Summary Basis of Decision for Ruzurgi

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 Ruzurgi is located below.

Recent Activity for Ruzurgi

SBDs written for eligible drugs approved after September 1, 2012 will be updated to include post-authorization information. This information will be compiled in a Post-Authorization Activity Table (PAAT). The PAAT will include brief summaries of activities such as submissions for new uses of the product, and whether Health Canada's decisions were negative or positive. PAATs will be updated regularly with post-authorization activity throughout the product's life cycle.

Post-Authorization Activity Table (PAAT) for Ruzurgi

Updated:

2023-01-24

The following table describes post-authorization activity for Ruzurgi, a product which contains the medicinal ingredient amifampridine. For more information on the type of information found in PAATs, please refer to the Frequently Asked Questions: Summary Basis of Decision (SBD) Project: Phase II and to the list of abbreviations that are found in PAATs.

For additional information about the drug submission process, refer to the Management of Drug Submissions and Applications Guidance.

Drug Identification Number (DIN):

  • DIN 02503034 - 10 mg amifampridine, tablet, oral administration

Post-Authorization Activity Table (PAAT)

Activity/submission type, control numberDate submittedDecision and dateSummary of activities
Health Professional Risk CommunicationNot applicablePosted
2023-01-20

Health Professional Risk Communication posted (Ruzurgi [amifampridine] – Authorization Status), containing updated information for healthcare professionals.

NDS # 2346552019-12-20Issued NOC
2023-01-10

In accordance with the Federal Court of Appeal decision in A-78-22, the June 24, 2021 decision of the Minister on the application of the data protection provisions was restored, and a new NOC was issued.

DIN 02503034 re-issuedNot applicable
2023-01-10

In accordance with the Federal Court of Appeal decision in A-78-22, the June 24, 2021 decision of the Minister on the application of the data protection provisions was restored, and the DIN was re-issued.

Health Product Risk CommunicationNot applicablePosted
2022-03-11
Health Product Risk Communication posted, containing updated information about the product withdrawal, for healthcare professionals.
DIN 02503034 cancelledNot applicable
2022-03-11
Health Canada cancelled the DIN further to the Federal Court Judgment in T-1047-21 (data protection provisions).
NOC invalidNot applicable
2022-03-10
The NOC is invalid in accordance with the Federal Court Judgment in T‑1047‑21 (data protection provisions).
Drug Recall postedNot applicablePosted
2021-09-09
Drug Recall posted on the Healthy Canadians Website, for the general public, healthcare professionals, and hospitals.
Drug product (DIN 02503034) market notificationNot applicableDate of first sale:
2021-06-25
The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.
Dear Healthcare Professional LetterNot applicablePosted
2021-06-25
Dear Healthcare Professional Letter posted, containing updated information about the product authorization, for healthcare professionals.
NDS # 2346552019-12-20Issued NOC
2021-06-24
Following a Federal Court order for a new determination, Health Canada issued a data protection decision with a new NOC.
DIN 02503034 issuedNot applicable
2021-06-24
Following a Federal Court order for a new determination, Health Canada issued a data protection decision with a new NOC and re-issued DIN 02503034.
Dear Healthcare Professional LetterNot applicablePosted
2021-06-10
Dear Healthcare Professional Letter posted, containing information about the product withdrawal, for healthcare professionals.
DIN 02503034 cancelledNot applicable
2021-06-01
Health Canada cancelled the DIN further to the Federal Court Judgment in T-984-20 (data protection provisions).
NOC invalidNot applicable
2021-05-31
The NOC is invalid in accordance with the Federal Court Judgment in T-984-20 (data protection provisions).
Drug product (DIN 02503034) market notificationNot applicableDate of first sale:
2020-09-24
The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.
NDS # 2346552019-12-20Issued NOC
2020-08-10
NOC issued for New Drug Submission.
Summary Basis of Decision (SBD) for Ruzurgi

Date SBD issued: 2020-10-22

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

Amifampridine

Drug Identification Number (DIN):

  • DIN 02503034 - 10 mg amifampridine, tablet, oral administration

Medunik Canada

New Drug Submission Control Number: 234655

On August 10, 2020, Health Canada issued a Notice of Compliance (NOC) to Medunik Canada for the drug product Ruzurgi. That NOC was invalid in accordance with the Federal Court Judgment in T-984-20 issued on May 31, 2021 (data protection provisions). On June 24, 2021, following a Federal Court order for a new determination, a data protection decision was issued with a new NOC for Ruzurgi. The NOC is invalid in accordance with the Federal Court Judgment in T-1047-21 issued on March 10, 2022 (data protection provisions). In accordance with the Federal Court of Appeal decision in A-78-22, the June 24, 2021 decision of the Minister on the application of the data protection provisions was restored, and a new NOC was issued on January 10, 2023.

