CENTER FOR DRUG EVALUATION AND RESEARCH
[Pages:1514]CENTER FOR DRUG EVALUATION AND
RESEARCH
APPLICATION NUMBER:
208259Orig1s000
SUMMARY REVIEW
Cross-Discipline Team Leader Review and
Deputy Division Director Summary Review
Date From
Subject
NDA# Applicant Date of Submission PDUFA Goal Date Proprietary Name Established or Proper Name Dosa2e Form Re2ulatorv Action
Recommended Indication(s)
Recommended Dosin2 Re2imen(s)
March 12, 2019 William M. Boyd, M.D. and Wiley A. Chambers, M.D. Cross-Discipline Team Leader Review an d Deputy Division Director Summary Review 208259 Aerie Phaim aceuticals, Inc. May 14, 2018 Mai?ch 14, 2019 Rocklatan Netarsudil and latanoprost ophthalmic solution Topical ophthalmic solution Approval Reduction of elevated intraocular pressure (IOP) in patients with open-angle glaucoma or oculai? hype1iension One drop in the affected eye(s) once daily in the evening
1. Benefit-Risk Assessment
Netarsudil and latan oprost ophthalmic solution, 0.02%/0.005% (fon nerly PG324) is a fixed-dose combination (FDC) of 2 FDA-approved oculai? hypotensive active components, netai?sudil ophthalmic solution, 0.02% and latanoprost ophthalmic solution, 0.005%, and has been studied by Aerie Phan naceuticals, Inc. {Aerie) as a once-daily treatment for the reduction of elevated intraoculai? pressure (IOP) in patients with open-angle glaucoma {OAG) or ocular hype1iension (OHT) .
The benefits of netarsudil and latan oprost ophthalmic solution, 0.02%/0.005% in lowering intraoculai? pressure outweighs the risks to patients with open-angle glaucoma or oculai? hype1iension.
Reference ID 4402232
Cross Discipline Team Leader Review and Deputy Division Director Review
Original NDA 208259 Rocklatan (netarsudil and latanoprost ophthalmic solution) 0.02%/0.005%
Benefit-Risk Assessment Framework
Benefit-Risk Integrated Assessment
The data contained in this submission establishes the efficacy of netarsudil and latanoprost ophthalmic solution, 0.02%/0.005% dosed once daily in the affected eye(s) in the evening for lowering elevated IOP in patients with open-angle glaucoma or ocular hypertension. Elevated IOP is a major risk factor in the development of visual field loss in patients with open-angle glaucoma.
In Studies PG324-CS301 and PG324-CS302, the average IOP lowering effect of netarsudil and latanoprost ophthalmic solution, 0.02%/0.005% was 1 to 3 mmHg greater than monotherapy with either netarsudil 0.02% or latanoprost 0.005% throughout 3 months. In Study -301, IOP reductions were maintained throughout 12 months.
The most common ocular adverse reaction observed in controlled clinical studies with netarsudil and latanoprost ophthalmic solution, 0.02%/0.005% was conjunctival hyperemia which was reported in 59% of patients. Other common ocular adverse reactions reported were: instillation site pain (20%), corneal verticillata (15%), and conjunctival hemorrhage (11%). Eye pruritus, visual acuity reduced, increased lacrimation, instillation site discomfort, and blurred vision were reported in 5-8% of patients.
The potential benefits of netarsudil and latanoprost ophthalmic solution, 0.02%/0.005% through lowering elevated IOP in patients with open-angle glaucoma or ocular hypertension outweigh the identified risks as demonstrated in the clinical studies submitted with this NDA application.
CDER Cross Discipline Team Leader Review Template
2
Version date: October 10, 2017 for all NDAs and BLAs
Reference ID: 4402232
Cross Discipline Team Leader Review and Deputy Division Director Review
Original NDA 208259 Rocklatan (netarsudil and latanoprost ophthalmic solution) 0.02%/0.005%
Dimension
Analysis of Condition
Benefit-Risk Dimensions
Evidence and Uncertainties
Glaucoma is a life-long progressive disease that is characterized by irreversible damage to the optic nerve and corresponding loss of visual field. One of the primary risk factors is elevated IOP.
