Summary Basis of Decision for Tissueblue

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 Tissueblue is located below.

Recent Activity for Tissueblue

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 Tissueblue

Date SBD issued: 2021-06-02

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

Brilliant Blue G

Drug Identification Number (DIN):

  • DIN 02510995 - 0.25 mg/mL Brilliant Blue G, solution, intravitreal administration

Dutch Ophthalmic Research Center International BV

New Drug Submission Control Number: 232449

On January 15, 2021, Health Canada issued a Notice of Compliance to Dutch Ophthalmic Research Center International BV for the drug product Tissueblue.

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 Tissueblue is favourable for use as an aid in ophthalmic surgery by selectively staining the internal limiting membrane (ILM).

1 What was approved?

Tissueblue, an ophthalmic dye, was authorized for use as an aid in ophthalmic surgery by selectively staining the internal limiting membrane (ILM).

Health Canada has not authorized an indication for use in pediatric patients (<9 years of age) as no data are available in this population.

Tissueblue is contraindicated in patients who are hypersensitive to this drug or to any ingredient in the formulation, including any non-medicinal ingredient, or component of the container.

Tissueblue 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.

Tissueblue (0.25 mg/mL Brilliant Blue G) is presented as a solution. In addition to the medicinal ingredient, the solution contains polyethylene glycol, sodium chloride, sodium phosphate dibasic dodecahydrate, sodium phosphate monobasic dihydrate, and water for injection.

For more information, refer to the Clinical, Non-clinical, and Quality (Chemistry and Manufacturing) Basis for Decision sections.

Additional information may be found in the Tissueblue Product Monograph, approved by Health Canada and available through the Drug Product Database.

2 Why was Tissueblue approved?

Health Canada considers that the benefit-harm-uncertainty profile of Tissueblue is favourable for use as an aid in ophthalmic surgery by selectively staining the internal limiting membrane (ILM).

The vitreous body of the eye undergoes several biochemical changes through aging, which cause progressive liquefaction of the vitreous gel. This may eventually result in a posterior vitreous detachment (PVD), which can lead to the development of a macular hole or an epiretinal membrane (ERM) when adhesions along the vitreoretinal interface occur in the macular area. These conditions may be treated by releasing the tractions between the vitreous body and the macula. Three tissues in the eye are of interest for this type of surgery: the posterior hyaloid, the ERM, and the ILM. All three tissues are thin and transparent, and therefore difficult to visualize. The use of vital dyes during the surgery facilitates the procedure and improves safety by improving contrast between the ILM and the remaining retina.

Brilliant Blue G (BBG) is a common laboratory reagent used for protein visualization during gel electrophoresis. It has been marketed in the European Union since 2007. The dye stains the ILM by forming a stable, negatively charged complex with the basic amino acid residues of proteins (mainly arginine and aromatic amino acids). Retinal toxicity has been reported with BBG and is a factor of exposure time and concentrations. The concentration used in the proposed product (0.25 mg/mL) is considered safe with an exposure of less than 3 minutes, as is expected with retinal surgery.

The New Drug Submission (NDS) for Tissueblue was filed as a Submission Relying on Third-Party Data (SRTD). The evidence of safety and efficacy is based heavily on published literature and other publicly available references, rather than on original clinical data. The published literature submitted by the sponsor included 13 articles supporting the efficacy of Tissueblue for the proposed indication, two of which were considered pivotal: Carpenter et. al., 2013, and Mohr et. al., 2013.

In the study by Carpenter et. al. (2013), surgeons conducted a specific procedure using three different dyes containing BBG, one of which was Tissueblue. The dyes were used at two stages during the procedure. The surgeons assessed the status of the ILM at each stage, and reported on the usefulness of each dye for visualization. The dyes were applied to 98 eyes from 92 patients. In 37% of cases, the surgeon was unable to determine the status of the ILM before the second staining. In the remaining cases (29 out of 61 cases), the surgeon's opinion often changed following the second staining. Surgeons reported a 100% rate of "utility for visualization" for Tissueblue, indicating that there were no staining failures with the product in this study.

