Summary Basis of Decision for Ilumya

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 Ilumya is located below.

Recent Activity for Ilumya

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.

AnchorThe following table describes post-authorization activity for Ilumya, a product which contains the medicinal ingredient tildrakizumab. 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.

Updated: 2023-10-11

Drug Identification Number (DIN):

DIN 02516098 - 100 mg/mL tildrakizumab, solution, subcutaneous administration

Post-Authorization Activity Table (PAAT)

Activity/Submission Type, Control Number

Date Submitted

Decision and Date

Summary of Activities

SNDS # 270759

2022-12-16

Issued NOC 2023-07-28

Submission filed as a Level I – Supplement for a change in the drug substance release or shelf-life specifications. The submission was reviewed and considered acceptable, and an NOC was issued.

Drug product (DIN 02516098) market notification

Not applicable

Date of first sale: 2022-10-24

The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.

SNDS # 259965

2021-12-24

Issued NOC 2022-06-27

Submission filed as a Level I – Supplement for the addition of an alternate drug substance manufacturing site. The submission was reviewed and considered acceptable, and an NOC was issued.

NDS # 259259

2021-12-03

Issued NOC 2022-01-24

Submission filed to change the name of the drug sponsor from Sun Pharma Global FZE to Sun Pharmaceutical Industries Ltd. An NOC was issued.

Drug product (DIN 02516098) market notification

Not applicable

Date of first sale: 2021-08-04

The manufacturer notified Health Canada of the date of first sale pursuant to C.01.014.3 of the Food and Drug Regulations.

NDS # 224036

2019-01-25

Issued NOC 2021-05-19

NOC issued for New Drug Submission.

Summary Basis of Decision (SBD) for Ilumya

Date SBD issued: 2021-09-15

The following information relates to the New Drug Submission for Ilumya.

Tildrakizumab

Drug Identification Number (DIN):

  • DIN 02516098 - 100 mg/mL tildrakizumab, solution, subcutaneous administration

Sun Pharma Global FZE

New Drug Submission Control Number: 224036

 

On May 19, 2021, Health Canada issued a Notice of Compliance to Sun Pharma Global FZE for the drug product Ilumya.

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 Ilumya is favourable for the treatment of adult patients with moderate-to-severe plaque psoriasis who are candidates for systemic therapy or phototherapy.

 

1 What was approved?

 

Ilumya, an interleukin-23 inhibitor, was authorized for the treatment of adult patients with moderate-to-severe plaque psoriasis who are candidates for systemic therapy or phototherapy.

No data are available to Health Canada regarding the use of Ilumya in patients younger than 18 years of age. Consequently, an indication for pediatric use has not been authorized.

Limited data on the use of Ilumya in elderly (65 years of age and older) patients did not indicate differences in safety or efficacy in these patients compared to patients younger than 65 years of age.

Ilumya is contraindicated in patients who are hypersensitive to tildrakizumab or to any ingredient in the formulation, including any non-medicinal ingredients, or component of the container.

Ilumya 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.

Ilumya (100 mg/mL tildrakizumab) is presented as a solution. In addition to the medicinal ingredient, the solution contains L-histidine, L-histidine hydrochloride monohydrate, polysorbate 80, sucrose, 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 Ilumya Product Monograph, approved by Health Canada and available through the Drug Product Database.

 

2 Why was Ilumya approved?

 

Health Canada considers that the benefit-risk profile of Ilumya is favourable for the treatment of adult patients with moderate-to-severe plaque psoriasis who are candidates for systemic therapy or phototherapy.

Psoriasis, which manifests most often as plaque psoriasis, is a chronic, immune-mediated inflammatory disease of the skin. The disease is associated with significant negative effects on the physical and mental well-being of affected patients. Among patients diagnosed with psoriasis, approximately 18% have a moderate or severe form associated with extensive psoriatic plaques (thickened, erythematous, scaly patches of skin), itching, pain, and comorbidities including cardiovascular disease, obesity, type 2 diabetes, arthritis, chronic renal disease, and psychiatric disorders (anxiety, depression, and suicidal ideation).

