Summary Basis of Decision for Calquence

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 Calquence is located below.

Recent Activity for Calquence

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 Calquence

Date SBD issued: 2020-01-13

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

Acalabrutinib

Drug Identification Number (DIN):

  • DIN 02491788 - 100 mg capsule, oral administration

AstraZeneca Canada Inc.

New Drug Submission Control Number: 214504

On August 23, 2019, Health Canada issued a Notice of Compliance to AstraZeneca Canada Inc. for the drug product Calquence.

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 Calquence is favourable for the treatment of patients with mantle cell lymphoma (MCL) who have received at least one prior therapy.

1 What was approved?

Calquence, an antineoplastic agent, was authorized for the treatment of patients with mantle cell lymphoma (MCL) who have received at least one prior therapy.

No data regarding the use of Calquence in the pediatric (below 18 years of age) population are available to Health Canada; therefore, Health Canada has not authorized an indication for pediatric use.

No clinically relevant differences in safety or efficacy were observed between patients aged 65 years or older and those younger than 65 years.

Calquence is contraindicated for patients who are hypersensitive to acalabrutinib or to any ingredient in the formulation or component of the container.

Calquence 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.

Calquence (100 mg acalabrutinib) is presented as a capsule. In addition to the medicinal ingredient, the capsule contains ammonium hydroxide, black iron oxide, colloidal silicon dioxide, FD&C Blue 2 (indigotine/indigo carmine), gelatine, magnesium stearate, microcrystalline cellulose, partially pregelatinized starch (maize), propylene glycol, shellac, sodium starch glycolate (Type A), titanium dioxide, and yellow iron oxide.

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

2 Why was Calquence approved?

Health Canada considers that the benefit-harm-uncertainty profile of Calquence is favourable for the treatment of patients with mantle cell lymphoma (MCL) who have received at least one prior therapy.

Mantle cell lymphoma (MCL) is a form of B-cell non-Hodgkin lymphoma (NHL). It is a serious and life-threatening disease. By the time of diagnosis, the disease has often reached stage 3 or 4, and spread to other lymph nodes, bone marrow, spleen, liver, and gastrointestinal tract.

There are several treatment options, but no curative treatments. Up to 50-90% of patients respond to combination chemotherapy and approximately 30% achieve complete response. The median time to treatment failure is less than 18 months, with a median survival of 2-5 years. For patients with relapsed/refractory MCL (R/R MCL), an alternative regimen from that used initially may be given, but typically the quality and durability of any remissions achieved are inferior to those seen after front-line therapy. Bortezomib and ibrutinib are also approved for the treatment of R/R MCL.

Calquence has been shown to be efficacious in patients with MCL who have received at least one prior therapy. The market authorization was based on a long-term follow-up (total of 24 months) from a single-arm pivotal Phase II study (ACE-LY-004) with 124 patients. These patients had histologically documented MCL and had relapsed after 1-5 prior treatment regimens and used the intended therapeutic regimen of 100 mg twice daily as monotherapy. The primary endpoint was investigator-assessed objective response rate (ORR) according to the Lugano classification for NHL.

The efficacy analysis contained a rationale and sufficient evidence supporting the validation of the complete response (CR) rate endpoint based on the Lugano classification as a surrogate of clinical benefit in patients with MCL. At the 24-month update, the ORR was 80.6% (95% confidence interval [CI]: 72.6%, 87.2%) and the CR rate was 42.7% (95% CI: 33.9%, 51.9%). The high concordance rate between the Independent Review Committee (IRC)-based and the investigator-based assessments also supported the primary efficacy endpoint.

Most of the patients who responded to Calquence treatment had sustained responses of significant duration. The median duration of response (DOR) was 25.7 months.

Progression-free survival (PFS) and overall survival (OS) were also reported in the study. However, the impact of Calquence on PFS and OS is uncertain because, without a comparator arm, PFS and OS can only be considered as exploratory endpoints. Nevertheless, the response rate results, in particular the complete metabolic response rate results, are likely to be associated with long-term clinical benefit, as suggested by the relatively long median DOR.

