Summary Basis of Decision for Veklury

Summary Basis of Decision (SBD) documents provide information related to the original authorization of a product. The SBD for Veklury is located below.

Recent Activity for Veklury

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 Veklury

Updated: 2024-03-22

The following table describes post-authorization activity for Veklury, a product which contains the medicinal ingredient remdesivir. 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 found in Post-Authorization Activity Tables (PAATs).

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

Drug Identification Number (DIN):

  • DIN 02502143 - 100 mg remdesivir/vial, powder for solution, intravenous administration
  • DIN 02502135 - 100 mg remdesivir/20 mL (5 mg/mL), solution, intravenous administration

Post-Authorization Activity Table (PAAT)

Activity/submission type, control number Date submitted Decision and date Summary of activities
SNDS # 275995 2023-06-05 Issued NOC 2024-02-06 Submission filed as a Level I – Supplement to add alternate manufacturing sites for the production of the drug product and an alternative rubber stopper. The information was reviewed and considered acceptable. An NOC was issued.
SNDS-C # 270659 2022-12-15 Issued NOC under NOC/c Guidance 2023-11-17 Submission filed as a Level I – Supplement in response to commitments made as per the provisions of the Guidance Document: Notice of Compliance with Conditions (NOC/c). The submission provided data for study GS-US-540-9015. The information was reviewed and considered acceptable. An NOC was issued under the NOC/c Guidance.
SNDS # 266313 2022-08-02 Issued NOC 2023-06-15 Submission filed as a Level I – Supplement for a new indication. The indication authorized was: the treatment of coronavirus disease 2019 (COVID-19) in pediatric patients at least 4 weeks of age and weighing at least 3 kg to less than 40 kg with pneumonia requiring supplemental oxygen (hospitalized pediatric patients) and pediatric patients weighing at least 40 kg who are at high risk for progression to severe COVID-19, including hospitalization or death (non-hospitalized pediatric patients). The submission was reviewed and considered acceptable, and an NOC was issued. A Regulatory Decision Summary was published.
PSUR # 269953 2023-01-13 Review completed 2023-06-01 Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. PSUR #5 for the period 2022-05-07 to 2022-11-06. The current post-market safety data are consistent with the labelled safety profile of Veklury. Health Canada will continue to monitor any new emerging evidence from all available sources as part of its post-authorization monitoring for Veklury.
PSUR # 242336 2022-07-21 Review completed
2022-11-23

Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. PSUR #4 for the period 2021-11-07 to 2022-05-06. The current post-market safety data are consistent with the labelled safety profile of Veklury. Health Canada will continue to monitor any new emerging evidence from all available sources as part of its post-authorization monitoring for Veklury.

SNDS-C # 252849 2021-05-19 Issued NOC under NOC/c Guidance
2022-10-14

Submission filed as a Level I – Supplement in response to quality-specific commitments made as per the provisions of the NOC/c Guidance. The information was reviewed and considered acceptable. An NOC was issued under the NOC/c Guidance.