First-line treatment options for patients with plaque psoriasis include topical agents (corticosteroids, vitamin D3 analogues, retinoids, anthralin, and tars). Moderate and severe disease is treated with phototherapy and systemic agents including acitretin (a systemic retinoid), cyclosporine, methotrexate, and biologic therapies such as interleukin inhibitors and tumour necrosis factor inhibitors.

Tildrakizumab, the medicinal ingredient in Ilumya, is a recombinant humanized immunoglobulin G1/kappa (IgG1/κ) antibody that binds to interleukin-23 (IL-23), a naturally occurring cytokine involved in inflammatory and immune responses. Along with other proinflammatory cytokines (e.g., tumour necrosis factor alpha [TNF-α], IL-12, and IL-17), IL-23 is a target of biologic therapies developed for plaque psoriasis. Anti-IL-23 agents authorized for the treatment of plaque psoriasis in Canada include risankizumab (Skyrizi, authorized in 2019), guselkumab (Tremfya, authorized in 2017), and ustekinumab, an anti-IL-23/IL-12 agent (Stelara, authorized in 2009).

The market authorization of Ilumya was based on efficacy and safety data derived primarily from two pivotal Phase III, international, double-blind, randomized, controlled clinical trials, P010 (reSURFACE 1) and P011 (reSURFACE 2), conducted in adults with moderate-to-severe plaque psoriasis who were candidates for phototherapy or systemic therapy.

Patients were treated with Ilumya at a dose of 100 mg (number of patients [n] = 616) or 200 mg (n = 622), or placebo (n = 310) administered subcutaneously at week 0, week 4, and every 12 weeks for up to 64 weeks in trial P010 and 52 weeks in trial P011. Placebo-treated patients were rerandomized to receive Ilumya 100 mg or 200 mg from week 12. In trial P011, 313 patients were treated with etanercept (a TNF-α inhibitor). Both trials included ongoing long-term (4-year) extension trials, the final results of which were not available to Health Canada.

The co-primary efficacy endpoints assessed in both trials were:

  • the proportion of patients who achieved at least 75% improvement in the Psoriasis Area and Severity Index (PASI) score from baseline (PASI 75) at week 12, and
  • the proportion of patients with a Physician Global Assessment (PGA) score of “clear” or “minimal”, with at least a 2-grade reduction from baseline, at week 12.

Key secondary endpoints were the proportion of patients who achieved improvement from baseline in PASI score of at least 90% (PASI 90) and 100% (PASI 100) at week 12.

In both trials, significantly more patients treated with Ilumya achieved these responses compared to placebo-treated patients. Over 60% of Ilumya-treated patients achieved a PASI 75 response and more than 54% attained a PGA response as defined above. Similarly, PASI 90 and PASI 100 responses were achieved by more of the Ilumya-treated patients than placebo-treated patients. The majority (over 80%) of Ilumya-treated patients who attained a PASI 75 response maintained that response for up to 64 weeks (in trial P010) or for up to 52 weeks (in trial P011).

The results of both pivotal studies were similar following various sensitivity (subgroup) analyses. Despite an attenuated efficacy effect seen in the subgroup of higher-weight (over 90 kg) patients treated with the 100 mg dose of Ilumya, an exposure-response model based on trial results found minimal clinical benefit of using the 200 mg dose in these patients.

Approximately 7.6% of patients treated with Ilumya 100 mg for up to 64 weeks developed antibodies to tildrakizumab (anti-drug antibodies, ADAs). Among these patients, 52% had antibodies that were classified as neutralizing. Notably, decreased efficacy was detected among Ilumya-treated patients who were positive for ADAs, particularly if they also had neutralizing ADAs. There was a 20% to 30% decrease in the proportion of Ilumya-treated patients achieving a PASI 75 response at week 12 when comparing ADA-positive to ADA-negative patients. However, these findings were based on a small sample size of approximately 5% of patients with treatment-emergent ADAs at that time.

