Summary Basis of Decision for Palynziq
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 Palynziq is located below.
Recent Activity for Palynziq
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 Palynziq
Date SBD issued: 2022-07-13
The following information relates to the new drug submission for Palynziq.
Pegvaliase
Drug Identification Number (DIN):
- DIN 02526247 - 2.5 mg/0.5 mL pegvaliase, solution, subcutaneous administration
- DIN 02526255 - 10 mg/0.5 mL pegvaliase, solution, subcutaneous administration
- DIN 02526263 - 20 mg/mL pegvaliase, solution, subcutaneous administration
BioMarin International Ltd.
New Drug Submission Control Number: 251687
On March 30, 2022, Health Canada issued a Notice of Compliance to BioMarin International Limited for the drug product Palynziq.
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-risk profile of Palynziq is favourable for the reduction of blood phenylalanine concentrations in patients with phenylketonuria (PKU) aged 16 years and older who have inadequate blood phenylalanine control (blood phenylalanine levels greater than 600 micromol/L) despite dietary management.
1 What was approved?
Palynziq, a recombinant phenylalanine ammonia lyase enzyme, was authorized for the reduction of blood phenylalanine concentrations in patients with phenylketonuria (PKU) aged 16 years and older who have inadequate blood phenylalanine control (blood phenylalanine levels greater than 600 micromol/L) despite dietary management.
The data supporting the efficacy and safety of Palynziq in adolescent patients aged 16 to less than 18 years of age are limited. No data are available to support the efficacy and safety of Palynziq in patients less than 16 years of age.
No data are available to support the efficacy and safety of Palynziq in geriatric patients.
Palynziq (2.5 mg/0.5 mL, 10 mg/0.5 mL, and 20 mg/mL pegvaliase) is presented as a solution. In addition to the medicinal ingredient, the solution contains sodium chloride, trans-cinnamic acid, trometamol, trometamol hydrochloride, and water for injection.
The use of Palynziq is contraindicated in:
- patients who have had a severe systemic hypersensitivity reaction (e.g., severe serum sickness, severe angioedema, or severe anaphylactic reaction) or a recurrence of a mild to moderate anaphylactic reaction to Palynziq or to any ingredient in the formulation, including any non-medicinal ingredient or component of the container.
- patients who have had an anaphylactic reaction to a product containing polyethylene glycol (PEG) or to another product containing a PEGylated ingredient.
The drug product was approved for use under the conditions stated in its Product Monograph taking into consideration the potential risks associated with its administration. The Palynziq Product Monograph is available through the Drug Product Database.
For more information about the rationale for Health Canada's decision, refer to the Clinical, Non-clinical, and Quality (Chemistry and Manufacturing) Basis for Decision sections.
2 Why was Palynziq approved?
Health Canada considers that the benefit-risk profile of Palynziq is favourable for the reduction of blood phenylalanine concentrations in patients with phenylketonuria (PKU) aged 16 years and older who have inadequate blood phenylalanine control (blood phenylalanine levels greater than 600 micromol/L) despite dietary management.
Phenylketonuria is a rare autosomal recessive genetic disorder in which patients have an abnormal gene for phenylalanine hydroxylase (PAH), an enzyme that breaks down the amino acid phenylalanine. A diagnosis of PKU is usually confirmed shortly after birth, as PKU testing is standard practice in Canada immediately after birth.
In healthy individuals, blood phenylalanine levels are around 60 micromol/L. These levels typically rise to over 1,200 micromol/L in individuals with severe untreated PKU. An elevated blood phenylalanine level is toxic to brain cells as it inhibits protein synthesis. This leads to abnormal morphology of myelinating proteins and arrested or delayed development of dendrites and synapses in the cerebral cortex. Sustained phenylalanine-induced toxicity is associated with substantial deficiencies and/or abnormalities in psychosocial metrics, psychological disorders, executive dysfunction, cognitive abilities, and overall quality of life.
The prevalence of PKU varies geographically, but is estimated to occur in approximately 1 in 12,000 live births in Canada. Disease severity can vary depending on whether PAH is profoundly deficient or completely absent, and whether dietary and non-dietary treatments have been successful. The goal of treatment for PKU is to decrease blood phenylalanine levels to the sub-toxic range of 120 to 360 micromol/L. Phenylketonuria is managed primarily by restricting the patient’s dietary intake of phenylalanine, which usually requires intake of low phenylalanine medical foods formulated specifically for patients with PKU. Restrictions must be undertaken as soon as possible, preferably within the first week of life, and continued throughout the patient’s lifetime.
Prior to the authorization of Palynziq, the only drug authorized in Canada for the treatment of PKU was sapropterin dihydrochloride, a synthetic cofactor that improves phenylalanine metabolism in patients with residual PAH activity. An estimated 25% to 50% of patients with PKU are responsive to sapropterin. Additional treatment options are therefore required to address the needs of this patient population.
