clinically indicated if the ABSSSI is polymicrobial and includes a suspected or documented Gram-negative pathogen.

  • Xydalba has been studied in the treatment of cellulitis/erysipelas, major cutaneous abscesses, or wound infections. Other types of complicated skin infections (including diabetic foot ulcer, necrotizing fasciitis, or decubitus ulcer) have not been studied.

  • To reduce the development of drug-resistant bacteria and maintain the effectiveness of Xydalba and other antibacterial drugs, Xydalba should be used only to treat infections that are proven or strongly suspected to be caused by susceptible bacteria. When culture and susceptibility information are available, they should be considered in selecting or modifying antibacterial therapy. In the absence of such data, local epidemiology and susceptibility patterns may contribute to the empiric selection of therapy.

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

Clinical Safety

The safety profile of Xydalba was evaluated in eight completed Phase II/III clinical studies comprising 2,473 patients treated with Xydalba. Of these, 1,778 patients were treated with Xydalba in seven Phase II/III trials comparing Xydalba to comparator antibacterial drugs, whereas 695 patients received Xydalba in one Phase III trial that compared the safety profile of the 1,500 mg single-dose regimen to the safety profile of the two-dose regimen (Study DUR001-303, described in the Clinical Efficacy section).

The most common adverse reactions in patients treated with any regimen of Xydalba included nausea (4.7%), headache (3.8%), diarrhea (3.4%), vomiting (2.4%), constipation (2.3%), pruritus (1.8%), and rash (1.7%). The median duration of adverse reactions was 3.0 days in patients treated with Xydalba. Serious adverse reactions occurred in 121/2,473 (4.9%) of patients treated with any regimen of Xydalba. Xydalba was discontinued due to an adverse reaction in 64/2,473 (2.6%) patients treated with any regimen of Xydalba.

A similar distribution of adverse events was seen in Study DUR001-303 in the single-dose and two-dose Xydalba treatment groups, although some events that were observed at a >1% rate in the overall Phase II/III database were reported at a rate <1%, including rash and pruritus.

Some special safety concerns for Xydalba included (but were not limited to):

  • Infusion-related reactions: There is a known association between glycopeptides and infusion-related reactions. An occurrence of "red man syndrome" following administration of a 1,500 mg dose of Xydalba was reported in one subject in the thorough QT trial.
  • Clostridium difficile-associated disease: In the Phase II/III safety database, Clostridium difficile-associated disease was reported in patients treated with Xydalba.
  • Hepatic effects: In the Phase II/III safety database, more Xydalba-treated subjects than comparator-treated subjects with normal baseline transaminase levels had post-baseline alanine aminotransferase (ALT) elevation greater than three times the upper limit of normal. Overall, abnormalities in liver tests (ALT, aspartate aminotransferase, bilirubin) were reported with similar frequency in the Xydalba and comparator arms.
  • Hypersensitivity reactions: Among patients treated with Xydalba, one patient experienced an anaphylactoid reaction whereas several patients experienced rash and pruritus.

Overall, the safety and tolerability profile of the Xydalba two-dose regimen (1,000 mg Day 1; 500 mg Day 8) was comparable to that seen for patients treated with the comparator agents. Furthermore, the safety and tolerability of the single-dose (1,500 mg) Xydalba regimen was similar to that of the two-dose Xydalba regimen. Appropriate warnings and precautions are in place in the approved Xydalba Product Monograph to address the identified safety concerns.

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

7.2 Non-Clinical Basis for Decision

The comprehensive non-clinical data and the international information submitted (i.e., decision summaries and assessment reports produced by the United States Food and Drug Administration and the European Medicines Agency) support the use of Xydalba (dalbavancin) for the specified indication.

Results of the non-clinical safety pharmacology studies of dalbavancin did not indicate any effects on the cardiovascular, respiratory, central nervous system and autonomic nervous system. There were modest declines in blood pressure and small increases in heart rate, which were associated with hives, skin swelling and erythema, and were attributed to histamine release. Safety pharmacology studies conclude that dalbavancin does not affect cardiac conduction or circulatory parameters.

In repeat dose toxicology studies (up to 3 months of exposure) dalbavancin was shown to induce similar systemic toxicity in both rats and dogs. In both species, the main target organs were kidneys, liver and the hematological system.

The reproductive and developmental toxicity studies in rats reported a reduced fertility and an increased incidence of embryo lethality, reductions in fetal weight and skeletal ossification and increased neonatal mortality. In addition, in rabbits, abortion occurred in conjunction with maternal toxicity at exposures below the human therapeutic range doses. In both rats and rabbits, no evidence of a teratogenic effect was found. Dalbavancin was found to cross the placenta and to be excreted in the milk of rats.

Dalbavancin was not genotoxic in in vitro bacterial and mammalian cell assays for gene mutation and chromosomal damage and in in vivo mouse micronucleus assay. No carcinogenicity studies have been performed, which was considered acceptable given the short clinical dosage regimen and the negative results obtained in the genotoxicity studies.

Considering the administration of only two doses to humans, one week apart, possible accumulation and related histopathological changes seen in repeat dose toxicology studies are not likely to be of relevance for the clinical use of Xydalba.

The results of the non-clinical studies as well as the potential risks to humans have been included in the Xydalba Product Monograph. In view of the intended use of Xydalba, there are no pharmacological or toxicological issues within this submission which preclude authorization of the product.

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

7.3 Quality Basis for Decision

The Chemistry and Manufacturing information submitted for Xydalba has demonstrated that the drug substance and drug product can be consistently manufactured to meet the approved specifications. Proper development and validation studies were conducted, and adequate controls are in place for the commercial processes. Changes to the manufacturing process and formulation made throughout the pharmaceutical development are considered acceptable upon review. Based on the stability data submitted, the unreconstituted Xydalba should be stored at 25ºC, with excursions permitted between 15ºC and 30ºC.

Proposed limits of drug-related impurities are considered adequately qualified, i.e., within International Council for Harmonisation limits and/or qualified from toxicological studies.

All sites involved in production are compliant with Good Manufacturing Practices.

All non-medicinal ingredients (described earlier) found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations.

The excipient lactose monohydrate is derived from milk obtained from healthy animals under the same conditions as milk collected for human consumption. Satisfactory information has been provided to establish that this excipient does not pose a risk of contamination with transmissible spongiform encephalopathy agents.