The safety profile of Ilumya in patients with moderate-to-severe plaque psoriasis was consistent with that of other anti-IL-23 drugs. Through the 12 -week placebo-controlled periods of the pivotal trials, the most frequently reported (in at least 10% of patients) adverse events were upper respiratory tract infections, which occurred in 15.1% of patients in the Ilumya 100 mg group as compared to 12.3% of patients in the placebo group. The overall rate of infections and infestations was similar between the Ilumya 100 mg group and the placebo group: 20.9% versus 21.0%.

In the clinical trials, no events of anaphylaxis were reported in patients treated with Ilumya for up to 64 weeks. However, several cases of urticaria occurred during this period. Apart from drug-related hypersensitivity, adverse events of special interest included infections (those classified as serious adverse events or requiring intravenous antibiotics), malignancies (non-melanoma skin cancers and melanoma skin cancers), and major adverse cardiovascular events. Based on the available evidence, exposure to Ilumya over a period of 64 weeks was not associated with an increased incidence of the aforementioned serious adverse events. In addition, no serious adverse events of suicidal ideation and behaviour were reported in the clinical trials.

While trial P011 included the active comparator drug etanercept, neither trial assessed Ilumya against other anti-IL-23 drugs, given that at the time of the clinical development of Ilumya, no other anti-IL-23 drugs were commercially available.

The safety profile of Ilumya in the select subset of patients with moderate-to-severe plaque psoriasis who entered the open-label, uncontrolled, safety extension studies was consistent to that observed in the placebo-controlled studies.

A Risk Management Plan (RMP) for Ilumya was submitted by Sun Pharma Global FZE 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 Ilumya 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 Ilumya was accepted.

Overall, based on non-clinical and clinical studies, Ilumya has been shown to have a favourable benefit-risk profile for the target population. The identified safety issues can be managed through labelling and adequate monitoring. Appropriate warnings and precautions are in place in the Ilumya 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 Ilumya?

 

During the initial review of the submitted information for Ilumya, Health Canada identified key deficiencies in some elements of the control strategy of the manufacturing process. Consequently, a Notice of Deficiency (NOD) was issued on December 13, 2019.

In its response to the NOD, the sponsor addressed all of the comments adequately. The issues were resolved satisfactorily and Health Canada granted a Notice of Compliance on May 19, 2021.

 

Submission Milestones: Ilumya

Submission Milestone Date
Pre-submission meeting 2018-07-12
Submission filed 2019-01-25
Screening  
Screening Acceptance Letter issued 2019-02-27
Review  
Review of Risk Management Plan complete 2019-10-21
Labelling Review complete 2019-11-26
Quality Evaluation complete 2019-12-06
Non-Clinical Evaluation complete 2019-12-06
Clinical/Medical Evaluation complete 2019-12-09
Notice of Deficiency (NOD) issued by Director General, Biologic and Radiopharmaceutical Drugs Directorate (quality issues) 2019-12-13
Response filed 2020-06-08
Screening of Response to NOD  
Screening Acceptance Letter issued 2020-07-24
Review of Response to NOD  
Clinical/Medical Evaluation complete 2021-05-12
Quality Evaluation complete 2021-05-12
Labelling Review complete 2021-05-18
Notice of Compliance issued by Director General, Biologic and Radiopharmaceutical Drugs Directorate 2021-05-19

 

The Canadian regulatory decision on the review of Ilumya was based on a critical assessment of the data package submitted to Health Canada. The foreign reviews completed by the Australia's Therapeutic Goods Administration (TGA), European Medicines Agency (EMA) and 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 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:

See the Register of Innovative Drugs for a list of drugs that are eligible for data protection under C.08.004.1 of the Food and Drug Regulations, if applicable.