Palynziq (pegvaliase) is a recombinant phenylalanine ammonia lyase (rAvPAL) enzyme to which polyethylene glycol (PEG) moieties have been added. Pegvaliase provides an alternate pathway for the breakdown of phenylalanine than that of endogenous PAH. The rAvPAL enzyme converts phenylalanine to ammonia and trans-cinnamic acid, thereby reducing the elevated blood phenylalanine levels characteristic of PKU. The addition of PEG increases the half-life of the enzyme and decreases immunogenicity.
The clinical efficacy of Palynziq was mainly evaluated in Study 302, which was conducted in patients who had previously participated in Study 301 (a safety and tolerability study). Both were Phase III studies conducted in patients with PKU aged 16 years or older with a mean blood phenylalanine level greater than 600 micromol/L at screening and on average over the 6 months prior to screening. Dosing in Study 301 included induction, titration, and maintenance periods, while Study 302 was intended to demonstrate the efficacy and safety of maintenance treatment with Palynziq.
Study 302 was organized into four parts, with Part 2, an 8-week randomized discontinuation trial (RDT) period identified as the primary focus of the clinical efficacy assessment. During the RDT part of the study, there were 29 patients in each of the groups remaining on the maintenance regimens of 20 mg or 40 mg Palynziq once daily, and 14 patients in each of the groups receiving 20 mg or 40 mg placebo once daily. None of the patients who entered the RDT period of the study were less than 18 years of age.
The primary endpoint of Study 302 was the change in blood phenylalanine levels from baseline of the RDT to Week 8 of the RDT. The actively treated pool of 58 patients consisted of 29 patients from each of the groups treated with 20 mg or 40 mg Palynziq once daily, and was evaluated against each of the two placebo groups (20 mg and 40 mg). This was done due to statistically significant differences between the two placebo groups, and was acceptable as the poolability analyses were prespecified in the statistical analysis plan.
During the RDT period, the mean blood phenylalanine levels at baseline were 563.9 micromol/L in the group receiving 20 mg placebo once daily, 508.2 micromol/L in the group receiving 40 mg placebo once daily, and 503.9 micromol/L in the actively treated pool of patients. At Week 8, the mean blood phenylalanine levels were 1,509.0 micromol/L in the group receiving 20 mg placebo once daily, 1,164.4 micromol/L in the group receiving 40 mg placebo once daily, and 559.2 micromol/L in the actively treated pool. The least square mean differences in blood phenylalanine levels after 8 weeks were -923.25 micromol/L (95% confidence interval [CI]: -1,135.0, -711.5; p<0.0001) for the actively treated pool versus the group receiving 20 mg placebo once daily, and -638.3 micromol/L (95% CI: -859.0, -417.6; p<0.0001) for the actively treated pool versus the group receiving 40 mg placebo once daily. After 8 weeks, patients treated with Palynziq maintained their blood phenylalanine reductions, while patients who received the placebo returned to their pre-treatment baseline levels.
The safety profile of Palynziq was derived primarily from Studies 301 and 302. Study 301 was an open-label and randomized (1:1) study conducted in 261 patients with PKU to evaluate the safety and tolerability of self-administered Palynziq in an induction/titration/maintenance (I/T/M) dose regimen. The patients ranged from 16 to 55 years of age (mean: 29 years). At baseline, patients had a mean blood phenylalanine level of 1,233 micromol/L, 149 patients (57%) were receiving part of their total protein intake from medical food, and 41 patients (16%) were on a phenylalanine-restricted diet (defined as receiving greater than 75% of total protein intake from medical food).
Patients initiated treatment with an induction regimen, followed by stepwise titration to reach their randomized maintenance dose of either 20 mg or 40 mg once daily. The median times to reach the maintenance dose were 10 weeks (range: 9 to 29 weeks) in the 20 mg once daily treatment arm and 11 weeks (range: 10 to 33 weeks) in the 40 mg once daily treatment arm. The mean total duration of dosing in Study 301 was 24.4 weeks.
Safety data from patients exposed to Palynziq through various studies were compiled into a safety database, including 299 patients exposed for 24 weeks, 209 patients exposed for one year, 181 patients exposed for two years, and 160 patients exposed for three years or longer. Collectively, the patients had 789 patient-years of exposure to pegvaliase. The safety database was limited by the lack of a comparator arm for all but 8 weeks of treatment in Study 302.
The most frequently reported adverse events in subjects treated with Palynziq were injection site reactions (93%), arthralgia (86%), and hypersensitivity reactions (>65%), including cutaneous reactions, serum sickness, angioedema, and acute systemic hypersensitivity reactions (i.e., anaphylaxis; 5.6%). Other frequently reported adverse events included headache (55%) and hypophenylalaninemia (46%). No fatal events attributed to treatment with Palynziq were reported.