PSUR # 242334 2022-01-27 Review completed
2022-05-06
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. PSUR #3 for the period 2021-05-07 to 2021-11-06. The current post-market safety data are consistent with the labelled safety profile of Veklury. Health Canada will continue to monitor any new emerging evidence from all available sources as part of its post-authorization monitoring for Veklury.
SNDS # 250151 2021-03-05 Issued NOC
2022-04-22
Submission filed as a Level I – Supplement to add a new indication for Veklury. The indication authorized was for use in non-hospitalized adults with positive results of direct severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) viral testing, and who are at high risk for progression to severe COVID-19, including hospitalization or death. A Regulatory Decision Summary was published.
Safety review
Control # 259111
2021-12-21 Review completed
2022-02-18
Health Canada's review concluded that Veklury is expected to maintain effectiveness against the Omicron SARS-CoV-2 variant based on the data available at this time and no Product Monograph updates are necessary at this time.
SNDS-C # 248928 2021-01-29 Issued NOC
2022-01-24
Submission filed as a Level I – Supplement in response to commitments made as per the provisions of the NOC/c Guidance. The submission provided data for the following studies: CO-US-540-5776, GS-US-540-5773, GS-US-5774, and GS-US-540-5758. Based on the data submitted, the benefit-harm-uncertainty profile of Veklury remains favourable when used as directed in the Product Monograph and an NOC was issued. The conditions related to the submission of confirmatory Phase III clinical trial evidence are considered to be met.
PSUR # 242333 2021-07-27 Review completed
2021-11-25
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. PSUR #2 for the period 2020-11-07 to 2021-05-06. The current post-market safety data are consistent with the labelled safety profile of Veklury. Health Canada will continue to monitor any new emerging evidence from all available sources as part of its post-authorization monitoring for Veklury.
SNDS # 254319 2021-06-30 Issued NOC
2021-11-23
Submission filed as a Level II – Supplement (Safety) to update the Product Monograph (PM) with new information regarding anaphylactic reaction and hypersensitivity, and to update the PM to the new template. As a result of the SNDS, additions were made to the Warnings and Precautions and Adverse Reactions sections of the PM and Part III: Patient Medication Information. An NOC was issued.
Risk Management Plan update
Control # 257313
2021-11-05 Review completed
2021-11-22
The updated Canadian Addendum (version 3.0) to the Risk Management Plan (RMP) was filed as requested by Health Canada. The review found that this document is acceptable.
Risk Management Plan update
Control # 251662
2021-06-14 Review completed
2021-09-29
The updated European Union (EU) Risk Management Plan (RMP) version 2.0 and Canadian Addendum were filed as requested by Health Canada. The review of the updated EU RMP in conjunction with the Canadian Addendum found that these documents are acceptable with revisions that were requested to be addressed by the sponsor within 30 days.
Summary Safety Review posted Not applicable Posted
2021-08-18

Summary Safety Review posted for Veklury (remdesivir), assessing the potential risk of sinus bradycardia. Health Canada’s review concluded that a link between the use of Veklury and the risk of sinus bradycardia is possible. Health Canada will work with the sponsor to update the Product Monograph.

SNDS # 250729 2021-03-22 Issued NOC
2021-08-12

Submission filed as a Level I – Supplement to update the Product Monograph for Veklury to add laboratory abnormality information regarding increased prothrombin time/International Normalized Ratio (PT/INR). As a result of the submission, the Dosage and Administration, Adverse Reactions, and Patient Medication Information sections of the Product Monograph were updated. The benefit/risk profile for Veklury remains positive when used for its approved indication.

Safety review
Control # 249357
Not applicable Review completed
2021-07-13

Health Canada’s review concluded that there is currently some evidence supporting a causal association between Veklury and sinus bradycardia. Health Canada will work with the sponsor to update the Product Monograph.