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 Ruzurgi is favourable for the symptomatic treatment of Lambert-Eaton myasthenic syndrome (LEMS) in patients 6 years of age and older.

Lambert-Eaton myasthenic syndrome should be diagnosed by a health professional who has experience and knowledge in clinical features of this disease.

Ruzurgi should only be prescribed by health professionals who have experience in the treatment of LEMS, are knowledgeable of the efficacy and safety profile of this drug, and are able to discuss benefits/risks of treatment with patients.

1 What was approved?

Ruzurgi, a potassium channel blocker, was authorized for the symptomatic treatment of Lambert-Eaton myasthenic syndrome (LEMS) in patients 6 years of age and older.

Lambert-Eaton myasthenic syndrome should be diagnosed by a health professional who has experience and knowledge in clinical features of this disease.

Ruzurgi should only be prescribed by health professionals who have experience in the treatment of LEMS, are knowledgeable of the efficacy and safety profile of this drug, and are able to discuss benefits/risks of treatment with patients.

The safety and efficacy of Ruzurgi in patients younger than 6 years of age have not been studied. Accordingly, Ruzurgi is not indicated for use in this patient population.

In controlled clinical trials and compassionate use programs, 106 patients with LEMS aged 65 years and older have received treatment with Ruzurgi. Based on these data, there is no significant difference in safety and efficacy between the elderly and younger adults. However, due to the greater frequency of decreased hepatic, renal, or cardiac function, concomitant diseases, or other drug therapy in the elderly, Ruzurgi should be initiated in the geriatric population at the low end of the dosing range, followed by slower titration to effect.

Ruzurgi is contraindicated in patients who:

  • are hypersensitive to this drug or to any ingredient in its formulation, including any non-medicinal ingredient, or component of the container;
  • have a history of seizures;
  • are taking other forms of amifampridine or other inopyridines.

Ruzurgi 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.

Ruzurgi (10 mg amifampridine) is presented as a tablet. In addition to the medicinal ingredient, the tablet contains colloidal silicon dioxide, dibasic calcium phosphate dihydrate, magnesium stearate, microcrystalline cellulose, and sodium starch glycolate.

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

2 Why was Ruzurgi approved?

Health Canada considers that the benefit-harm-uncertainty profile of Ruzurgi is favourable for the symptomatic treatment of Lambert-Eaton myasthenic syndrome (LEMS) in patients 6 years of age and older.

Lambert-Eaton myasthenic syndrome should be diagnosed by a health professional who has experience and knowledge in clinical features of this disease.

Ruzurgi should only be prescribed by health professionals who have experience in the treatment of LEMS, are knowledgeable of the efficacy and safety profile of this drug, and are able to discuss benefits/risks of treatment with patients.

Lambert-Eaton myasthenic syndrome is a very rare presynaptic disorder, which adversely affects neuromuscular transmission. It may present as an autoimmune disorder or develop due to an underlying cancer (paraneoplastic type). In the autoimmune type, autoantibodies develop against presynaptic voltage-gated calcium channels, leading to lower levels of calcium ions in the presynaptic terminal and resulting in diminished levels of acetylcholine present at the neuromuscular junction. This adversely affects neuromuscular transmission and subsequent muscle contraction. Expected consequences include progressive weakness of proximal muscles such as the hip girdle muscles and those involved in patient mobility. Patients with LEMS experience difficulty rising from a bed or chair, walking, climbing stairs, and other similar movement-related tasks. In the paraneoplastic type of LEMS, an underlying malignancy (mostly small cell lung carcinoma) leads to the development of autoantibodies against voltage-gated calcium channels in the presynaptic cell, leading to the progressive weakness of the same muscles over time.