The safety profile of Palynziq in patients 16 to less than 18 years of age was not considered to have meaningful differences from the safety profile in patients 18 years of age and older. However, the safety data provided in this population was limited to 12 patients.
A Serious Warnings and Precautions box was included in the Palynziq Product Monograph to highlight the risk of severe and potentially life-threatening allergic reactions, which could happen any time after receiving treatment with Palynziq.
A Risk Management Plan (RMP) for Palynziq was submitted by BioMarin International Limited to Health Canada. 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. Upon review, the RMP was considered to be acceptable.
The submitted inner and outer labels, package insert and Patient Medication Information section of the Palynziq Product Monograph meet the necessary regulatory labelling, plain language and design element requirements.
The sponsor submitted a brand name assessment that included testing for look-alike sound-alike attributes. Upon review, the proposed name Palynziq was accepted.
Palynziq has an acceptable safety profile based on the non-clinical data and clinical studies. The identified safety issues can be managed through labelling and adequate monitoring. Appropriate warnings and precautions are in place in the Palynziq 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 issued 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 Palynziq?
The review of the quality component of the New Drug Submission (NDS) for Palynziq was based on a critical assessment of the data package submitted to Health Canada. The reviews completed by the United States Food and Drug Administration (FDA) and the European Medicines Agency (EMA) were used as added references, as per Method 3 described in the Draft Guidance Document: The Use of Foreign Reviews by Health Canada. The Canadian regulatory decision on the Palynziq NDS was made independently based on the Canadian review.
For additional information about the drug submission process, refer to the Management of Drug Submissions and Applications Guidance.
Submission Milestones: Palynziq
Submission Milestone | Date |
---|---|
Pre-submission meeting | 2020-10-14 |
New Drug Submission filed | 2021-04-09 |
Screening | |
Screening Acceptance Letter issued | 2021-06-04 |
Review | |
Quality evaluation completed | 2022-03-07 |
Review of Risk Management Plan completed | 2022-03-10 |
Non-clinical evaluation completed | 2022-03-25 |
Clinical/medical evaluation completed | 2022-03-28 |
Biostatistics evaluation completed | 2022-03-28 |
Labelling review completed | 2022-03-29 |
Notice of Compliance issued by Director General, Biologic and Radiopharmaceutical Drugs Directorate | 2022-03-30 |
4 What follow-up measures will the company take?
Requirements for post-market commitments are outlined in the Food and Drugs Act and Regulations.
6 What other information is available about drugs?
Up-to-date information on drug products can be found at the following links:
- See MedEffect Canada for the latest advisories, warnings and recalls for marketed products.
- See the Notice of Compliance (NOC) Database for a listing of the authorization dates for all drugs that have been issued an NOC since 1994.
- See the Drug Product Database (DPD) for the most recent Product Monograph. The DPD contains product-specific information on drugs that have been approved for use in Canada.
- 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
Pegvaliase is produced through the addition of polyethylene glycol (PEG) moieties to the recombinant phenylalanine ammonia lyase (rAvPAL) enzyme. The rAvPAL enzyme converts phenylalanine to ammonia and trans-cinnamic acid, thereby reducing the elevated blood phenylalanine levels characteristic of phenylketonuria (PKU).
The major pharmacokinetic aspects of the absorption, distribution, metabolism, and elimination of pegvaliase were characterized in patients with PKU. The pharmacokinetics of pegvaliase exhibit high inter-patient and intra-patient variability due to the heterogeneity of the immune response in adult patients with PKU. Immune response affects clearance and time to reach steady state, with higher antibody titers correlating with higher pegvaliase clearance.
The pharmacokinetic profile of pegvaliase was developed primarily through data from the Phase III Studies 301 and 302, with Part 3 of Study 302 focusing specifically on the pharmacokinetics and pharmacodynamics of pegvaliase. In Part 3 of Study 302, no clinically meaningful increase in pegvaliase exposure was observed between the 20 mg and 40 mg once daily doses with respect to the maximum concentration (Cmax) or the area under the plasma drug concentration time curve from 0 to 24 hours post-dose (AUC0-24). The mean (± standard deviation [SD]) Cmax was 14.04 ± 16.26 mcg/mL at the 20 mg once daily dose and 16.69 ± 19.456 mcg/mL at the 40 mg once daily dose. The mean (± SD) AUC0-24 was 262.18 ± 280.38 mcg*hr/mL at the 20 mg once daily dose and 246.78 ± 338.59 mcg*hr/mL at the 40 mg once daily dose.
All patients treated with pegvaliase in Studies 301 and 302 developed a sustained anti-drug antibody (ADA) response, with 91% of patients (235 of 258) developing this response by Week 4 of treatment. Mean overall ADA titers peaked two weeks after treatment initiation and remained elevated throughout the duration of the studies.