Expedited summary safety report
Control # 252344
2021-04-30 Filed
2021-06-15
Submission filed in response to a Health Canada request and provided an expedited summary safety report for the period 2021-01-01 to 2021-03-31. The current post-market safety data are consistent with the labelled safety profile of Veklury. Health Canada will continue to monitor any new emerging evidence from all available sources as part of its post-authorization monitoring for Veklury.
DIN 02502135 cancelled (pre-market) Not applicable Discontinuation date:
2021-04-13
The manufacturer notified Health Canada that sale of the drug has been discontinued pre-market. Health Canada cancelled the DIN pursuant to section C.01.014.6(1)(a) of the Food and Drug Regulations. DIN 02502143 remains active.
Summary Safety Review posted Not applicable Posted
2021-04-09
Summary Safety Review posted for Veklury (remdesivir), assessing the potential risks of acute kidney injury (AKI) and acute renal failure (ARF). Health Canada's review could not establish a direct link between the use of Veklury and the risk of AKI/ARF. The safety information for Veklury is appropriate at this time.
PSUR # 242337 2021-01-15 Filed
2021-04-07
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. PSUR #1 for the period 2020-05-07 to 2020-11-06. The current post-market safety data are consistent with the labelled safety profile of Veklury. Health Canada will continue to monitor any new emerging evidence from all available sources as part of its post-authorization monitoring for Veklury.
SNDS # 247779 2020-12-23 Issued NOC under NOC/c Guidance
2021-03-02
Submission filed as a Level I - Supplement to add an alternate manufacturing site for the production of the remdesivir drug substance. There were no changes to the manufacturing process for the drug substance. The information was reviewed and considered acceptable. An NOC was issued under the NOC/c Guidance.
Monthly safety report
Control # 248787
2021-01-27 Review completed
2021-02-19
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. Monthly safety report #6 for the period 2020-11-02 to 2020-12-31. Additional information has been requested from the manufacturer following international cases of sinus bradycardia (slow heart rate less than 60 bpm). Health Canada will review this information when provided. The current post-market safety data are consistent with the labelled safety profile of Veklury.
Safety review
Control # 244656
Not applicable Review completed
2021-02-11
Health Canada's review concluded that the evidence does not suggest any additional concern or new safety characteristic regarding Veklury and acute kidney injury. The safety information for Veklury available in the Product Monograph is appropriate at this time to mitigate the risk. Health Canada will continue to monitor any new emerging evidence from all available sources as part of its post-authorization monitoring for Veklury.
Monthly safety report Control # 247955 2020-12-24 Review completed
2021-01-17
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. Monthly safety report #5 for the period 2020-11-02 to 2020-11-30. The current post-market safety data are consistent with the labelled safety profile of Veklury.
Monthly safety report Control # 245540 2020-11-19 Review completed
2020-12-16
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. Monthly safety report #4 for the period 2020-10-02 to 2020-11-01. The current post-market safety data are consistent with the labelled safety profile of Veklury.
Monthly safety report Control # 245911 2020-10-28 Review completed
2020-11-19
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. Monthly safety report #3 for the period 2020-09-03 to 2020-10-02. The current post-market safety data are consistent with the labelled safety profile of Veklury.
Monthly safety report Control # 244559 2020-09-29 Review completed
2020-10-25
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. Monthly safety report #2 for the period 2020-08-04 to 2020-09-02. The current post-market safety data are consistent with the labelled safety profile of Veklury.
New safety review started by Health Canada Not applicable Started between
2020-10-01
Health Canada started a safety review for Veklury in response to international reports of acute kidney injury.
Monthly safety report Control # 243244 2020-08-21 Review completed
2020-09-22
Submission filed in response to commitments made as per the provisions of the NOC/c Guidance. Monthly safety report #1 for the period 2020-07-05 to 2020-08-03. The current post-market safety data are consistent with the labelled safety profile of Veklury.
Drug product (DIN 02502143) market notification Not applicable Date of first sale:
2020-10-16
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 Letter posted Not applicable Posted
2020-09-15
Dear Healthcare Professional Letter posted (Importation of US Clinical Trial-Labelled Remdesivir for Injection Due to Shortage of Canadian-Labelled Remdesivir), containing product safety, supply, and important safety information for healthcare professionals and hospitals.
Advisory posted Not applicable Posted
2020-07-28
Advisory posted (Remdesivir authorized with conditions for the treatment of patients in Canada with severe COVID-19 symptoms), containing a product label update for healthcare professionals, hospitals, and the general public.
NDS # 240551 2020-06-19 Issued NOC under NOC/c Guidance
2020-07-27
NOC issued under the NOC/c Guidance for New Drug Submission.
Summary Basis of Decision (SBD) for Veklury

Date SBD issued: 2020-08-19

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

Remdesivir

Drug Identification Number (DIN):

  • DIN 02502143 - 100 mg/vial, powder for solution, intravenous administration
  • DIN 02502135 - 100 mg/20 mL (5 mg/mL), solution, intravenous administration

Gilead Sciences Canada Inc.