Lambert-Eaton myasthenic syndrome typically begins around 60 years of age, with some patients being diagnosed between 40 and 60 years of age. It has a prevalence of 2.3 cases per million and an annual incidence of about 0.5 cases per million. This disease occurs extremely rarely in the pediatric population, accounting for approximately 5% of cases. Rough estimates indicate that there may be around 70 to 100 patients with LEMS in Canada.

Currently, there is no cure for LEMS. At the time of Ruzurgi authorization, there was only one other approved treatment for LEMS in Canada. In patients whose LEMS is associated with an underlying malignancy, both chemotherapy and a variety of immunosuppressive therapies may be used. Other treatments include acetylcholinesterase inhibitors such as pyridostigmine bromide, as well as potassium channel blockers (e.g., guanidine). However, these drugs, especially guanidine, have significant side effects including fatal bone marrow suppression and renal failure.

Amifampridine, the medicinal ingredient in Ruzurgi, is a potassium channel blocker. It acts on voltage-gated potassium channels in the presynaptic membrane, which prolongs the depolarizing phase of the action potential, thus lengthening the open time for voltage-gated calcium channels. This leads to the availability of more acetylcholine at the neuromuscular junction and may result in stronger muscle contractions.

Ruzurgi has been shown to be efficacious in the symptomatic treatment of LEMS in patients 6 years of age and older. The clinical efficacy of Ruzurgi in adults was based primarily on one pivotal randomized, controlled, withdrawal study (DAPPER) involving 32 adult patients with LEMS who had received amifampridine, the medicinal ingredient in Ruzurgi, for at least 90 days prior to study entry. These patients were randomized to either continue their usual dose of amifampridine or to be tapered off to placebo over the course of 3 days. Using the primary efficacy endpoint, the degree of change in the Triple Timed Up and Go test, significant deterioration in function was observed following withdrawal of amifampridine, compared to the time-matched average at baseline. Function was restored in patients after their amifampridine regimen was reinstituted. The results of the primary endpoint were supported by the key secondary endpoint, the change in the self-assessment of LEMS-related weakness (W‑SAS) score following withdrawal of amifampridine, compared to baseline.

Over the last 27 years, it is estimated that more than 600 patients with LEMS have received amifampridine through various compassionate use programs, including Health Canada's Special Access Programme. The long-term safety of Ruzurgi treatment in patients with LEMS is established by a database of 162 patients treated with amifampridine for long periods of time. Adverse events reported during long-term use included paresthesia/hypoesthesia, abdominal pain, infection, fall, dyspepsia, nausea, pneumonia, and arrhythmia. A key safety issue associated with the use of amifampridine is the occurrence of seizures. Across the more than 600 patients who have received amifampridine, seizures were reported in 26 patients. Five of these patients experienced seizures during long-term use, three of whom were taking amifampridine 60 to 80 mg/day and did not have a prior history of seizures. Therefore, Ruzurgi is contraindicated in patients with a history of seizures and should be used with caution in combination with drugs that are known to lower the seizure threshold.

Cardiac-related events have also been reported during amifampridine treatment. Among over 600 patients treated with amifampridine through various compassionate use programs, 57 experienced one or more cardiac-related event, including QT interval prolongation. According to a database consisting of 234 patients taking amifampridine for long periods of time, 25 patients experienced cardiac-related adverse events such as atrial fibrillation, cardiac arrest, tachycardia, and palpitations. This was further supported by a double-blind, randomized, placebo- and positive-controlled crossover study (JPC 3,4-DAP.TQT) involving 52 healthy subjects in which QTcF (QT interval corrected for heart rate by the Fridericia formula) prolongation and a reduction in heart rate were observed following treatment with amifampridine. Therefore, caution should be observed if Ruzurgi is administered to patients who have risk factors for torsade de pointes. Hypokalemia, hypocalcemia, and hypomagnesemia should be corrected prior to initiation or continuation of Ruzurgi.