Neutralizing antibodies were detected in 88% of patients (249 of 284). Mean neutralizing antibody titers peaked and reached a plateau at 16 to 20 weeks of treatment, and remained present throughout the duration of the studies. Sixteen patients experienced acute systemic hypersensitivity (anaphylactic) reactions, and tested negative for pegvaliase-specific immunoglobulin E (IgE) antibodies at or near the time of the episode. The incidence and titer of anti-PEG IgE were not measured. The observed hypersensitivity reactions were most frequent during the induction and titration periods, and decreased during the maintenance phase of treatment. The antibody titers were not predictive of hypersensitivity reactions.
Although limited data are available in these patient populations, body weight, gender, and age were not associated with notable effects on pegvaliase pharmacokinetics. No clinical studies have been conducted to evaluate the effect of renal or hepatic impairment on the pharmacokinetics of pegvaliase.
For further details, please refer to the Palynziq Product Monograph, approved by Health Canada and available through the Drug Product Database.
Clinical Efficacy
The clinical efficacy of Palynziq was mainly evaluated in Study 302, which was conducted in patients who had previously participated in Study 301 (a safety and tolerability study, described in the Clinical Safety section). Both were Phase III studies and included patients with phenylketonuria (PKU) aged 16 years or older. Patients had a mean blood phenylalanine level greater than 600 micromol/L at screening and on average over the 6 months prior to screening. Dosing in Study 301 included induction, titration, and maintenance periods, while Study 302 was intended to demonstrate the efficacy and safety of maintenance treatment with Palynziq. Parts 1, 2, and 4 of Study 302 are described below. Part 3, which evaluated the pharmacokinetics and pharmacodynamics of Palynziq, is addressed in the Clinical Pharmacology section.
The eligibility period (Part 1) of Study 302 included 164 patients previously treated with Palynziq (152 patients from Study 301 and 12 patients from other studies), who continued treatment at maintenance doses of 20 mg or 40 mg once daily for up to 13 weeks. By the completion of 13 weeks of Part 1, 86 of the 164 patients had achieved a reduction of 20% or greater in mean blood phenylalanine level from their pre-treatment baseline while taking Palynziq at their assigned maintenance dose and continued to the randomized discontinuation trial (RDT; Part 2) period of the study. Twelve patients discontinued treatment, and 57 patients transferred directly to the open-label extension period (Part 4).
The 8-week RDT period (Part 2) of Study 302 was the primary focus of the clinical efficacy assessment, and the only part involving a formal statistical plan. There were 29 patients in each of the groups remaining on the maintenance regimens of 20 mg or 40 mg Palynziq once daily, and 14 patients in each of the groups receiving 20 mg or 40 mg placebo once daily. None of the patients who entered the RDT period of the study were less than 18 years of age.
The primary endpoint of Study 302 was the change in blood phenylalanine levels from baseline of the RDT to Week 8 of the RDT. The primary analysis was conducted by evaluating the actively treated pool of 58 patients (29 patients from each of the groups treated with 20 mg or 40 mg Palynziq once daily) against each of the two placebo groups. This was done due to statistically significant differences between the two placebo groups, and was acceptable as the poolability analyses were prespecified in the statistical analysis plan.
At baseline of the RDT period, the mean blood phenylalanine levels were 563.9 micromol/L in the group randomized to 20 mg placebo once daily, 508.2 micromol/L in the group randomized to 40 mg placebo once daily, and 503.9 micromol/L in the actively treated pool of patients. At Week 8, the mean blood phenylalanine levels were 1,509.0 micromol/L in the group receiving 20 mg placebo once daily, 1,164.4 micromol/L in the group receiving 40 mg placebo once daily, and 559.2 micromol/L in the actively treated pool. The least square mean differences in blood phenylalanine levels after 8 weeks of randomized blinded treatment were -923.25 micromol/L (95% confidence interval [CI]: -1,135.0, -711.5; p<0.0001) for the actively treated pool versus the group receiving 20 mg placebo once daily, and -638.3 micromol/L (95% CI: -859.0, -417.6; p<0.0001) for the actively treated pool versus the group receiving 40 mg placebo once daily. After 8 weeks, patients treated with Palynziq maintained their blood phenylalanine reductions, while patients who received the placebo returned to their pre-treatment baseline levels.
Along with the data from the RDT period, the efficacy assessment also focused on data from the induction/titration/maintenance (I/T/M) population. This population included 285 patients who received Palynziq in an I/T/M regimen in the Phase III Studies 301 (described in the Clinical Safety section) and 302, and the Phase II Studies 205 and PAL-003. The primary efficacy endpoint of interest was mean blood phenylalanine level, which was evaluated at multiple time points throughout the assessment.