The safety profile of Calquence (acalabrutinib) in MCL patients was mainly derived from the pivotal single-arm Phase II study. Additional risks were identified in the overall safety profile of Calquence in 612 patients with hematologic malignancies, who received acalabrutinib monotherapy at doses ranging from 100 mg twice daily to 200 mg twice daily. The key safety findings were:

  • The long-term effect of acalabrutinib on renal function has not been evaluated.
  • Events of atrial fibrillation/flutter were reported in patients with hematologic malignancies treated with Calquence. However, in a clinical electrocardiogram assessment study, Calquence demonstrated no clinically meaningful effect on the QTcF interval, the QRS duration, or the PR interval of healthy subjects.
  • Second primary malignancies were observed in patients treated with Calquence, although Calquence showed negative results for mutagenicity in an in vitro bacterial reverse mutation assay, an in vitro chromosome aberration assay, and an in vivo mouse micronucleus test.
  • There were limited clinical data of Calquence use in pregnant women. Based on findings from animal studies, a risk to the fetus from exposure to Calquence during pregnancy cannot be excluded.

The most common adverse drug reactions reported in patients receiving Calquence were headache, bruising, diarrhea, nausea, and rash. Serious adverse reactions included second primary malignancies, atrial fibrillation, serious hemorrhage, and serious infections. The important risks associated with Calquence along with dosage adjustment recommendations in the events of grade ≥3 adverse reactions are appropriately captured in the Calquence Product Monograph.

A Serious Warnings and Precautions box is included in the Calquence Product Monograph. It emphasizes that the treatment with Calquence should be initiated and supervised by a qualified physician experienced in the use of anticancer therapies. Furthermore, it specifies that concomitant use of Calquence with a strong cytochrome (CYP) P450 inhibitor CYP3A should be avoided, and recommends monitoring for and appropriate management of bleeding to prevent serious hemorrhage.

A Risk Management Plan (RMP) for Calquence 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.

The submitted inner and outer labels, package insert and Patient Medication Information section of the Calquence 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 Calquence was accepted.

In conclusion, marketing authorization of Calquence was recommended for the treatment of patients with MCL who have received at least one prior therapy. This therapy is expected to be associated with significant clinical benefits but there also exist significant potential risks. These risks appear to be manageable through appropriate labelling. Given that MCL is a serious and life-threatening disease, the clinical benefits of Calquence therapy are considered to outweigh its risks for the proposed indication.

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 Calquence?

A meeting to discuss the new drug submission (NDS) for Calquence was held on November 15, 2017 between Health Canada and AstraZeneca Canada. The submission was considered to meet the requirements for filing under the Notice of Compliance with Conditions (NOC/c) Guidance.

In March 2018, AstraZeneca Canada Inc. filed a request for Advance Consideration under the Notice of Compliance with Conditions (NOC/c) Guidance for the review of the NDS for Calquence for the proposed indication.

On November 5, 2018, Health Canada issued a Notice of Deficiency (NOD) for the proposed indication with the following three major objections:

  • The dossier did not contain sufficient data supporting a potential improvement of the benefit-harm-uncertainty profile with Calquence over existing therapies for the proposed indication. This precluded the issuance of a Notice of Compliance (NOC) with conditions.
  • The proposed trials for confirming the potential improvement of the benefit-harm-uncertainty profile with Calquence over existing therapies for the proposed indication were not acceptable. This precluded the issuance of an NOC with conditions.
  • The dossier did not contain substantial evidence supporting the clinical effectiveness of Calquence for the proposed indication. This precluded the issuance of an NOC.

On November 26, 2018, a teleconference was held between AstraZeneca Canada Inc. and Health Canada to discuss the NOD comments and the potential regulatory pathway forward for the Calquence NDS. It was recommended to the sponsor that a regular NOC pathway be considered should long-term efficacy data be provided to support the benefit of the treatment.

On February 18, 2019, the response to the NOD was accepted for review. The sponsor submitted data from a 24-month follow-up update to support the proposed indication. The concerns that led to the NOD were satisfactorily addressed, and an NOC was issued on August 23, 2019.