Lambert-Eaton myasthenic syndrome occurs extremely rarely in children. There are only 24 reported pediatric patients with a true diagnosis of LEMS worldwide. Therefore, obtaining safety and efficacy data for this population is challenging. This submission contained no controlled safety, efficacy or pharmacokinetic/exposure data for pediatric patients with LEMS. To support the indication in children 6 years of age and older, the clinical efficacy and safety of Ruzurgi were evaluated in 7 pediatric (<18 years of age) patients with LEMS who were treated with Ruzurgi through various compassionate use programs. Improvement in function was reported and etiology, clinical presentation, pathophysiology, and progression appeared to be similar to that seen in adult patients with LEMS. Although improvement in function was reported, 6 of the 7 patients also experienced various adverse events similar to those seen in adults, including one case of palpitations. No serious events were reported. Further, the pathway for the metabolism and clearance of amifampridine appears to reach maturity by 4 to 5 years of age, and is the same for both the pediatric and adult population. The efficacy of Ruzurgi in patients aged 6 to 17 years was further supported by population pharmacokinetic and modelling/simulation studies where exposure and dosing in the pediatric population was predicted utilizing weight allometric scaling based on adult exposure and efficacy data.

In the thorough QT study, JPC 3,4-DAP.TQT, patients classified as slow acetylators, based on genotyping for variants of the N‑acetyltransferase 2 (NAT2) gene, were more likely to experience adverse reactions during treatment with amifampridine than intermediate or rapid acetylators. This was further supported by a Phase I, randomized, double-blind, placebo-controlled, parallel-group study (JPC 3,4-DAP.PK1) involving healthy subjects where slow acetylators had an average maximum plasma concentration (Cmax) just over 2‑fold higher compared to intermediate acetylators in the fasted state, and between 2‑ to 4‑fold higher compared to fast acetylators in the fed state. Ruzurgi should be initiated at the lowest recommended starting dose in patients who are known NAT2 slow acetylators, and monitored for adverse reactions.

Ruzurgi has not been studied under controlled conditions in patients or volunteers with any degree of hepatic or renal impairment. Dosing recommendations and appropriate warnings and precautions are in place in the Ruzurgi Product Monograph.

A Risk Management Plan (RMP) for Ruzurgi was submitted by Medunik Canada 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 Ruzurgi 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, Ruzurgi, was accepted.

Overall, Ruzurgi has been shown to have a favourable benefit-harm-uncertainty profile based on non-clinical and clinical studies. Appropriate warnings and precautions are in place in the Ruzurgi Product Monograph to address the identified safety concerns.

This New Drug Submission complies with the requirements of sections C.08.002 and C.08.005.1 and therefore Health Canada has granted the Notice of Compliance pursuant to section C.08.004 of the Food and Drug Regulations. For more information, refer to the Clinical, Non‑clinical, and Quality (Chemistry and Manufacturing) Basis for Decision sections.

3 What steps led to the approval of Ruzurgi?

The drug submission for Ruzurgi was reviewed under the Priority Review Policy. Sufficient evidence was submitted demonstrating that Ruzurgi provided an effective treatment of a severely debilitating disease for which no drug is currently marketed in Canada.

Submission Milestones: Ruzurgi

Submission MilestoneDate
Request for priority status
Filed:2019-11-05
Approval issued by Director, Bureau of Medical Sciences:2019-12-05
Submission filed:2019-12-20
Screening
Screening Deficiency Notice issued:2020-01-21
Response filed:2020-01-27
Screening Acceptance Letter issued:2020-02-21
Review
Biostatistics Evaluation complete:2020-07-14
Quality Evaluation complete:2020-07-22
Review of Risk Management Plan complete:2020-07-30
Labelling Review complete, including Look-alike Sound-alike brand name assessment:2020-07-30
Clinical/Medical Evaluation complete:2020-08-04
Notice of Compliance issued by Director General, Therapeutic Products Directorate:2020-08-10

The Canadian regulatory decision on the review of Ruzurgi was based on a critical assessment of the data package submitted to Health Canada. The foreign review completed by the United States Food and Drug Administration was used as added reference.

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 mechanism by which the medicinal ingredient in Ruzurgi (amifampridine) exerts its therapeutic effect in patients with LEMS has not been fully elucidated. Amifampridine is a broad-spectrum potassium channel blocker. It acts on voltage-gated potassium channels in the presynaptic membrane, which prolongs the depolarizing phase of the action potential, thus lengthening the open time for voltage-gated calcium channels. This leads to the availability of more acetylcholine at the neuromuscular junction and may result in stronger muscle contractions.