At pre-treatment baseline, the mean blood phenylalanine level in the I/T/M population was 1,227.3 micromol/L (range: 285 to 2,330 micromol/L). The length of the titration period varied based on patient tolerability, and most patients achieved a maintenance dose of 20 to 40 mg per day within approximately 6 months. At this time, the mean blood phenylalanine level was 766.4 micromol/L, which is a reduction of approximately 40% relative to baseline. A continued treatment period followed, during which maintenance doses of 20 to 60 mg per day were tailored based on efficacy and patient tolerability. The mean blood phenylalanine levels were 546.6 micromol/L at one year of treatment and 390.3 micromol/L at 18 months. Mean levels remained stable between 300 and 400 micromol/L for up to four years for patients remaining in the study. Current clinical practice guidelines advise a target blood phenylalanine level of 120 to 360 micromol/L. In the I/T/M population, 190 patients (66.7%) achieved a blood phenylalanine level ≤360 micromol/L at any time during treatment. The mean time to achieve this target was 10.35 months (range: 0.5 to 57.1 months). Patients were generally able to maintain or increase their protein intake from intact food over the course of treatment and still achieve target blood phenylalanine levels.
The long-term extension period (Part 4) of Study 302 included 202 patients who continued treatment with Palynziq. Doses were adjusted by the physician (5 mg, 10 mg, 20 mg, 40 mg, or 60 mg once daily) to achieve further blood phenylalanine reductions and maintain previously achieved phenylalanine levels. The mean daily dose was 33.2 mg once daily and the mean duration of treatment was 1,034 days (range: 17 to 1,729 days).
Indication
Sponsor's proposed indication | Health Canada-approved indication |
Palynziq (pegvaliase injection) is indicated for the treatment of patients with phenylketonuria (PKU) aged 16 years and older who have inadequate blood phenylalanine control (blood phenylalanine levels greater than 600 micromol/L) on existing management. | Palynziq (pegvaliase injection) is indicated to reduce blood phenylalanine concentrations in patients with phenylketonuria (PKU) aged 16 years and older who have inadequate blood phenylalanine control (blood phenylalanine levels greater than 600 micromol/L) despite dietary management. |
The proposed indication was revised to more accurately represent the patient population in Studies 301 and 302. The recommended dosing regimen includes induction, titration, and maintenance phases intended to gradually acclimatize the patient’s immune response while building to therapeutic dose levels. The proposed maintenance doses range from 20 to 60 mg per day depending on individual patient blood phenylalanine response and tolerability. The recommended dosing table and comprehensive dosing and administration guidelines are provided in the Palynziq Product Monograph.
For more information, refer to the Palynziq Product Monograph, approved by Health Canada and available through the Drug Product Database.
Clinical Safety
The safety profile of Palynziq was derived primarily from the two Phase III studies, 301 and 302, which included patients with PKU in the I/T/M population. Study 302 and the I/T/M population are described in the Clinical Efficacy section. Study 301, a safety and tolerability study, is described below.
Study 301 was an open-label and randomized (1:1) study conducted in 261 patients with PKU to evaluate the safety and tolerability of self-administered Palynziq in an I/T/M dose regimen. The patients ranged from 16 to 55 years of age (mean: 29 years). At baseline, patients had a mean blood phenylalanine level of 1,233 micromol/L, 149 patients (57%) were receiving part of their total protein intake from medical food, and 41 patients (16%) were on a phenylalanine-restricted diet (defined as receiving greater than 75% of total protein intake from medical food).
Patients initiated treatment with an induction regimen (2.5 mg once weekly for 4 weeks), followed by a stepwise titration to reach their randomized maintenance dose of either 20 mg or 40 mg once daily. The length of the titration period varied based on patient tolerability, with a maximum length of 30 weeks. The maintenance period was defined as a minimum of three weeks of dosing at the randomized maintenance dose, which was reached by 103 patients in the 20 mg once daily treatment arm and 92 patients in the 40 mg once daily treatment arm (in total, 195 of 261 patients; 75%). The median times to reach the maintenance dose were 10 weeks (range: 9 to 29 weeks) in the 20 mg once daily treatment arm and 11 weeks (range: 10 to 33 weeks) in the 40 mg once daily treatment arm. The mean total duration of dosing in Study 301 was 24.4 weeks. After Study 301, 152 patients continued to the eligibility period (Part 1) of Study 302, and 51 patients continued to the long-term extension period (Part 4) of Study 302.
Safety data from patients exposed to Palynziq were compiled into a safety database which included 299 patients exposed for 24 weeks, 209 patients exposed for one year, 181 patients exposed for two years, and 160 patients exposed for three years or longer. Collectively, the patients had 789 patient-years of exposure to pegvaliase. The safety database was limited by the lack of a comparator arm for all but the 8 weeks of treatment in the RDT period (Part 2) of Study 302.