The study reported by Mohr et. al. (2013) was a prospective multicentre cohort study in patients undergoing ERM removal. One of the dyes used in these procedures was a solution of 0.25 mg/mL BBG and 4% polyethylene glycol, as contained in Tissueblue. This solution was used in 64 eyes, and surgeons reported adequate visualization and removal of the membranes in 95% of patients (61 out of 64 eyes). In three patients (5%), the staining effect obtained was insufficient and Indocyanine (IC) Green was used as a backup stain. The second dye was a dual dye solution (containing two active ingredients) consisting of 0.15% Trypan Blue, 0.25 mg/mL BBG, and 4% polyethylene glycol. This solution was used in 63 eyes, and 97% reported adequate visualization (61 out of 63 eyes).

Collectively, the pivotal and supportive studies submitted included a sufficient number of patients exposed to an identical product to determine that Tissueblue is effective when used according to the approved indication.

Clinical safety data were collected from 51 peer‑reviewed articles including data from 2,627 patients in whom staining agents were administered to 2,645 eyes. Major treatment types included ILM‑Blue, BBG, IC Green, and Trypan Blue.

A total of 284 adverse events were reported across all treatment groups. Adverse events were reported in 133 out of 1,145 subjects (12%) who received BBG from any source. The most commonly reported adverse event in subjects treated with BBG was cataract development or progression (69 subjects; 6%). Vitreous detachment, transient ocular hypertension, and retinal hemorrhage were also reported in approximately 1% each of subjects. All reported adverse events are common with the ophthalmic surgical procedures that were performed, and are frequently attributed to the vitrectomy itself.

Adverse events that only occurred in the BBG group included retinal break/tear and hemorrhage, cystoid macular edema, transient ocular hypertension, and cataract formation. These adverse events are also frequently attributed to the vitrectomy procedure. No serious, long‑term or delayed adverse events, or deaths were reported in the safety database. No differences were identified between population subgroups, including age or race.

The Mohr et. al. (2013) article reported that residual staining and dye remnants in the eye could not be detected in the month after surgery, which was of special interest and supported transient local action of BBG.

More than 275,000 units of the product have been distributed worldwide since the initial approval in 2010 in the European Union. No post‑marketing adverse reactions have been reported to the manufacturer since the product was launched.

A Risk Management Plan (RMP) for Tissueblue was submitted by Dutch Ophthalmic Research Center International BV 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 Tissueblue Product Monograph meet the necessary regulatory labelling, plain language and design element requirements.

A review of the submitted brand name assessment, including testing for Look‑alike Sound‑alike attributes, was conducted and the proposed name Tissueblue was accepted.

Tissueblue 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 Tissueblue 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 Tissueblue?

The New Drug Submission for Tissueblue was filed as a Submission Relying on Third‑Party Data (SRTD), according to the Guidance Document: Drug Submissions Relying on Third-Party Data (Literature and Market Experience).

Brilliant Blue G, the medicinal ingredient in Tissueblue, is a common laboratory reagent used for protein visualization during gel electrophoresis. It was first authorized in the European Union, and since 2007, has been marketed as a medical device for visualizing the internal limiting membrane.

Submission Milestones: Tissueblue

Submission MilestoneDate
Pre-submission meeting2019-05-29
Submission filed2019-09-27
Screening
Screening Deficiency Notice issued2019-12-27
Response filed2020-02-04
Screening Acceptance Letter issued2020-03-23
Review
Review of Risk Management Plan complete2020-11-28
Labelling Review complete2020-12-17
Quality Evaluation complete2021-01-13
Clinical/Medical Evaluation complete2021-01-14
Notice of Compliance issued by Director General, Therapeutic Products Directorate2021-01-15

The Canadian regulatory decision on the review of Tissueblue 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 (FDA) was used as an added reference.

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

A solution of Brilliant Blue G (BBG) and 4% polyethylene glycol (PEG), as contained in Tissueblue, has been shown to selectively stain the internal limiting membrane (ILM) but not the epiretinal membrane (ERM) nor the retina, making it easier to visualize for removal. However, the exact mechanism of this selectivity has not been elucidated.