New Drug Submission Control Number: 240551

 

On July 27, 2020, Health Canada issued a Notice of Compliance under the Notice of Compliance with Conditions (NOC/c) Guidance to Gilead Sciences Canada, Inc. for the drug product Veklury. The product was authorized under the NOC/c Guidance, pending the results of trials to verify its clinical benefit. Patients should be advised of the fact that the market authorization was issued with conditions.

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 Veklury is favourable for the treatment of coronavirus disease 2019 (COVID-19) in adults and adolescents (aged 12 years and older with body weight at least 40 kg) with pneumonia requiring supplemental oxygen.

1 What was approved?

Veklury (remdesivir), a nucleotide prodrug, was authorized for the treatment of coronavirus disease 2019 (COVID-19) in adults and adolescents (aged 12 years and older with body weight at least 40 kg) with pneumonia requiring supplemental oxygen.

The safety and efficacy of Veklury in children younger than 12 years of age and weighing less than 40 kg have not been established. Therefore, Health Canada has not authorized an indication in this population.

Reported clinical experience has not identified differences in response between the elderly (over 65 years of age) and younger patients.

Veklury 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.

Veklury 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.

Veklury (remdesivir 100 mg/vial and 100 mg/20 mL [5 mg/mL]) is presented in two dosage forms, a powder for solution and a solution. In addition to the medicinal ingredient, both dosage forms contain betadex sulfobutyl ether sodium, hydrochloric acid, and sodium hydroxide. Water for injections is an additional non-medicinal component in the solution.

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

2 Why was Veklury approved?

Health Canada considers that the benefit-harm-uncertainty profile of Veklury is favourable for the treatment of coronavirus disease 2019 (COVID-19) in adults and adolescents (aged 12 years and older with body weight at least 40 kg) with pneumonia requiring supplemental oxygen. Veklury was authorized under the Notice of Compliance with Conditions (NOC/c) Guidance, pending the results of trials to verify its clinical benefit.

In December 2019, health authorities in Wuhan, China, reported an outbreak of viral pneumonia of unknown cause. A novel coronavirus ribonucleic acid (RNA) was detected in some of these patients. This novel coronavirus has been named "severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2)". The new human infectious disease caused by SARS-CoV-2 has been designated as "coronavirus disease 2019 (COVID-19)".

Coronaviruses are a group of highly diverse, enveloped, positive-sense, single-stranded RNA viruses. Currently, there are seven strains of coronaviruses known to infect humans: human coronavirus 229E (HCoV-229E), OC43 (HCoV-OC43), NL63 (HCoV-NL63), HKU1 (HCoV-HKU1), severe acute respiratory syndrome coronavirus (SARS-CoV), Middle East respiratory syndrome coronavirus (MERS-CoV), and SARS-CoV-2.

The diagnosis of COVID-19 can be established on the basis of a suggestive clinical history and the detection of SARS-CoV-2 RNA in respiratory secretions. In most cases (approximately 80%), COVID-19 presents as a mild to moderately severe, self-limited acute respiratory illness with fever, chills, cough, and shortness of breath. Approximately 15% of patients with COVID-19 develop severe disease that requires oxygen support, and 5% have critical disease with complications such as respiratory failure, acute respiratory distress syndrome, sepsis and septic shock, thromboembolism, and/or multi-organ failure, including acute kidney injury and cardiac injury. As of July 27, 2020, there were 16,636,008 confirmed cases and 656,914 deaths worldwide, including 114,597 confirmed cases and 8,901 deaths in Canada.

There is currently no vaccine to prevent infection with SARS-CoV-2 and no antiviral drug to treat COVID-19. Supportive therapies include supplemental oxygen, ventilation, treatment with convalescent serum and anti-inflammatory therapies with low dose glucocorticoids to combat the cytokine storm. Dexamethasone, which has anti-cytokine activity, has recently been reported to reduce mortality in patients with severe COVID-19, however, these results are preliminary.