The most frequently reported adverse events in patients treated with Palynziq were injection site reactions (93%), arthralgia (86%), and hypersensitivity reactions (>65%), including cutaneous reactions, serum sickness, angioedema, and acute systemic hypersensitivity reactions (i.e., anaphylaxis; 5.6%). Other frequently reported adverse events included headache (55%) and hypophenylalaninemia (46%). No fatal events attributed to treatment with Palynziq were reported.
The safety profile of Palynziq in patients 16 to less than 18 years of age was not considered to have meaningful differences from the safety profile in patients 18 years of age and older. However, the safety data provided in this population was limited to 12 patients.
A Serious Warnings and Precautions box was included in the Palynziq Product Monograph to highlight the risk of systemic hypersensitivity reactions, including anaphylaxis. These have been reported following the administration of Palynziq, and may occur at any time during treatment. The initial doses of Palynziq must be administered under the supervision of a health professional equipped to manage an acute systemic hypersensitivity (anaphylactic) reaction. Patients should be observed closely for at least one hour after injection. Additionally, auto-injectable epinephrine must be prescribed to the patient. Prior to the first self-administered or caregiver-administered dose, the patient or caregiver and a trained observer must be instructed on the appropriate use of epinephrine. The patient should also be instructed to carry auto-injectable epinephrine at all times during the course of treatment, and to seek immediate medical care in the case of epinephrine use. Finally, Palynziq should be discontinued in patients who experience a severe systemic hypersensitivity reaction and in patients who experience a recurrent mild to moderate anaphylactic reaction.
For more information, refer to the Palynziq Product Monograph, approved by Health Canada and available through the Drug Product Database.
7.2 Non-Clinical Basis for Decision
Non-clinical toxicology studies were conducted in normal healthy animals without phenylketonuria (PKU). Dose-dependent reductions in plasma phenylalanine concentrations were detected in all species, with some cases resulting in phenylalanine depletion, including in pregnant animals. This observation is consistent with the pharmacological effects of pegvaliase, and depletion can be attributed to the administration of pegvaliase to normal animals with normal plasma phenylalanine concentrations at baseline.
Repeat-dose toxicity studies were conducted in rats administered pegvaliase subcutaneously at 0, 1, 8, and 25 mg/kg body weight twice weekly for either 4 weeks or 26 weeks. At dose levels of 1 and 8 mg/kg, systemic exposures were lower than the human exposure at the 40 mg/day dose. Dose-dependent vacuolation was detected in multiple organs and tissues at dose levels of 8 and 25 mg/kg, and persisted in the histiocytes of affected organs and tissues after cessation of dosing. The results of clinical pathology parameters and histopathological examination indicated that vacuolation was not associated with organ-related toxicities. However, the vacuolation observed in renal tubular epithelial cells was associated with cellular hypertrophy and was therefore considered adverse. Based on these findings, the no-observed-adverse-effect level (NOAEL) for the general systemic toxicity of pegvaliase in rats was 1 mg/kg body weight twice weekly. Exposure at the NOAEL was lower than the human exposure level at 40 mg/day.
A 39-week repeat-dose toxicity study was conducted in cynomolgus monkeys administered pegvaliase subcutaneously at doses of 0.01, 0.1, 1, 3, and 7/5/3 mg/kg body weight twice weekly. Systemic exposures at all doses were lower than the human exposure at the 40 mg/day dose. In the highest dose group (7/5/3 mg/kg body weight group), signs of dose-limiting toxicity including reductions in food consumption, body weight loss, and hypoactivity were observed when animals were administered a dose of 7 mg/kg body weight twice weekly. The dose was therefore lowered to 5 mg/kg body weight twice weekly in these animals; however, similar findings were observed. The dose was subsequently lowered to 3 mg/kg body weight twice weekly in these animals. In groups administered 3 mg/kg body weight twice weekly, systemic arteritis was observed, involving small arteries and arterioles in a wide range of organs and tissues. The development of arteritis was attributed to the immune-mediated response associated with chronic administration of a foreign protein to the animals. The incidence and severity of systemic arthritis was dose-dependent. The results of clinical pathology parameters and histopathological examination indicated that the observed vascular inflammation was not associated with organ-related toxicities. Due to the systemic arteritis observed at the higher dose levels, the NOAEL for the general systemic toxicity of pegvaliase in cynomolgus monkeys was 1 mg/kg body weight twice weekly. Exposure at the NOAEL was lower than the human exposure level at 40 mg/day.
No studies have been performed to evaluate the carcinogenic or genotoxic potential of pegvaliase, which is acceptable and in line with International Council for Harmonisation (ICH) guidelines.