Systemic uptake of BBG 0.025% solution is expected to be negligible during a clinical chromovitrectomy. Therefore, clinical pharmacology studies were not deemed relevant for the proposed indication.

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

Clinical Efficacy

As a Submission Relying on Third-Party Data (SRTD), the evidence of clinical efficacy of Tissueblue was obtained primarily from published literature and other publicly available references. Instead of original clinical data, the sponsor submitted a comprehensive literature review including articles reporting on patients exposed to BBG solutions of various concentrations and formulations. The sponsor’s literature search identified 13 articles to support the efficacy of Tissueblue for the proposed indication, including two articles which were considered pivotal: Carpenter et. al., 2013, and Mohr et. al., 2013.

In the study by Carpenter et. al. (2013), surgeons conducted a specific procedure using three different dyes containing BBG, one of which was Tissueblue. The dyes were used at two stages during the procedure, and the surgeons reported on the usefulness of each dye for visualization. The BBG solution was first used to stain the ERM, which was then removed. The surgeon then observed and recorded the status of the underlying ILM. The posterior pole was stained a second time with the BBG solution. The same assessment of ILM status was repeated, followed by peeling of the remaining ILM.

Along with Tissueblue, which contains BBG and 4% PEG, two other dyes were included in this study. Both dyes contained BBG and heavy water (D2O) without PEG. The dyes were applied to 98 eyes from 92 patients. In 37% of cases, the surgeon was unable to determine the status of the ILM before the second staining. In the remaining cases (29 out of 61 cases), the surgeon’s opinion often changed following the second staining. Surgeons reported a 100% rate of “utility for visualization” for Tissueblue, indicating that there were no staining failures with the product in this study.

The study reported by Mohr et. al. (2013) was a prospective multicentre cohort study in patients undergoing ERM removal. The mean patient age was 68 ± 1.3 years. One of the dyes used in these procedures was a solution of 0.25 mg/mL BBG and 4% PEG, as is contained in Tissueblue. This solution was used in 64 eyes, and surgeons reported adequate visualization and removal of the membranes in 95% of patients (61 out of 64 eyes). In three patients (5%), the staining effect obtained was insufficient and Indocyanine (IC) Green was used as a backup stain. The second dye was a dual dye solution (containing two active ingredients) consisting of 0.15% Trypan Blue, 0.25 mg/mL BBG, and 4% PEG. This solution was used in 63 eyes, and 97% reported adequate visualization (61 out of 63 eyes).

Supportive evidence of the efficacy of BBG for staining the ILM was provided through nine additional articles commenting on studies in which patients in at least one study arm received BBG. The exact formulations described were different from the proposed product with respect to the concentration of BBG and/or the excipients. All nine articles reported similar efficacy rates when considering the facilitation of ILM visualization.

Collectively, the studies included a sufficient number of patients exposed to an identical product to determine that Tissueblue is effective when used according to the approved indication.

Indication

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

  • Tissueblue (Brilliant Blue G Injection) is indicated for use as an aid in ophthalmic surgery by selectively staining the internal limiting membrane (ILM).

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

Clinical Safety

Clinical safety data were collected from 51 peer‑reviewed articles including data from 2,627 patients in whom staining agents were administered to 2,645 eyes. Major treatment types included ILM‑Blue, BBG, IC Green, and Trypan Blue. A small number of patients received bromophenol blue, Chicago Blue, Membrane Blue‑Dual, triamcinolone, or no staining agent.

A total of 284 adverse events were reported across all treatment groups. Adverse events were reported in 133 out of the 1,145 subjects (12%) who received BBG from any source. The most commonly reported adverse event in subjects treated with BBG was cataract development or progression (69 subjects; 6%). Vitreous detachment, transient ocular hypertension, and retinal hemorrhage were also reported in approximately 1% each of subjects. All reported adverse events are common with the ophthalmic surgical procedures that were performed, and are frequently attributed to the vitrectomy itself.

Adverse events that only occurred in the BBG group included retinal break/tear and hemorrhage, cystoid macular edema, transient ocular hypertension, and cataract formation. These adverse events are all also frequently attributed to the vitrectomy procedure. No serious, long‑term or delayed adverse events, or deaths were reported in the safety database. No differences were identified between population subgroups, including age or race.