 

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

 

Clinical Pharmacology

The pharmacokinetics of tildrakizumab, the medicinal ingredient in Ilumya, was characterized in three Phase I pharmacokinetic studies in healthy subjects and two Phase I studies in psoriasis patients. In addition, sparse pharmacokinetic data were collected from the two pivotal Phase III studies (described in the Clinical Efficacy section) and one Phase II study in psoriasis patients. Data collected from six of these studies constituted the database for a population pharmacokinetic modelling analysis of subcutaneously administered tildrakizumab.

The formulation used in the Phase I/II clinical trials was a lyophilized powder for solution for injection in a vial (herein referred to as lyophilized formulation), whereas a solution for injection housed in a prefilled syringe (herein referred to as PFS formulation) was used in the Phase III clinical trials. No dedicated clinical trials were conducted to compare the pharmacokinetics of tildrakizumab following administration of the lyophilized formulation and following administration of the commercial PFS formulation. The population pharmacokinetic model showed that the lyophilized formulation had 5% lower bioavailability than the PFS formulation. This difference is not considered clinically relevant, since the simulated difference in exposure of tildrakizumab, using formulation as a covariate, fell within the clinical comparability bounds for exposure of tildrakizumab, where the Psoriasis Area and Severity Index (PASI) response and safety findings are not expected to be different. Thus, the pharmacokinetic properties of tildrakizumab administered as a lyophilized formulation or as a PFS formulation are expected to be similar.

Following single-dose subcutaneous administration, the pharmacokinetics of tildrakizumab was dose proportional over a dose range of 50 mg to 400 mg.

Based on population pharmacokinetic modelling results, the pharmacokinetics of tildrakizumab in psoriatic patients was characterized by a mean (percent coefficient of variation [%CV]) clearance of 0.32 L/day (38%), volume of distribution of 10.8 L (24%), absorption half-life of 1.5 days (18%), and elimination half-life of 23.4 days (23%).

Following the proposed dose regimen of 100 mg of tildrakizumab administered subcutaneously at week 0, week 4, and every 12 weeks thereafter, steady state was achieved by 16 weeks, with no accumulation observed. At steady state, the mean values (%CV) of the area under the concentration-time curve (AUC) to the end of the dosing period (AUC0-tau), maximum concentration (Cmax), and time to reach maximum concentration (Tmax) were 305 μg*day/mL (41%), 8.1 μg/mL (34%), and 6.2 days (46%), respectively. The median average concentration of tildrakizumab from week 1 to week 12 in psoriasis patients treated with the 100 mg dose was 6.4 μg/mL.

No pharmacokinetic studies were conducted in special populations (children, elderly, subjects with renal or hepatic impairment). The population pharmacokinetic analysis identified body weight as an important covariate on drug exposure. Lower average concentration and AUC were observed in subjects with higher body weights (over 90 kg). In clinical trials, in patients with a body weight over 90 kg, the 200 mg dose offered a minimal and inconsistent benefit over the 100 mg dose, and the risk-benefit profile was similar between the two doses. Thus, body weight-based dose adjustment is considered unnecessary.

Among patients treated with the 100 mg dose in the Phase III trials, the incidence of antibodies to tildrakizumab (anti-drug antibodies, ADAs) after up to week 64 of exposure was 7.6% (52 of 686 patients). Twenty-seven of the 52 patients (52%) who developed ADAs were positive for neutralizing antibodies. The pharmacokinetic profiles of tildrakizumab in ADA-positive patients were similar to those in the ADA-negative patients. However, lower mean tildrakizumab concentrations were found in patients with treatment-emergent neutralizing ADAs compared to patients who were negative for neutralizing ADAs.

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

Clinical Efficacy

Data derived from two pivotal Phase III trials (P010 [reSURFACE 1] and P011 [reSURFACE 2]) support the clinical efficacy of Ilumya for the treatment of adult patients with moderate-to-severe plaque psoriasis who are candidates for phototherapy or systemic therapy.

Based on results of a Phase IIb dose-range finding study, the pivotal studies used two doses of Ilumya (100 mg and 200 mg), administered subcutaneously at week 0, week 4, and every 12 weeks thereafter (for up to 64 weeks in the P010 trial and for up to 52 weeks in the P011 trial). Both trials included ongoing long-term (4-year) extension trials, the efficacy results of which were not available for Health Canada’s review.