A combined fertility and embryo-fetal development study was conducted in which pegvaliase was administered subcutaneously to male and female rats at doses of 0 (vehicle control), 2, 8, or 20 mg/kg body weight per day (corresponding to 2, 8, and 20 times the maximum recommended human dose of 60 mg/day, respectively). Doses were administered during the pre-mating period (41 days in males, 28 days in females), throughout mating (maximum of 8 days), and post-mating in males (minimum of 77 total doses) or during gestation in females until gestation day (GD) 17 (which covers the period of organogenesis to closure of the hard palate). Adverse reductions in body weight, body weight gain, and food consumption were observed in both male and female rats at the 20 mg/kg dose level. No adverse effects were observed on sperm parameters, estrous cycling, or on mating, fertility, and pregnancy indices. However, adverse effects on female fertility were observed at the 8 and 20 mg/kg dose levels, consisting of dose-dependent decreases in the number of corpora lutea and the number of implantation sites. Signs of embryo-fetal toxicity, including reductions in mean litter size, fetal weights, and the number of live fetuses were observed at a maternal dose of 20 mg/kg body weight per day. Pegvaliase was also detected in fetal blood at the 20 mg/kg dose level. No pegvaliase-related external, visceral, or skeletal malformations were observed. Based on these observations, the NOAEL for effects on female fertility in rats was 2 mg/kg body weight per day, and the NOAEL for developmental toxicity in rats following maternal subcutaneous administration was 8 mg/kg body weight per day.
An embryo-fetal development study was conducted in which pegvaliase was administered subcutaneously to pregnant rabbits. Doses of 2 or 5 mg/kg body weight per day (corresponding to 2 or 5 times the maximum recommended human dose of 60 mg/day, respectively) were administered using a divided dosing regimen - doses were administered from GD 7 to 12, GD 11 to 16, or GD 15 to 20. The period from GD 7 to 20 includes implantation through organogenesis to the closure of the hard palate. Signs of maternal toxicity were detected at both the 2 and 5 mg/kg dose levels, including a reduction in body weight gain, body weight loss, a reduction in food consumption, and/or clinical signs. At the 5 mg/kg dose level, maternal toxicity was accompanied by increases in abortions and post-implantation losses (due to increased resorptions), fetal deaths, reductions in fetal weight, and the percentage of live male fetuses, which were all found to be related to pegvaliase.
Exposure to pegvaliase in utero also resulted in numerous fetal external, visceral, and skeletal malformations in rabbits, with the incidence of malformations found to be dose-dependent. In the control group, no external or visceral malformations were observed, and skeletal malformations fell within the historical control ranges. The observed teratogenicity was related to pegvaliase and could not be attributed to maternal toxicity. As maternal and developmental toxicity were observed at both doses, the NOAELs for these could not be determined. Additionally, pegvaliase was detected in fetal blood, with concentrations increasing with increasing maternal dose.
Pre- and postnatal development studies were conducted in which doses of 0 (vehicle control), 2, 8, or 20 mg/kg body weight per day (corresponding to 2, 8, and 20 times the maximum recommended human dose of 60 mg/day, respectively) were administered subcutaneously to female rats. The dosing period included a 28-day pre-mating period, mating, gestation, and lactation, until postnatal day (PND) 21. Signs of maternal toxicity were observed at the 20 mg/kg dose level, including adverse clinical signs or poor maternal behaviour coupled with poor litter condition, and reductions in body weight, body weight gain, and food consumption. Although no adverse effects were detected with respect to mating, fertility, and pregnancy indices, reductions in pup weight, litter size, and survival of offspring during the lactation period were observed. The body weight effect was resolved post-weaning. No other adverse effects were observed in offspring, including effects on physical development, neurobehavioural development, sexual maturation, and reproduction. Based on these findings, the NOAELs for both the maternal toxicity and developmental toxicity of pegvaliase in rats following maternal subcutaneous administration was 8 mg/kg body weight per day.
In the pre- and postnatal development studies, pegvaliase was detected in the milk of dams from all dose groups on PND 14, with concentrations increasing in a dose-dependent manner. While pegvaliase was not observed in the offspring of dams administered pegvaliase on PND 14, a dose-dependent reduction in mean plasma phenylalanine concentration was observed in the offspring. These findings indicate that in utero/lactational exposure to pegvaliase results in an unwanted pharmacological effect in offspring.
The results of the non-clinical studies as well as the potential risks to humans have been included in the Palynziq Product Monograph. Considering the intended use of Palynziq, there are no pharmacological or toxicological issues within this submission which preclude authorization of the product.
For more information, refer to the Palynziq Product Monograph, approved by Health Canada and available through the Drug Product Database.
7.3 Quality Basis for Decision
As described above, the review of the quality component of the New Drug Submission for Palynziq was conducted as per Method 3 described in the Draft Guidance Document: The Use of Foreign Reviews by Health Canada.
Characterization of the Drug Substance
Palynziq contains the drug substance pegvaliase, a recombinant version of the Anabaena variabilis phenylalanine ammonia lyase (rAvPAL) enzyme, to which polyethylene glycol (PEG) moieties have been added. The enzyme exists in tetrameric form. It catalyzes the non-oxidative deamination of phenylalanine to trans-cinnamic acid and ammonia, thereby reducing the elevated blood phenylalanine levels characteristic of phenylketonuria (PKU).