The Mohr et. al. (2013) article reported that residual staining and dye remnants in the eye could not be detected in the month after surgery, which was of special interest and supported transient local action of BBG.

More than 275,000 units of the product have been distributed worldwide since the initial approval in 2010 in the European Union. No post‑marketing adverse reactions have been reported to the manufacturer since the product was launched.

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

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

7.2 Non-Clinical Basis for Decision

The non‑clinical package submitted for review included in vitro cytotoxicity studies, a complete battery of genotoxicity tests, a review of scientific publications of in vitro and in vivo studies conducted with Brilliant Blue G (BBG), skin sensitizing studies in guinea pigs, and studies in rabbits examining ocular and skin irritation, as well as single‑dose ocular toxicity. Overall, the toxicology data reviewed did not raise any safety issues that would preclude the approval of Tissueblue for short‑term ocular use.

The ocular toxicity of BBG was primarily evaluated in a single‑dose ocular toxicity study in rabbits. A single bilateral intravitreal injection (25 or 50 µg/eye) or subretinal injection (12.5 or 25 µg/eye) of a purified formulation of BBG was administered, after which the rabbits were observed for a 14‑day recovery period.

There were no macroscopic or microscopic treatment‑related findings following a single intravitreal injection in the controls or in BBG‑treated groups. Following subretinal administration, anterior segment inflammation, vitreous opacity, and the presence of vitreal hemorrhage were observed in the controls as well as in BBG‑treated groups. Minimal to marked microscopic retinal changes (detachment and degeneration) were also detected in both the control and BBG‑treated groups, with increased severity and/or incidence in BBG‑treated groups. The changes observed in animals dosed by subretinal injection may be related to the surgical procedure. However, a contribution from the test article could not be ruled out, considering the increased severity and/or incidence seen in animals treated with BBG.

Electroretinogram (ERG) changes, including reductions in scotopic a‑wave and/or b‑wave amplitude, were observed at both doses following intravitreal administration and in the high dose group following subretinal administration. The blue colour in the vitreous body may have contributed to the ERG changes observed. However, a direct effect of the test article could not be ruled out. Similar observations were reported in the published literature submitted for review with respect to ERG changes in in vitro studies and one in vivo study using a 0.025% solution of BBG. In both types of studies, the effect of BBG on ERG responses was reversible.

Plasma concentrations of BBG from 24 hours post‑dose through Day 14 were below the limit of quantitation (<10 ng/mL) following intravitreal and subretinal administration, although high levels were observed in ocular tissues (primarily in the retina). There is no margin of exposure between any of the doses used in the animal ocular toxicity study and the expected clinical dose. However, the exposure in animals during the study was far greater than the anticipated exposure in humans in clinical practice. In humans, BBG is mostly removed during the internal limiting membrane peeling procedure, whereas in the animal study, the dye was not removed during the 14‑day recovery and observation period.

A purified BBG preparation was used in the ocular toxicity study, whereas the intended clinical product contains the excipient polyethylene glycol (PEG). No in vivo studies have been conducted to evaluate the ocular toxicity of PEG‑containing formulations of BBG. However, an in vitro cytotoxicity assessment using the direct contact test showed that a 0.025% solution of BBG containing PEG was not cytotoxic to mammalian fibroblasts (BALB/3T3 clone A31). In published in vitro studies, no adverse cytotoxicity or ERG findings were reported with PEG alone or with BBG solutions containing PEG. Brilliant Blue G was not genotoxic in in vitro and in vivo genotoxicity assays. Brilliant Blue G 0.025% solution is indicated for a single‑dose ophthalmic use with subsequent removal of most of the dye, and has negligible systemic uptake. Therefore, repeat‑dose, carcinogenicity, and reproduction and development studies are not considered to be relevant and have not been conducted.

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

For more information, refer to the Tissueblue 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 Tissueblue 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 24 months is acceptable when the drug product is stored at room temperature (15 ºC to 25 ºC). The product should be protected from light, heat, freezing, and moisture.

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 Tissueblue are of human or animal origin.