Remdesivir, the medicinal ingredient in Veklury, is an adenosine nucleotide prodrug. It is metabolized within host cells to form the pharmacologically active nucleoside triphosphate metabolite. Remdesivir triphosphate acts as an analog of adenosine triphosphate (ATP) and competes with the natural ATP substrate for incorporation into nascent RNA chains by the SARS-CoV-2 RNA-dependent RNA polymerase, which results in delayed chain termination during replication of the viral RNA.

The market authorization of Veklury is supported primarily by the safety and efficacy data from the interim analysis of a pivotal, randomized, double-blind, placebo-controlled clinical study NIAID ACTT-1 (CO-US-540-5776). There is additional evidence from two open-label SIMPLE-studies (GS-US-540-5773 in patients with severe COVID-19 and GS-US-540-5774 in patients with moderate COVID-19), the placebo-controlled GS-US-540-5758 study in patients with severe COVID-19, and compassionate use of remdesivir.

The NIAID ACTT-1 study evaluated Veklury 200 mg once daily for 1 day followed by Veklury 100 mg once daily for up to 9 days (for a total of up to 10 days of intravenously administered therapy) in hospitalized adult patients with COVID-19 with evidence of lower respiratory tract involvement. The trial enrolled 1,063 hospitalized patients: 120 (11.3%) patients with mild/moderate disease (defined by oxygen saturation [SpO2] >94% and respiratory rate <24 breaths/min without supplemental oxygen) and 943 (88.7%) patients with severe disease (defined by SpO2 ≤94% on room air or respiratory rate ≥24 breaths/min and requiring supplemental oxygen or ventilatory support). Patients were randomized in a ratio of 1:1 to receive Veklury (number of patients [n] = 541) or placebo (n = 522), plus standard of care. Randomization was stratified by study site and disease severity at enrolment.

The primary clinical endpoint was time to recovery within 28 days after randomization, defined as either discharged from hospital (with or without limitations of activity and with or without home oxygen requirements) or hospitalized but not requiring supplemental oxygen and no longer requiring ongoing medical care. Based on the interim analysis performed after all patients had been followed up for 14 days, the median time to recovery in the overall population was 11 days in the Veklury group compared to 15 days in the placebo group (recovery rate ratio 1.32 [95% confidence interval [CI] 1.12 to 1.55], p<0.001).

The outcome differed between the two baseline strata (mild to moderate disease and severe disease). Time to recovery was similar between the two treatment groups in patients with mild to moderate disease at baseline, whereas in the severe disease stratum, time to recovery was 12 days in the Veklury group and 18 days in the placebo group (recovery rate ratio 1.37 [95% CI 1.15 to 1.63]). The clinical benefit of Veklury was limited to patients with pneumonia who were receiving oxygen at baseline (recovery rate ratio 1.47 [95% CI 1.17 to 1.84]). Veklury did not reduce the time to recovery in patients who were receiving mechanical ventilation or extracorporeal membrane oxygenation at baseline (recovery rate ratio 0.95 [95% CI 0.64 to 1.42]. There was no difference in efficacy in patients randomized during the first 10 days after the onset of symptoms as compared to those with symptoms for more than 10 days. Mortality was numerically lower in the Veklury group than in the placebo group, however, the difference was not statistically significant (hazard ratio for death 0.70 [95% CI 0.47 to 1.04], based on 1,059 patients). The data for the key secondary endpoint, day 28 mortality, were not available at the time of the review.

The placebo-controlled GS-US-540-5758 trial was terminated early due to low patient enrollment. This study failed to show efficacy of Veklury with respect to time to clinical improvement and mortality at day 28.

The ongoing SIMPLE-severe and SIMPLE-moderate studies have important deficiencies in design, such as the lack of blinding in both studies and the lack of a placebo arm in the SIMPLE-severe study. The SIMPLE-severe study showed no difference in clinical status at day 14 between Veklury administered for 5 days and Veklury administered for 10 days.