The pivotal studies included 1,862 plaque psoriasis patients aged 18 years or older. At baseline, the patients had a body surface area involvement of ≥10%, a Physician Global Assessment (PGA) score of ≥3 in the overall assessment (plaque thickness, erythema, and scaling) of psoriasis on a severity scale of 0 to 5, a Psoriasis Area and Severity Index (PASI) score of ≥12, and were candidates for phototherapy or systemic therapy.

Trial P010 (reSURFACE 1) included three treatment arms (Ilumya 100 mg, Ilumya 200 mg, and placebo) for the primary efficacy assessments at week 12. At that point, the placebo-treated patients were rerandomized 1:1 to receive Ilumya100 mg or Ilumya 200 mg until week 28. At week 28, all non-responders (patients who did not achieve at least 50% improvement in PASI score from baseline) discontinued participation in the study, as per study design. Partial responders (patients who achieved improvement of 50% or greater but less than 75% improvement in PASI score from baseline) continued to receive treatment at the same dose (or at the higher, 200 mg dose, for half of the partial responders treated with Ilumya 100 mg). Responders (patients who achieved at least 75% improvement in PASI score from baseline [PASI 75]) were rerandomized to continue the same treatment or to receive placebo. Patients rerandomized to placebo were placed back on active treatment (at the same dose which they were originally receiving) if they experienced a relapse (i.e., a reduction of maximal PASI response by 50%).

Trial P011 (reSURFACE 2) included four treatment arms (Ilumya 100 mg, Ilumya 200 mg, etanercept, and placebo) for the primary efficacy assessments at week 12. After week 12 and until week 28, the placebo-treated patients were rerandomized 1:1 to receive 100 mg or 200 mg of Ilumya, whereas the etanercept-treated patients continued to receive etanercept. As per study design, at week 28, Ilumya non-responders discontinued participation in the study, while partial and full responders received either Ilumya 100 mg or Ilumya 200 mg according to a rerandomization scheme. Etanercept responders discontinued participation in the study, while partial or non-responders at week 28 were switched to Ilumya 200 mg.

In total, there were 616 patients randomized to Ilumya 100 mg, 622 to Ilumya 200 mg, 310 to placebo, and 313 to etanercept 50 mg (administered in trial P011 only). Of the Ilumya-treated patients, 8% to 9% discontinued treatment prior to week 28.

In both trials, the co-primary efficacy endpoints were the proportion of patients with a PASI 75 response at week 12 and the proportion of patients with a PGA score of “clear” or “minimal”, with at least a 2-grade reduction from baseline, at week 12. Key secondary endpoints were the proportion of patients who achieved improvement from baseline in PASI score of at least 90% (PASI 90) and 100% (PASI 100) at week 12.

After implementing non-responder imputation for missing data in the full analysis set, there were 62.5% of patients in the Ilumya100 mg arm, 64.0% in the Ilumya 200 mg arm, 48.2% in the etanercept 50 mg arm, and 5.8% in the placebo arm who achieved a PASI 75 response at week 12. Similarly, at week 12, 56.3%, 59.2%, 47.6%, and 5.8% of patients in the respective treatment arms achieved a PGA score of “clear” or “minimal”, with at least a 2-grade reduction from baseline. The differences in the two co-primary efficacy endpoints for each dose of Ilumya compared to placebo were statistically and clinically significant.

With regard to the key secondary endpoints, at week 12, a PASI 90 response was achieved by 36.7% of patients treated with Ilumya 100 mg, 36.0% of patients treated with Ilumya 200 mg, and 1.9% of placebo-treated patients, whereas a PASI 100 response was achieved by 13.2%, 12.9%, and 0.6% of patients in these groups, respectively. While patient-reported outcomes, measured by the Dermatology Life Quality Index (DLQI) questionnaire, were not incorporated as part of the key secondary endpoint testing strategy, it was noteworthy that, in both trials, 35% to 40% more patients in the Ilumya arms reported a DLQI score of 0 or 1 (minimal or no quality-of-life impairment) than in the placebo arms.