The pharmacokinetic parameters of Ruzurgi were evaluated in a Phase I, randomized, double-blind, placebo-controlled, parallel-group study (JPC 3,4-DAP.PK1) involving healthy male and female volunteers. Subjects were randomized to receive either 20 mg Ruzurgi, 30 mg Ruzurgi, or placebo. On Study Day 1, a single dose was administered under fasting conditions. On Study Day 2, the same procedure was repeated under fed conditions (a high-calorie, high-fat meal).

Steady state was generally reached within 1 day of dosing. For both amifampridine and its metabolite, 3-N-acetyl amifampridine (3‑AC), pharmacokinetic parameters appeared to change proportionally to dose. The apparent oral clearance of amifampridine was 149 to 214 L/h and the average elimination half-life (t1/2) was 3.6 to 4.2 hours. The average t1/2 for 3‑AC was 4.1 to 4.8 hours. The majority (>65%) of amifampridine was recovered in urine as either the parent compound or 3‑AC. Food did not significantly alter the urine recovery, nor did it have a clinically relevant impact on t1/2, Cmax, or overall exposure. Ruzurgi can be taken without regard to food intake. However, food may mitigate paresthesia and abdominal discomfort.

Amifampridine is primarily metabolized by N-acetyltransferase 2 (NAT2) to the inactive 3‑AC metabolite. Metabolism of amifampridine by N-acetyltransferase 1 (NAT1) can also occur, but at a slower rate. Genetic variants in the NAT2 gene affect the rate and extent of amifampridine metabolism. Subjects with the slow acetylator phenotype had an average peak serum concentration (Cmax) just over 2‑fold higher compared to those with the intermediate acetylator phenotype in the fasted state, and between 2‑ to 4‑fold higher compared to those with the fast acetylator phenotype in the fed state.

Controlled clinical drug‑drug interaction studies have not been performed with Ruzurgi; however, drugs that affect NAT2 metabolism may affect the pharmacokinetics of amifampridine.

The effect of amifampridine on QTc interval prolongation was studied in a double-blind, randomized, placebo-and positive-controlled crossover study (JPC 3,4‑DAP.TQT) involving 52 healthy subjects (including 23 subjects with the NAT2 slow acetylator phenotype). Study participants were administered 120 mg amifampridine for 1 day in four equal doses of 30 mg at 4‑hour intervals. Amifampridine was associated with a QTcF (QT interval corrected for heart rate by the Fridericia formula) prolongation from 1 to 24 hours post‑dose. The maximum difference compared to placebo in mean change from baseline QTcF was 6.14 ms (90% confidence interval [CI]: 4.03, 8.25) at 15 hours post‑dose. In the slow acetylator subgroup, the maximum difference from placebo in mean change from baseline QTcF was 8.29 ms (90% CI: 5.10, 11.49) at 13.5 hours post‑dose. No individual subject had an increase in QTcF >30 ms.

Amifampridine treatment was associated with a reduction in heart rate, with a maximum difference from placebo in mean change from baseline heart rate of ‑3.15 beats per minute (bpm) (90% CI: ‑4.81, ‑1.50) at 13 hours post‑dose. In the slow acetylator subgroup, the maximum difference from placebo in mean change from baseline heart rate was ‑5.91 bpm (90% CI: ‑8.35, ‑3.48) at 12.5 hours post‑dose.

Of note, after the first 30 mg dose, the mean Cmax of amifampridine was 113 ng/mL (coefficient of variation [CV%] = 24.5) in slow acetylators, 52.4 ng/mL (CV% = 54.4) in intermediate acetylators, and 20.9 ng/mL (CV% = 7.0) in rapid acetylators.

The clinical relevance of these cardiac‑related findings is apparent in the analysis of more than 600 patients treated with amifampridine through various compassionate use programs (see Clinical Safety). Appropriate warnings and precautions are in place in the Ruzurgi Product Monograph to address the identified safety concerns.

Overall, the clinical pharmacological data support the use of Ruzurgi for the recommended indication.