Adolescents (12 years of age and older and weighing at least 40 kg) were not included in the clinical trials with Veklury. The indication for this group of patients is supported by a physiologically based pharmacokinetic modelling study that predicted similar disposition of remdesivir and its metabolites in adolescents as compared to adults.

A clinical proof-of-concept for the antiviral activity of remdesivir has not been demonstrated. The GS-US-540-5758 study investigated levels of SARS-CoV-2 RNA in nasopharyngeal swabs as an additional endpoint. Among the limited number of patients tested, no change in viral RNA levels was noted in the Veklury treatment arm.

Veklury was generally well tolerated across the clinical trials in patients with COVID-19. The most common adverse reactions were increased transaminases, nausea, headache, and rash. Other adverse reactions included infusion-related reactions and hypersensitivity reactions. In the NIAID ACTT-1 study, no increase in serious adverse events or discontinuations due to an adverse event were reported for Veklury as compared to placebo.

No dedicated clinical studies have been conducted in patients with hepatic or renal impairment. The Veklury Product Monograph recommends that both liver and renal functions should be determined in all patients prior to treatment with Veklury and monitored during treatment as clinically appropriate. Veklury should only be used in patients with hepatic impairment if the potential benefit outweighs the potential risk. Veklury should not be used in patients with estimated glomerular filtration rate lower than 30 mL/min.

There are no data for the use of Veklury in pregnant women. Animal studies are insufficient with respect to reproductive toxicity. Therefore, the Veklury Product Monograph recommends that Veklury should not be used during pregnancy unless the potential clinical benefit outweighs the risk to the mother and the fetus. Women of childbearing potential are advised to use effective contraception during treatment. In addition, given the potential for viral transmission to SARS-CoV-2-negative infants and adverse reactions from the drug in breastfeeding infants, the Veklury Product Monograph recommends that a decision to discontinue breastfeeding or to discontinue/abstain from Veklury therapy must be made taking into account the benefit of breastfeeding for the child and the benefit of therapy for the woman.

No clinical drug-drug interactions studies were conducted with Veklury, therefore, the overall potential for interactions between Veklury and concomitantly administered drugs is currently unknown. Accordingly, the Veklury Product Monograph recommends that patients should remain under close observation during Veklury treatment. Furthermore, based on an antagonism observed in vitro, the concomitant use of Veklury with chloroquine phosphate or hydroxychloroquine sulphate is not recommended.

A Risk Management Plan (RMP) for Veklury was submitted by Gilead Sciences Canada, Inc. to Health Canada. Upon review, the RMP was considered to be acceptable. The RMP is designed to describe known and potential safety issues, to present the monitoring scheme and when needed, to describe measures that will be put in place to minimize risks associated with the product.

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

Overall, the efficacy and safety of Veklury in the treatment of COVID-19 have not been fully characterized at this time because the available clinical trial data are not comprehensive (see Clinical Basis for Decision). Specifically, no clinical study report was available for any of the COVID-19 clinical trials and the data submitted were limited to study protocols and preliminary or topline results. However, given the unmet need for treatment of patients with COVID-19 and the public health emergency context of the COVID-19 pandemic, Health Canada considers the balance of benefit and harm for Veklury to be positive. A Notice of Compliance under the Notice of Compliance with Conditions (NOC/c) Guidance has been issued for the indication in the treatment of COVID-19 in adults and adolescents (aged 12 years and older with body weight at least 40 kg) with pneumonia requiring supplemental oxygen. The data provided in the submission have not established the efficacy of Veklury in patients with moderate COVID-19 and therefore, Veklury is not indicated in these patients.

The identified safety issues can be managed through labelling and adequate monitoring. Appropriate warnings and precautions are in place in the Veklury Product Monograph to address the identified safety concerns. As described within the framework of the Notice of Compliance with Conditions (NOC/c) Guidance, safety monitoring of the use of Veklury will be ongoing. Some uncertainty remains regarding the ability of the manufacturing processes and control strategy to consistently produce a drug substance and drug product of suitable quality for the intended use, and additional information is needed. Further assessment will be conducted by Health Canada upon submission of the additional efficacy, safety, and quality data requested from the sponsor as part of the conditions under the Notice of Compliance with Conditions (NOC/c) Guidance.