The following longer-term results relate to patients treated with the recommended dose of 100 mg of Ilumya.

In trial P010, 87.5% (98/112) of patients treated with Ilumya 100 mg who were PASI 75 responders at week 28 and who continued to receive the same dose of Ilumya maintained a PASI 75 response at week 64. Among the responders who at week 28 were rerandomized to receive placebo, about half maintained a PASI 75 response at week 64. Of the patients rerandomized to receive placebo who experienced a relapse and restarted the initial treatment of Ilumya 100 mg, 85.7% regained a PASI 75 response by week 64.

In trial P011, 93.6% (191/204) of patients treated with Ilumya 100 mg who were PASI 75 responders at week 28 maintained PASI 75 response at week 52. Among the patients who were partial responders at week 28, 68.4% achieved a PASI 75 response after continued treatment with Ilumya100 mg from week 28 to week 52.

The results of both trials were similar following various sensitivity (subgroup) analyses.

Approximately 7.6% of patients treated with Ilumya 100 mg for up to 64 weeks developed antibodies to tildrakizumab (anti-drug antibodies, ADAs). Among these patients, 52% had antibodies that were classified as neutralizing. Of note, decreased efficacy was detected among Ilumya-treated patients who were positive for ADAs, particularly if they also had neutralizing ADAs. There was a 20% to 30% decrease in the proportion of Ilumya-treated patients achieving a PASI 75 response at week 12 when comparing ADA-positive to ADA-negative patients. However, these findings were based on a small sample size of approximately 5% of patients with treatment-emergent ADAs at that time.

While the P011 pivotal trial included one active comparator (etanercept, a tumour necrosis factor inhibitor), neither pivotal trial assessed Ilumya against other anti-IL-23 drugs, given that at the time of the clinical development of Ilumya, no other anti-IL-23 drugs were commercially available.

In summary, the recommended regimen of 100 mg of Ilumya administered at week 0, week 4, and every 12 weeks thereafter, offers significant benefit in terms of improvement of the common indicators of psoriatic disease severity and status (PASI and PGA scores). Patients who responded to treatment in the clinical trials were very likely to continue to exhibit improvement for up to 64 weeks. Data beyond 64 weeks were not available for assessment.

Indication

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

  • Ilumya (tildrakizumab injection) is indicated for the treatment of adult patients with moderate-to-severe plaque psoriasis who are candidates for systemic therapy or phototherapy.

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

Clinical Safety

The safety profile of Ilumya in patients with moderate-to-severe plaque psoriasis is based primarily on pooled data from two pivotal Phase III clinical trials (P010 [reSURFACE 1] and P011 [reSURFACE 2], described in the Clinical Efficacy section).

In total, the pooled safety dataset included 1,861 patients (616 patients treated with Ilumya 100 mg, 622 patients treated with Ilumya 200 mg, 310 patients treated with placebo, and 313 patients treated with etanercept 50 mg). Among the 1,238 patients who were exposed to Ilumya, 642 received Ilumya 100 mg for at least 52 weeks, 587 for at least 78 weeks, and 469 for at least 104 weeks.

Through the 12-week placebo-controlled periods of the pivotal trials, the most frequently reported (in at least 10% of patients) adverse events were upper respiratory tract infections, which occurred in 15.1% of patients in the Ilumya 100 mg group as compared to 12.3% of patients in the placebo group. The overall rate of infections and infestations was similar between the Ilumya 100 mg group and the placebo group: 20.9% versus 21.0%.

No events of anaphylaxis were reported in patients treated with Ilumya for up to 64 weeks in the clinical trials. However, several cases of urticaria occurred during this period. Apart from drug-related hypersensitivity, adverse events of special interest included infections (those classified as serious adverse events or requiring intravenous antibiotics), malignancies (non-melanoma skin cancers and melanoma skin cancers), and major adverse cardiovascular events. Based on the available evidence, exposure to Ilumya over a period of 64 weeks is not associated with an increased incidence of the aforementioned serious adverse events. In addition, no serious adverse events of suicidal ideation and behaviour were reported in the clinical trials.