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

Clinical Efficacy

The clinical efficacy of Ruzurgi (amifampridine) in adults (≥18 years of age) with Lambert-Eaton myasthenic syndrome (LEMS) was evaluated primarily in a small pivotal, randomized, double-blind, placebo-controlled, enriched, withdrawal study known as DAPPER. Two-thirds of the patients were female, 90% were Caucasian and the mean age was 56 years (range: 23 to 83 years). All eligible patients were required to have had a clinical diagnosis of LEMS and to have been stable on amifampridine for at least 90 days prior to study entry (Phase I). During Phase II of the study, a total of 32 patients were randomized to either continue their usual dose of amifampridine (continuous Ruzurgi arm; number of patients [n] = 14) or to be tapered off of amifampridine over 3 days to placebo, with up to an additional 16 hours with no active drug (taper-to-placebo arm; n = 18).

The primary efficacy endpoint was the categorization of the degree of change (e.g., >30% deterioration) in the Triple Timed Up and Go (3TUG) test upon withdrawal of Ruzurgi, compared with the time-matched average of the 3TUG at baseline. The 3TUG is a measure of the time it takes a person to rise from a chair, walk three meters, and return to the chair for three consecutive laps without pause. Higher 3TUG scores represent greater impairment. The key secondary endpoint was the change in the self-assessment of LEMS-related weakness (W‑SAS) score at the end of Phase II. Patients were to take the W‑SAS three times daily.

Results show that 72% of the patients in the taper-to-placebo arm had a >30% deterioration in the final 3TUG test following withdrawal of Ruzurgi, compared to 0% of those in the continuous Ruzurgi arm. Two patients in the taper-to-placebo arm experienced a >200% deterioration and 1 patient experienced a >100% to 200% deterioration. These results were supported by the W‑SAS secondary endpoint. Although there was a clear clinically and statistically significant separation between Ruzurgi and placebo arms, the following three caveats should be acknowledged. Firstly, this was a small study with very few patients randomized to the two groups. Secondly, this study was designed as an enriched withdrawal study with no amifampridine-naïve patients, which meant that, in order to be eligible to participate in Phase II, patients had to display adequate response to amifampridine during Phase I. Thirdly, Phase II of this study was quite short (approximately 5 days). Thus, there are no robust efficacy data in a controlled setting beyond a few days of treatment.

A pediatric (<18 years of age) indication was also sought for Ruzurgi. Due to the extreme rareness of LEMS in the pediatric population, there are no controlled clinical trials of amifampridine in this age group. Isolated reports of effectiveness in children receiving amifampridine through various compassionate use programs are available. A total of 7 pediatric patients with LEMS (age range: 9.6 to <18 years) have received amifampridine (total duration: 23.6 patient‑years). Improvement in function was reported, and etiology, clinical presentation, pathophysiology, and progression appeared to be similar to that of adult patients with LEMS. Further, the pathway for metabolism and clearance of amifampridine appears to reach maturity by 4 to 5 years of age and is the same for both the pediatric and adult populations. The efficacy of Ruzurgi in patients 6 to 17 years of age was further supported by population pharmacokinetic and modelling/simulation studies where exposure and dosing in the pediatric population was predicted utilizing weight allometric scaling based on adult exposure and efficacy data.

Considering the totality of evidence and the fact that patients with LEMS are usually under close supervision of a specialist, Health Canada has approved the use of Ruzurgi in patients 6 years of age and older.

Indication

Sponsor's proposed indicationHealth Canada-approved indication
Ruzurgi (amifampridine tablets) is indicated for the treatment of Lambert-Eaton myasthenic syndrome (LEMS) in patients 6 years of age or older.Ruzurgi (amifampridine) is indicated for the symptomatic treatment of Lambert-Eaton myasthenic syndrome (LEMS) in patients 6 years of age and older.

Lambert-Eaton myasthenic syndrome (LEMS) should be diagnosed by a health professional who has experience and knowledge in clinical features of this disease.

Ruzurgi should only be prescribed by health professionals who have experience in the treatment of LEMS, are knowledgeable of the efficacy and safety profile of this drug, and are able to discuss benefits/risks of treatment with patients.

Dosing recommendations and appropriate warnings and precautions are in place in the Ruzurgi Product Monograph to address the identified safety concerns.To ensure safe and effective use of Ruzurgi in the symptomatic treatment of Lambert-Eaton myasthenic syndrome, Health Canada included caveat statements in the indication related to the diagnosis of this disease and the initiation of treatment with Ruzurgi.