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 Veklury?

The New Drug Submission (NDS) for Veklury underwent an expedited review by Health Canada due to the exceptional circumstances of an unmet medical need and emergency context of the coronavirus disease 2019 (COVID-19) pandemic.

A Notice of Compliance with Conditions - Qualifying Notice (NOC/c-QN) was issued on July 24, 2020. The review of the sponsor's Letter of Undertaking led to the decision to issue the sponsor market authorization for Veklury under the Notice of Compliance with Conditions (NOC/c) Guidance, pending the results of trials to verify its clinical benefit.

 

Submission Milestones: Veklury

Submission Milestone Date
Pre-submission meeting 2020-06-12
Submission filed 2020-06-19
Screening  
Screening Acceptance Letter issued 2020-07-21
Review  
Review of Risk Management Plan complete 2020-07-21
Quality Evaluation complete 2020-07-22
Clinical/Medical Evaluation complete 2020-07-22
Labelling Review complete, including Look-alike Sound-alike brand name assessment 2020-07-23
Notice of Compliance with Conditions - Qualifying Notice (NOC/c-QN) issued 2020-07-24
Review of Response to NOC/c-QN:  
Response filed (Letter of Undertaking) 2020-07-24
Quality Evaluation complete 2020-07-24
Clinical/Medical Evaluation complete 2020-07-25
Notice of Compliance (NOC) issued by Director General, Therapeutic Products Directorate under the Notice of Compliance with Conditions (NOC/c) Guidance 2020-07-27

The Canadian regulatory decision on the review of Veklury was based on a critical assessment of the data package submitted to Health Canada. The foreign review completed by the European Medicines Agency (EMA) was used as an 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?

In addition to requirements outlined in the Food and Drugs Act and Regulations, and in keeping with the provisions outlined in the Notice of Compliance with Conditions (NOC/c) Guidance, the commitments agreed upon by the sponsor include (but are not limited to) the following:

  • To confirm the safety and efficacy of Veklury in the treatment of coronavirus disease 2019 (COVID-19), the sponsor will provide the final clinical study reports from studies CO-US-540-5776 (NIAID ACTT-1), GS-US-540-5773 (SIMPLE-severe), and GS-US-540-5774 (SIMPLE-moderate) as well as the Integrated Summary of Safety and clinical study reports from studies in hepatic and renal impairment.
     
  • The sponsor will provide reports of post-market safety monitoring activities, including:
     
    • monthly safety reports until the time of submission of the first Periodic Benefit-Risk Evaluation Report (PBRER) or Periodic Safety Update Report (PSUR);
    • reports of all serious adverse drug reactions that occurred in Canada and all serious unexpected adverse drug reactions that occurred outside of Canada;
    • a pregnancy safety report from the compassionate use (IN-US-540-5755) and expanded access program (GS-US-540-5821) within the first PSUR. Subsequent pregnancy data will be presented in future PSURs;
    • PBRERs or PSURs every 6 months for the first 2 years of marketing following authorization in Canada; and
    • any foreign regulatory actions related to the safety of remdesivir (the medicinal ingredient in Veklury).
       
  • The sponsor will address the quality-related comments and provide additional quality data related to, but not limited to, the drug substance and drug product manufacturing information and controls.
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

Limited clinical pharmacology data are available for remdesivir, the medicinal ingredient in Veklury.

The pharmacokinetic properties of remdesivir have only been studied in healthy adult volunteers. Pharmacokinetic data of remdesivir in adult and pediatric patients with coronavirus disease 2019 (COVID-19) are not available.

Following intravenous administration over 30 min, peak plasma concentrations of remdesivir were observed at the end of infusion and declined rapidly thereafter with a half-life of approximately 1 hour.