Current Treatment
Options
Benefit
There are many ophthalmic drug products approved for lowering intraocular pressure in patients with open-angle glaucoma and ocular hypertension. These treatments include beta-adrenergic antagonists (beta blockers), alpha-adrenergic agonists, parasympathomimetic (miotic) agents, carbonic anhydrase inhibitors, rho kinase inhibitors and prostaglandin analogues.
Additional reduction in IOP can be achieved by administering products from different classes of IOP reducing products.
The adverse events previously identified in each of the individual components
can be expected to occur in the combination product. No additional adverse
Risk
reactions were identified in the clinical trials.
Conclusions and Reasons Intraocular pressure establishes a direct measure of the efficacy of ocular hypotensive medications.
Different classes of products lower intraocular pressure by either decreasing aqueous production or increasing aqueous outflow.
The combination product demonstrated greater IOP reduction than either of the individual components given alone. Labeling will identify the expected adverse reactions from each of components. Routine monitoring and reporting of all adverse events are expected to be adequate.
CDER Cross Discipline Team Leader Review Template
3
Version date: October 10, 2017 for all NDAs and BLAs
Reference ID: 4402232
Cross Discipline Team Leader Review and Deputy Division Director Review
Original NDA 208259 Rocklatan (netarsudil and latanoprost ophthalmic solution) 0.02%/0.005%
2. Background
Glaucoma is a life-long progressive disease that is characterized by irreversible damage to the optic nerve and corresponding loss of visual field. It affects one person in 200 over the age of 40. It is the leading cause of irreversible blindness in the United States. One of the primary risk factors is elevated IOP. The reduction and control of elevated IOP in open-angle glaucoma and ocular hypertension is usually managed by chronic, long-term topical ocular therapy.
There are many ophthalmic drug products approved for lowering intraocular pressure in patients with open-angle glaucoma and ocular hypertension. These treatments include beta-adrenergic antagonists (beta-blockers), alpha-adrenergic agonists, parasympathomimetic (miotic) agents, carbonic anhydrase inhibitors, rho kinase inhibitors and prostaglandin analogs.
Netarsudil ophthalmic solution, 0.2% was approved in the US in 2017 (Rhopressa). Latanoprost ophthalmic solution, 0.005% was approved in the US in 1996 (Xalatan).
Summary of Presubmission/Submission Regulatory Activity under IND 113064:
Type C Meeting to Discuss Clinical/Non-clinical plans EOP2 Clinical/Non-clinical Meeting EOP2 CMC Meeting Request for Preliminary Advice-Breakthrough Therapy Type C CMC meeting Pre-NDA Meeting
6/5/14 3/24/15 5/18/15 5/24/16 5/10/17 8/18/17
This is a 505(b)(2) application. In order to bridge the nonclinical program of netarsudil and latanoprost ophthalmic solution to that of Rhopressa (data owned by Aerie) and Xalatan, Aerie conducted a comparative rabbit ocular tissue distribution study, comparative 3-day ocular tolerability studies in rabbits and monkeys, and a 3-month repeat-dose ocular toxicity study with netarsudil/latanoprost ophthalmic solution in rabbits. The data from these studies provides an adequate bridge to the nonclinical program of Rhopressa and Xalatan.
Netarsudil and latanoprost ophthalmic solution, 0.02%/0.005% is not marketed in any other country.
3. Product Quality
Summarized from the Quality Assessment reviews dated 2/6/2019 (IQA#1) and 2/27/2019 (IQA#2):
Netarsudil and latanoprost ophthalmic solution, 0.02%/0.005% is sterile, preserved and packaged in a 4 mL multi-dose LDPE (b) (4) with (b) (4) tip and polypropylene screw cap. The fill volume is 2.5 mL.