Submission Milestones: Calquence

Submission MilestoneDate
Pre-submission meeting:2017-11-15
Submission filed:2018-03-15
Screening 1
Screening Deficiency Notice issued:2018-04-09
Response filed:2018-04-13
Screening Acceptance Letter issued:2018-04-27
Review 1
Biopharmaceutics Evaluation complete:2018-09-07
Biostatistics Evaluation complete:2018-10-24
Notice of Deficiency (NOD) issued by Director General, Therapeutic Products Directorate (safety, effectiveness, and quality issues):2018-11-05
Response filed:2019-01-30
Screening 2
Screening Acceptance Letter issued:2019-02-20
Review 2
Biostatistics Evaluation complete:2019-06-28
Review of Risk Management Plan complete:2019-08-02
Labelling Review complete, including Look-alike Sound-alike brand name assessment:2019-08-16
Quality Evaluation complete:2019-08-22
Clinical/Medical Evaluation complete:2019-08-22
Notice of Compliance issued by Director General, Therapeutic Products Directorate:2019-08-23

The Canadian regulatory decision on the non-clinical and/or clinical review of Calquence 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?

Requirements for post-market commitments are outlined in the Food and Drugs Act and Regulations.

6 What other information is available about drugs?

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

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

Clinical Pharmacology

The active ingredient of Calquence, acalabrutinib, is a potent, highly selective small-molecule inhibitor of Bruton's tyrosine kinase (BTK), with minimal off-target kinase activity. Bruton's tyrosine kinase is a signalling molecule of the B-cell antigen receptor (BCR) and cytokine receptor pathways. In B cells, BTK signalling results in B-cell survival and proliferation, and is required for cellular adhesion, trafficking, and chemotaxis.

Acalabrutinib forms a covalent bond with Cys481 in the BTK adenosine triphosphate pocket, permanently inactivating the enzyme and resulting in the inhibition of proliferation and survival signals in malignant B cells. Acalabrutinib has an active metabolite, ACP-5862, that is also a covalent inhibitor of BTK.

In patients with B-cell malignancies dosed with 100 mg Calquence twice daily, median steady state BTK occupancy of ≥95% in peripheral blood was maintained over 12 hours, resulting in inactivation of BTK throughout the recommended dosing interval.

The clinical pharmacology data included reports on the human pharmacodynamic and pharmacokinetic studies. The data support the use of Calquence for the specified indication.

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

Clinical Efficacy

The clinical efficacy of Calquence in patients with mantle cell lymphoma (MCL) was evaluated in an open-label, multicentre, single-arm Phase II study (ACE-LY-004) that enrolled 124 previously treated patients. The patients had histologically documented relapsed or refractory MCL after 1-5 prior treatment regimens.

The patients were administered Calquence 100 mg orally twice daily until disease progression or unacceptable toxicity. The median age of the patients was 68 (range 42 to 90) years, 80% were male and 74% were Caucasian. At baseline, 93% of patients had an Eastern Cooperative Oncology Group (ECOG) performance status of 0 or 1.

The majority of patients (95%) had previously received rituximab as a single agent or part of a regimen. Common prior regimens included combination chemotherapy of cyclophosphamide, doxorubicin, vincristine and prednisone (CHOP-based regimen [52%]); cytarabine (34%); bendamustine and rituximab-based regimens (22%); and hyperfractionated cyclophosphamide, vincristine, doxorubicin, dexamethasone, methotrexate and cytarabine (Hyper-CVAD [21%]). Eighteen percent of the patients had undergone stem cell transplant. At baseline, 24% and 76% of patients had refractory and relapsed disease, respectively, and 37% of patients had at least one tumour with a longest diameter of ≥5 cm, 73% had extra nodal involvement including 51% with bone marrow involvement. The simplified MCL International Prognostic Index (MIPI) score (which includes age, ECOG score, and baseline lactate dehydrogenase and white cell count) was intermediate in 44% and high in 17% of patients, and 75% of patients had Ann Arbor Stage IV disease. The study did not include patients who received prior treatment with inhibitors of BTK.

The primary endpoint was investigator-assessed objective response rate (ORR) according to the Lugano classification for non-Hodgkin lymphoma (NHL).

The key secondary endpoints were investigator-assessed duration of response (DOR) according to the Lugano classification, progression-free survival (PFS) according to the Lugano classification, and overall survival (OS). In addition, ORR, DOR and PFS according to the Lugano classification assessed by an independent review committee (IRC) were also included as secondary endpoints.