Treatment with any therapeutic protein is accompanied by the risk of immunogenicity (the development of anti-drug antibodies, which have the potential to neutralize the biological activity of the drug). Approximately 7.6% of patients treated with Ilumya 100 mg for up to 64 weeks developed antibodies to tildrakizumab. Among these patients, 52% had antibodies that were classified as neutralizing.

The safety profile of Ilumya in the select subset of patients with moderate-to-severe plaque psoriasis who entered the open-label, uncontrolled, safety extension studies was consistent to that observed in the placebo-controlled studies.

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

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

 

 

 

7.2 Non-Clinical Basis for Decision

 

Tildrakizumab, the medicinal ingredient in Ilumya, was shown to bind to human interleukin-23 (IL-23) with high affinity in vitro and to inhibit IL-23 signalling in cell-based assays.

No overt toxicity findings were observed in cynomolgus monkeys given subcutaneous injections of tildrakizumab once every two weeks for 3 or 9 months. The no-observed-adverse-effect level (NOAEL) for tildrakizumab in the 3- and 9-month repeated-dose toxicity studies was 140 mg/kg body weight and 100 mg/kg body weight, respectively (corresponding to exposures that were 133-fold and 90-fold greater than the estimated human exposure at the maximum recommended human dose [MRHD]).

No malformations or embryo-fetal toxicity were observed in an embryo-fetal development study, in which pregnant cynomolgus monkeys received tildrakizumab at doses of up to 300 mg/kg (159-fold greater than the estimated human exposure at the MRHD) by subcutaneous injection once every two weeks during organogenesis (gestation days 20 to 118).

In a pre- and postnatal development toxicity study, subcutaneous doses of 0 (vehicle), 10, and 100 mg/kg tildrakizumab were administered to pregnant cynomolgus monkeys once every two weeks from gestational day 50 to parturition. No tildrakizumab-related increase in pregnancy loss was observed. However, neonatal monkey deaths were observed, where maternal monkeys were given tildrakizumab (1/12 [8%] in the vehicle control group, 2/12 [17%] in the low-dose group and 4/14 [29%] in the high-dose group). These neonatal deaths were attributed to maternal neglect, except for two neonates in the high-dose group, which died following viral infection. A drug-related effect could not be ruled out. A NOAEL of 10 mg/kg body weight (6-fold greater than the estimated human exposure at the MRHD) was determined based on an increase in postnatal deaths from infection observed at the highest dose.

The developmental studies showed that tildrakizumab crossed the placenta during pregnancy, as its presence was documented in the fetal serum.

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

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

 

 

7.3 Quality Basis for Decision

 

Characterization of the Drug Substance

Tildrakizumab, the medicinal ingredient in Ilumya, is a humanized immunoglobulin G1/kappa (IgG1/κ) monoclonal antibody that specifically binds to interleukin-23 (IL-23) and inhibits its interaction with the IL-23 receptor. The average molecular weight of tildrakizumab is 144,144 Da.

Detailed characterization studies were performed to provide assurance that tildrakizumab consistently exhibits the expected structural, physicochemical, and functional characteristics.

Results from process validation studies indicate that the processing steps adequately control the levels of product- and process-related impurities. The impurities that were reported and characterized were found to be within established limits.

Manufacturing Process and Process Controls of the Drug Substance and Drug Product

Tildrakizumab is produced in Chinese hamster ovary (CHO) cells by recombinant deoxyribonucleic (DNA) technology. The antibody is expressed as a secreted product of the CHO cells.