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

Clinical Safety

The effects of Ruzurgi on QTc interval prolongation was assessed in a double-blind, randomized, placebo-and positive-controlled crossover study (JPC 3,4‑DAP.TQT) involving healthy adult subjects (see Clinical Pharmacology). In this study, adverse reactions that occurred during Ruzurgi treatment and with incidence of at least 2% greater than with placebo treatment were dysesthesia, abdominal pain, dyspepsia, dizziness, nausea, back pain, muscle spasms, hypoesthesia, diarrhea, chest discomfort, pain in extremity, dysgeusia, paresthesia, hiccups, hot flush, and hypotension.

Amifampridine has been provided to more than 600 patients on a compassionate use basis over the last 27 years in Canada and the United States. The main source of data to support the long-term safety of Ruzurgi in adult patients with LEMS is the retrospective pharmacovigilance review of 162 patients with LEMS (54% female) who were treated with Ruzurgi through compassionate use programs. Among patients with available exposure data (n = 158), the median duration of treatment was 1.7 years (mean: 4.85 years; range: 1 day to 27.6 years) for a total of 766.4 person-years. The mean age at the time of treatment initiation was 58.7 years (range: 21 to 84 years). The median and mean of the maximum total daily dose was 75.0 mg/day and 68.3 mg/day, respectively.

In general, the most frequent adverse reactions observed were similar to those observed in the QT study involving healthy subjects. Additionally, the following adverse reactions were reported in ≥5% of long-term patients: falls, pneumonia, dyspnea, arthralgia, asthenia, depression, dysphagia, headache, insomnia, blurred vision, anemia, anxiety, constipation, feeling cold, gastroesophageal reflux disease, and pain. Of note, these reactions were captured retrospectively from compassionate use programs, and therefore, it is not possible to reliably estimate their frequency or establish a causal relationship to Ruzurgi.

A key safety issue associated with the use of amifampridine is the occurrence of seizures. Across the more than 600 patients who have received amifampridine, seizures were reported in 26 patients. Five of these patients experienced seizures during long-term use, three of whom were taking amifampridine 60 to 80 mg/day and did not have a prior history of seizures. Although seizures have been reported at various doses of amifampridine, data suggest that they are dose-dependent. Ruzurgi is contraindicated in patients with a history of seizures and should be used with caution in combination with drugs that are known to lower the seizure threshold.

Cardiac-related events have also been reported during amifampridine treatment. Across more than 600 patients treated with amifampridine in various compassionate use programs, 57 experienced one or more cardiac-related event, including QT interval prolongation. According to a database consisting of 234 patients who are part of long-term compassionate use programs, 25 patients experienced cardiac-related adverse events such as atrial fibrillation, cardiac arrest, tachycardia, and palpitations. Drugs that prolong the QTc increase the risk of torsade de pointes, a polymorphic ventricular tachyarrhythmia. Caution should be observed if Ruzurgi is administered to patients who have risk factors for torsade de pointes. Hypokalemia, hypocalcemia, and hypomagnesemia should be corrected prior to initiation or continuation of Ruzurgi.

The safety of Ruzurgi was evaluated in 7 pediatric (<18 years of age) patients with LEMS who were treated with amifampridine through compassionate use programs for. Adverse reactions reported in these patients were similar to those seen in adult patients with LEMS and included one patient with palpitations.

Patients classified as slow acetylators, based on genotyping for variants of the NAT2 gene, were more likely to experience adverse reactions during Ruzurgi treatment than intermediate or rapid acetylators. Ruzurgi should be initiated at the lowest recommended starting dose in patients who are known NAT2 slow acetylators and monitored for adverse reactions.

Amifampridine is metabolized by the liver and its inactive metabolite (3‑AC) is largely eliminated through the kidneys. There are no controlled data on the effects of amifampridine in patients with renal or hepatic impairment. Therefore, the Ruzurgi Product Monograph contains specific dosing recommendations for patients with renal or hepatic impairment, based on limited available information.

Considering the totality of evidence and that patients with LEMS are usually under the close supervision of a specialist, Health Canada has approved the use of Ruzurgi in patients 6 years of age and older.

Dosing recommendations and appropriate warnings and precautions are in place in the Ruzurgi Product Monograph to address the identified safety concerns.