Upon review of the initial drug submission for Calquence, it was determined that it did not fulfill the requirements for a NOC with conditions. Furthermore, there were uncertainties around the validation of the primary endpoint as a surrogate of clinical benefit in the mantle cell lymphoma setting based on the Lugano classification. There were also uncertainties around the quality of the response due to the limited follow-up time. Finally, the long-term safety profile of Calquence was unknown and the submitted results failed to demonstrate an improvement in the quality of life of MCL patients treated with Calquence. These uncertainties precluded the issuance of a NOC. As a result, Health Canada issued a Notice of Deficiency (NOD) to the sponsor (see What steps led to the approval of Calquence?).

The sponsor responded to the NOD with a 24-month follow-up update of the ACE-LY-004 study. The median duration of treatment was 17.3 months and the median dose intensity was 98.7%. The median duration of follow-up was 26.3 months.

In the 24-month follow-up update, the ORR was 80.6% (95% CI: 72.6%, 87.2%) and the CR rate was 42.7% (95% CI: 33.9%, 51.9%). The median DOR was 25.7 months. Patients with CR had a median DOR over 28 months. The median DOR for patients with a partial response (PR) was approximately 17 months. This finding suggests that most of the patients who were responding to Calquence treatment kept their response for a significant duration.

The median investigator-assessed PFS was 19.5 months. However, without a comparator arm, PFS can only be considered as an exploratory endpoint. Furthermore, it cannot be compared with historical data as the events of progressive disease were based on different criteria set.

The median OS had not been reached. Without a comparator arm, OS can only be considered as an exploratory endpoint.

The 12-month follow-up data showed a high concordance rate for the investigator assessment and the IRC assessment of ORR and CR (91% and 94% respectively). An IRC assessment was not conducted for the 24-month update, but a similar concordance was expected. The median PFS and the median DOR from the 24-month follow-up data were also expected to be consistent between the IRC and the investigator assessment.

Overall, the sponsor addressed the issues stated in the NOD. The response to the NOD contained a rationale and sufficient evidence supporting the validation of the CR rate endpoint based on the Lugano classification as a surrogate of clinical benefit in patients with MCL.

The submission was found to be in compliance with the Food and Drugs Act and Regulations. The results from the clinical pivotal study supports the efficacy of Calquence for the proposed indication.

Indication

The New Drug Submission for Calquence was filed by the sponsor with the following indication, which Health Canada subsequently approved:

  • Calquence (acalabrutinib) is indicated for the treatment of patients with mantle cell lymphoma (MCL) who have received at least one prior therapy.

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

Clinical Safety

The clinical safety profile of Calquence (acalabrutinib) in MCL patients was mainly derived from the pivotal single-arm Phase II study (ACE-LY-004), described in the Clinical Efficacy section (see the Clinical Efficacy section). Additional risks were identified in the overall safety profile obtained from 612 patients with hematologic malignancies, who received acalabrutinib monotherapy at doses ranging from 100 mg twice daily to 200 mg twice daily.

The most common (≥20%) adverse events (AEs) of any grade reported in patients receiving acalabrutinib were headache, diarrhea, fatigue, cough, nausea, contusion, and upper respiratory tract infection. The majority of AEs reported were grade 1 or 2 in severity and generally did not lead to acalabrutinib discontinuation. The most frequently reported (≥2%) serious adverse events (SAEs) included pneumonia (6%) and pyrexia (3%). Some cases of atrial fibrillation were observed during the ACE-LY-004 study.

In addition, the following safety findings were found in the 24-month update obtained from patients with MCL in the ACE-LY-004 study.

  • Lymphocytosis occurred in 32% of patients with MCL. There was no apparent increased risk of tumour lysis syndrome observed in patients who had lymphocytosis. However, the risk of leukostasis cannot be ruled out.
  • There was a high incidence of grade 1 or grade 2 events of increased levels of creatinine (91.8%) None of the patients had a grade 3 or grade 4 event of increased levels of creatinine. However, the long-term effect of Calquence on renal function has not been evaluated.
  • Grade 3 and grade 4 events of increased levels of uric acid occurred in 17.9% and 9.0% of patients, respectively.
  • Calquence was associated with grade 2 and grade 3 events of increased levels of blood pressure.
  • Major hemorrhage events were reported for 1 patient (0.8%) in the ACE-LY-004 study but in the overall safety database it was reported for 15 patients (2.5%).
  • An increased risk of infections, including hepatitis B reactivation and progressive multifocal leukoencephalopathy cannot be ruled out.
  • SAEs of interstitial lung disease (ILD) were reported in the ACE-LY-004 study. The relationship with Calquence is unclear due to the presence of confounding factors in these patients and the absence of additional ILD events in the overall safety database.