The drug substance manufacturing process consists of cell culture, harvesting, purification, and formulation steps. Cell culture is initiated by thawing a vial of the working cell bank. The cell substrate biomass is expanded by sequential subcultivation into a progressively larger volume of medium to generate sufficient inoculum volume for the production bioreactor, which is operated in a batch mode until harvesting. The recovered cell suspension is processed by centrifugation and filtration, resulting in a clarified supernatant. Tildrakizumab is purified using a series of chromatographic, filtration, and chemical treatment steps. Purified tildrakizumab is subsequently formulated, and diluted to the target concentration of 90 mg/mL to 110 mg/mL. Finally, the formulated bulk is filtered, transferred into bags, and stored at or below -40±5 °C in controlled temperature units.

Operating parameters associated with each unit operation were adequately described and justified. The performance of the manufacturing process is routinely monitored by in-process testing of relevant process intermediates against justified acceptance criteria.

The drug substance manufacturing process was validated at commercial scale and/or characterized using qualified small-scale models. Accordingly, its capability to remove specific impurities, including viruses, has been adequately demonstrated. The provided batch analysis data confirm that the proposed drug substance manufacturing process consistently yields a drug substance of acceptable quality.

The drug product manufacturing process includes: i) thawing, pooling and mixing, bioburden reducing and sterile filtration, filling into syringes followed by visual inspection; and ii) manufacturing of the combination product that includes labelling of the prefilled syringe, assembly with the safety device components, and visual inspection followed by secondary packaging of the assembled product.

The performance of the manufacturing process is monitored routinely through in-process testing against justified acceptance criteria. The manufacturing process was validated at commercial scale to establish the overall consistency and effectiveness of aseptic operations. The provided batch analysis data confirm that the proposed drug product manufacturing process consistently yields a drug product of acceptable quality.

Control of the Drug Substance and Drug Product

Specifications for the drug substance and drug product include acceptance criteria for identity, quantity, purity, potency, impurities, and safety parameters. The relevant analytical methods were validated or qualified, and the acceptance criteria were appropriately justified.

Through Health Canada’s lot release testing and evaluation program, consecutively manufactured final product lots were tested using a subset of release methods. All results obtained during the lot-to-lot consistency testing and in-house data analyses were acceptable and within the manufacturer’s specifications.

Ilumya is a Schedule D (biologic) drug and is, therefore, subject to Health Canada’s Lot Release Program as per Health Canada’s Guidance for Sponsors: Lot Release Program for Schedule D (Biologic) Drugs.

Stability of the Drug Substance and Drug Product

Based on the stability data submitted, the proposed shelf life and storage conditions for the drug substance and drug product were adequately supported and are considered to be satisfactory.

The stability data support the proposed shelf life of 36 months for the drug product, when stored at 2 °C to 8 °C in the original carton to protect from light.

Facilities and Equipment

While initially recommended, an on-site evaluation of the drug substance manufacturing facility was not feasible at the time of the review because of process discontinuation and transferring to a new manufacturing site. The sponsor is expected to file a Supplement to a New Drug Submission for the approval of the new manufacturing site.

Based on a risk assessment score determined by Health Canada, an on-site evaluation of the drug product manufacturing facilities was not deemed necessary.

The design, operations, and controls of the facilities and equipment involved in the production are considered suitable for the activities and products manufactured.

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

Adventitious Agents Safety Evaluation

The tildrakizumab manufacturing process incorporates adequate control measures to prevent contamination and maintain microbial control. Pre-harvest culture fluid from each lot is tested to ensure freedom from adventitious microorganisms (bioburden, mycoplasma, and viruses) and appropriate limits are set. Purification process steps designed to remove and inactivate viruses are adequately validated.

No raw materials of human or animal origin are used in the tildrakizumab manufacturing process. The excipients used in the drug product formulation are not of animal or human origin.

Although the sucrose used in the manufacture of the drug substance is derived from sugar cane, it is decolourized through a process using bone char of animal origin. The bones (i.e., bone-derived charcoal) are sourced from countries free of bovine spongiform encephalopathy and the manufacturing process of the bone-derived charcoal includes a step of heating at 1,000 °C for twelve hours.