CDER Cross Discipline Team Leader Review Template
4
Version date: October 10, 2017 for all NDAs and BLAs
Reference ID: 4402232
Cross Discipline Team Leader Review and Deputy Division Director Review
Original NDA 208259 Rocklatan (netarsudil and latanoprost ophthalmic solution) 0.02%/0.005%
Drug Substance(s) Latanoprost = Isopropyl-(Z)-7 [(1R,2R,3R,5S) 3,5- dihydroxy-2-[(3R)- 3- hydroxy-5 phenylpentyl] cyclopentyl]-5-heptenoate Netarsudil Mesylate = Benzoic acid, 2,4-dimethyl-, [4-[(1S)-1-(aminomethyl)-2-(6 isoquinolinylamino)-2-oxoethyl]phenyl]methyl ester, methanesulfonate (1:2)
The latanoprost drug substance specifications provided in
(b) (4) Type II DMF# : (b) (4)
Test Description* Identification
IR HPLC Specific Rotation (c=1 in acetonitrile, 20?C) Residue on Ignition / Sulphated Ash
Acceptance Criteria (b) (4) yellow
(b) (4) oil
Conform to reference IR spectrum Identical retention time as that of the reference standard
(b) (4)
NMT % (b) (4)
Water Content*
NMT % (b) (4)
Related Substances
(b) (4)
(b) (4)
NMT %
NMT %
NMT %
NMT
NMT %
NMT %
NMT %
Residual Solvents (GC)
(b) (4)
NMT (b) (4)ppm NMT ppm NMT ppm NMT ppm NMT (b) (4) ppm
CDER Cross Discipline Team Leader Review Template
5
Version date: October 10, 2017 for all NDAs and BLAs
Reference ID: 4402232
Cross Discipline Team Leader Review and Deputy Division Director Review
Original NDA 208259 Rocklatan (netarsudil and latanoprost ophthalmic solution) 0.02%/0.005%
---rrest
--
Acceptance Crite1?ia
(b) (4)
NMT ,(b}\4J oom
NMT oom
NMT DOm
NMT nom
NMT DOm
ILimit of CbH4~ (GC) k C4> NMT Cb> C41
Analytical Procedm?e Visual (ADOl 7 TST) FTIR (USP ; AD002 TST) HPLC (AD130 TST)
HPLC (AD130 TST) HPLC (AD130 TST)
HPLC (AD072 TST) IC (AD12 1 TST) GC (AD082 TST)
Residual Solvents (pp..!!Y.1
(b)(4Y
Water Content (% w/w)
Elemental Impurities (?~g)1 .
(b)(4l
~(b)(4l
NMT NMT NMT NMT NMT NMTQ:41~
-
NMT
(b)(4J
NMT
NMT
NMT
NMT
NMT
GC-HS (AD 137 TST, ICblT~ TST4)
GC (AD142 TST4) Karl Fischer (USP ; AD004 TST) ICP-MS (USP , AD077 TST)
CDER Cross Disci pline Team Leader Review Tem plate
6
Version date: October 10, 2017for all NDAs and BLAs
Reference ID 4402232
Cross Discipline Team Leader Review and Deputy Division Director Review
Original NDA 208259 Rocklatan (netarsudil and latanoprost ophthalmic solution) 0.02%/0.005%
Test
Acceptance Criteria
Analytical Procedm?e
Microbial Bioburden Test
Total Aerobic Count Total Yeasts & Mold Count Absence ofobjectionable organisms5
NMT~1(4b1l CFUl~ .Mi mg NMUCib1
CPU 0(b0~: meer Absent
Microbiological Examination (USP , ; AD050 TS1)
NMT = Not More Than; CPU = Colony Fonning Units
I.
Tested only at release.
2.
Structures and names ofimpurities are provided in Section 3.2.S.3.2.
3.
Total Imi:mrities includes all impurities observed at or above ltif ................
................
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