Detailed characterization studies were performed, which demonstrated that pegvaliase consistently exhibits the desired characteristic structure and biological activity. Product- and process-related impurities were evaluated and found to be adequately controlled.
Manufacturing Process of the Drug Substance and Drug Product and Process Controls
The manufacturing process of pegvaliase occurs in two stages: the synthesis and purification of the rAvPAL intermediate, followed by the addition of the PEG moiety (PEGylation).
The rAvPAL intermediate is expressed from Escherichia coli cells, which have been engineered to express this protein through recombinant deoxyribonucleic acid (DNA) technology. A seed culture of E. coli cells is initiated and used to inoculate a production bioreactor in which the cell culture expands to commercial scale. When set criteria have been reached, the cells are harvested and lysed. Centrifugation is performed, and the supernatant (which contains the rAvPAL intermediate) is collected and passed through a filter train.
The downstream purification process for the rAvPAL intermediate involves a series of chromatography, filtration, and concentration steps. The intermediate is filtered and stored at -70 °C, or forward processed. The rAvPAL undergoes a PEGylation reaction, followed by filtration to remove residual PEGylation byproducts, and to formulate the drug substance. The formulated bulk drug substance is then stored at -70 °C.
Manufacturing of the drug product involves equilibration of the bulk drug substance to ambient temperature, filtration, pooling, mixing, and sterile filtration. Syringes are filled and stoppered, visually inspected, and stored at 2 °C to 8 °C prior to device assembly and secondary packaging.
Process validation was conducted using batches of the rAvPAL intermediate, drug substance (pegvaliase), and drug product (Palynziq). The process performance qualification data reviewed reflect consistency in the manufacturing processes and demonstrated that all relevant specifications were met.
None of the non-medicinal ingredients (excipients, described earlier) found in the drug product are prohibited by the Food and Drug Regulations. The compatibility of pegvaliase with the excipients is supported by the stability data provided.
Control of the Drug Substance and Drug Product
Palynziq is a Schedule D (biologic) drug and is, therefore, subject to Health Canada's Lot Release Program before sale as per the Guidance for Sponsors: Lot Release Program for Schedule D (Biologic) Drugs. Consistency lot testing was conducted and the results indicated that the methods are suitable for their intended use and support the consistency of the manufacturing process.
A comprehensive control strategy has been implemented for the manufacture of the rAvPAL intermediate, drug substance, and drug product. The control strategy was found to be suitable for controlling the critical process parameters and ensuring that production of Palynziq meets pre-defined criteria and specifications.
The validation of non-compendial analytical methods was performed in line with International Council for Harmonisation (ICH) guidelines. Accuracy, precision, specificity, limit of quantitation, limit of detection, linearity, range and robustness were tested as appropriate. The specifications proposed by the sponsor were also consistent with ICH guidelines. All release and stability acceptance criteria were met for the rAvPAL intermediate, drug substance, and drug product.
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 shelf life of 24 months at 2 °C to 8 °C is considered acceptable. Palynziq may be stored at room temperature for up to 30 days. After removal from refrigeration, the product must not be returned to the refrigerator. Additional storage and special handling instructions are included in the Palynziq Product Monograph.
Facilities and Equipment
Based on risk assessment scores determined by Health Canada, an on-site evaluation (OSE) was warranted for the drug substance manufacturing site.
Due to the ongoing coronavirus disease 2019 (COVID-19) pandemic, an OSE was not feasible during the review period. To mitigate the risk of not performing an OSE, selected documents evaluated during an OSE were requested and confirm that the Quality System and its operation continue to be suitable.
An OSE was not recommended for the drug product manufacturing site.
Adventitious Agents Safety Evaluation
The master and working cell banks were extensively characterized and confirmed to be free of fungal contaminants, bacteriophages, and other adventitious agents. Incoming raw materials are assessed for microbial contamination. Testing of in-process material and intermediates has been built into the manufacturing process to control microbial contamination.
There are no reagents or raw materials derived from human or animal sources used in the manufacture of pegvaliase. The enzyme is expressed by a microbial fermentation process and therefore the viral clearance studies were not required.
Related Drug Products
Product name | DIN | Company name | Active ingredient(s) & strength |
---|---|---|---|
PALYNZIQ | 02526263 | BIOMARIN INTERNATIONAL LIMITED | PEGVALIASE 20 MG / ML |
PALYNZIQ | 02526247 | BIOMARIN INTERNATIONAL LIMITED | PEGVALIASE 2.5 MG / 0.5 ML |
PALYNZIQ | 02526255 | BIOMARIN INTERNATIONAL LIMITED | PEGVALIASE 10 MG / 0.5 ML |