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

7.2 Non-Clinical Basis for Decision

The non-clinical data demonstrate that amifampridine is a nonspecific voltage-dependent potassium channel blocker that shows relatively weak concentration inhibition in the half maximal inhibitory concentration (IC50) range of 187.6 to 1,575.1 µM. At the neuromuscular junction, amifampridine was shown to increase stimulus-evoked acetylcholine release (range: 0.25 to 6 µM), the mechanism by which potassium channel inhibition is thought to lead to the stimulation of muscle at the end plate.

In mouse, rat, and dog studies, the absorption of amifampridine after oral administration was rapid and increased with dose. Amifampridine metabolism to its 3‑AC metabolite was clearly demonstrated to occur primarily by NAT2 in mice, rats, and human hepatocytes. This route of metabolism is absent in dogs.

The general toxicity of amifampridine was characterized mainly in rats and dogs following amifampridine administration for up to 6 months and 9 months in duration, respectively. In a 6‑month dietary study in rats with a 1‑month recovery period, amifampridine was orally administered at target dose levels of 15, 45 and 135 mg/kg/day. The no-observed-adverse-effect level (NOAEL) was 100.72 mg/kg/day (Cmax = 475 ng/mL) in male rats and 42.74 mg/kg/day (Cmax = 21.5 ng/mL) in female rats. In a 9-month toxicity study in dogs with a 28-day recovery period, amifampridine was administered as an oral capsule at dose levels of 0.13, 0.52, 1.04 and 2.10 mg/kg/day. The NOAEL was 0.52 mg/kg/day (Cmax = 108 ng/mL) in male dogs and 1.04 mg/kg/day (Cmax = 215 ng/mL) in female dogs.

In both studies, adverse effects including decreased body weight gain and central nervous system (CNS) effects were observed at doses above the NOAEL. Reduction in body weight gain was linked to a reduction in food consumption and recovery occurred during the 1‑month non-dosing period. Adverse CNS‑related effects following oral administration of amifampridine generally occurred at Cmax and included convulsions and irregular respiration in rats at 70 mg/kg/day and sustained convulsions, incoordination, and increased activity in dogs at 2.10 mg/kg/day. Four dogs were euthanized moribund on Study Day 1 due to sustained convulsions following administration of the second dose. The majority of the remaining dogs in this dose group also showed several drug-related clinical signs on Study Day 1, but recovered by the next day. No drug-related mortality was observed in the rat study.

The margin of safety in relation to amifampridine plasma exposure at the NOAEL and the exposure level at which adverse CNS effects were observed is quite small, at approximately 2‑fold. This was supported by observations from a rat Irwin study where amifampridine was administered intravenously. Sustained convulsions, ataxia, and increased startle and hypersensitivity occurred almost immediately following the highest dose tested (6 mg/kg). Of note, in dogs, adverse CNS effects occurred at 4‑ to 8‑fold the mean clinical plasma exposure at the 30 mg dose. Since amifampridine is not metabolized into 3‑AC in dogs, it is inferred that the adverse body weight gains and CNS effects are mediated by the parent compound. This further supports the caution raised regarding differences in N‑acetylation rates (slow versus fast) found in patients, and the potential for CNS‑related toxicity.

Genotoxicity studies conducted with amifampridine demonstrate that amifampridine will not impose significant risk of mutagenicity to patients.

Studies to characterize potential risks of carcinogenicity and reproductive and developmental toxicity, including juvenile toxicity, were not conducted at the time of this submission. Due to the very rare nature of LEMS and the fact that amifampridine has been administered to at least 600 patients over the past 27 years, upon completion of the review of the submission, it was determined that the results of these studies were not essential for approval. The sponsor has committed to conducting further studies and providing completed study reports to Health Canada when available. While not essential for market authorization, publicly available safety information for the phosphate salt of amifampridine is included in the Product Monograph to ensure that it contains known information that may be relevant to the optimal, safe, and effective use of Ruzurgi.

Appropriate warnings and precautionary measures are in place in the Ruzurgi Product Monograph to address the identified safety concerns.

For more information, refer to the Ruzurgi 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 Ruzurgi 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 proposed shelf life of 3 months is acceptable when the drug product is stored between 20ºC to 25ºC and protected from moisture.

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.

None of the excipients used in the formulation of Ruzurgi is of human or animal origin.