In a randomized, double-blind, double-dummy, placebo- and positive-controlled, four-way crossover electrocardiogram assessment study, single-dose administration of acalabrutinib 100 mg and 400 mg (4 times the maximum recommended single dose) was not demonstrated to affect the QTcF interval, the QRS duration, or the PR interval in healthy subjects (number of subjects = 44).

No post-marketing data were available to add additional safety information.

Acalabrutinib showed negative results in an in vitro bacterial reverse mutation assay, an in vitro chromosomal aberration assay, and an in vivo mouse micronucleus test. Despite these negative results, second primary malignancies have been observed in patients treated with Calquence.

Limited clinical data exist on the use of Calquence in pregnant women. Based on findings from animal studies, there may be a risk to the fetus from exposure to Calquence during pregnancy.

Appropriate warnings and precautions are in place in the approved Calquence Product Monograph to address the identified safety concerns.

A Serious Warnings and Precautions box has been included in the Calquence Product Monograph, which highlights that the treatment with Calquence should be initiated and supervised by a qualified physician experienced in the use of anticancer therapies. Furthermore, it specifies that concomitant use of Calquence with a strong cytochrome (CYP) P450 inhibitor CYP3A should be avoided, and recommends monitoring for an appropriate management of bleeding to prevent serious hemorrhage.

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

7.2 Non-Clinical Basis for Decision

The active ingredient of Calquence, acalabrutinib, was rapidly absorbed in all non-clinical species tested and had a short half-life. Oral bioavailability was affected by food in the monkey, but not the dog. Plasma protein binding was high in all of the species, including humans. Acalabrutinib was widely distributed in tissues, and placental transfer and excretion into milk of lactating rats were observed. Acalabrutinib was extensively metabolized, with ACP 5862 identified as the major metabolite. Excretion was mainly in the feces and the elimination was essentially complete within 48 hours.

At the concentrations studied, acalabrutinib was a weak inhibitor of the cytochrome (CYP) P450 enzyme CYP3A4. Acalabrutinib was a substrate for P-glycoprotein and breast cancer resistance protein in vitro.

Safety pharmacology studies demonstrated that there were no neurobehavioral effects in rats. No cardiovascular or electrocardiogram effects were observed in dogs and there were no effects on respiration.

In repeat-dose toxicity studies in rats and dogs the target organs of toxicity were identified as the kidney, liver, and pancreas.

Acalabrutinib showed negative results in an in vitro bacterial reverse mutation assay, an in vitro chromosomal aberration assay, and an in vivo mouse micronucleus test.

In a rabbit embryo-fetal development study, skeletal variations of delayed ossification were observed with reductions in fetal weights. These findings were observed only at maternotoxic doses of acalabrutinib. Acalabrutinib had no effects on fertility or embryo-fetal development in rats.

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

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

7.3 Quality Basis for Decision

The Notice of Deficiency previously issued on November 5, 2018 included several quality concerns in addition to the major clinical deficiencies. All of these concerns have now been resolved satisfactorily.

This drug product is manufactured by dry granulation and encapsulation. The process and proposed operating ranges have been supported by extensive development. The formulation and manufacturing process used to produce the clinical lots have been found to be representative of those proposed for commercial production. The change in manufacturing site has been supported by appropriate comparative dissolution data.

The Chemistry and Manufacturing information submitted for Calquence has demonstrated that the drug substance and drug product can be consistently manufactured to meet the approved specifications. Based on the stability data submitted, the proposed shelf life of 12 months is acceptable when the drug product is stored at room temperature (15ºC to 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.

One of the excipients in the capsule shell, gelatin, is of animal origin. Letters of attestation confirming that the materials are not from a bovine spongiform encephalopathy and transmissible spongiform encephalopathy (BSE/TSE) affected country/area have been provided for this product indicating that it is considered to be safe for human use.