Remdesivir undergoes rapid hydrolysis by esterases resulting in the formation of the intermediate metabolite GS-704277. Phosphoramidate cleavage followed by phosphorylation forms the active triphosphate GS-443902. Dephosphorylation of all phosphorylated metabolites can result in the formation of nucleoside metabolite GS-441524 that itself is not efficiently re-phosphorylated. Additionally, the human mass balance study indicates presence of a currently unidentified major and possible human-specific metabolite (M27) in plasma.

Following administration of [14C]-remdesivir, over 92% of the dose was recovered, consisting of approximately 74% in urine and 18% in feces. The majority of the dose recovered in urine was GS-441524 (48.6%), while 10.3% was recovered as remdesivir. These data indicate that renal clearance is the major elimination pathway for GS-441524. The median terminal half-lives of remdesivir, GS-704277, and GS-441524 were approximately 1, approximately 1.3, and 27 hours, respectively.

The effect of intrinsic factors, including the effect of renal and hepatic impairment on the pharmacokinetics of remdesivir, has not been examined. Intra- and inter-subject variability has also not been studied.

In order to define the dosing recommendation for Remdesivir in adolescent patients (12 years of age and older weighing at least 40 kg), the sponsor developed a physiologically based pharmacokinetic model to characterize the pharmacokinetics of remdesivir and the primary circulating nucleoside metabolite, GS-441524, in adults. This model was applied to predict pediatric patient exposure, accounting for age-dependent changes in organ volume or size, enzyme expression, plasma protein binding, blood cell distribution, and organ blood flow. The model predicts that for pediatric patients weighing at least 40 kg, the proposed adult dosage regimen (one loading dose of remdesivir 200 mg intravenously infused over 30 min on day 1, followed by remdesivir 100 mg intravenously infused over 30 min once daily for 9 days) will provide exposures of remdesivir and GS-441524 similar to those observed in healthy adult volunteers.

Drug-drug interaction studies of remdesivir and other concomitantly administered drugs have not been conducted in humans.

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

Clinical Efficacy and Safety

The efficacy and safety of Veklury in the treatment of COVID-19 have not been fully characterized at this time because the available clinical trial data are not comprehensive. No clinical study report was available to Health Canada for any of the clinical trials conducted in COVID-19 patients and the data provided were limited to study protocols and preliminary or topline results.

Additional efficacy and safety data will be assessed when the requested studies are submitted, as part of the conditions under the Notice of Compliance with Conditions (NOC/c) Guidance.

Clinical Efficacy

The efficacy of Veklury in the treatment of COVID-19 is supported primarily by the ongoing, pivotal, Phase III, randomized, double-blind, placebo-controlled, multicentre study (NIAID ACTT-1). In order to expedite the regulatory approval of Veklury, an interim analysis of data from the published study was accepted for review by Health Canada. The complete study report is expected to be available before the end of 2020.

Additional clinical evidence is from the following supportive trials: two open-label SIMPLE-studies, GS-US-540-5773 in patients with severe COVID-19 and GS-US-540-5774 in patients with moderate COVID-19, and the placebo-controlled study GS-US-540-5758 in patients with severe COVID-19.

Study NIAID ACTT-1 (CO-US-540-5776)

The pivotal, Phase III study NIAID ACTT-1 was conducted in hospitalized adult patients with laboratory-confirmed severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) infection and evidence of lower respiratory tract involvement.

The study enrolled 1,063 hospitalized patients: 120 (11.3%) patients with mild/moderate disease (defined by oxygen saturation [SpO2] >94% and respiratory rate <24 breaths/min without supplemental oxygen) and 943 (88.7%) patients with severe disease (defined by SpO2 ≤94% on room air or respiratory rate ≥24 breaths/min and requiring supplemental oxygen or ventilatory support). Patients were randomized in a ratio of 1:1 to receive Veklury (number of patients [n] = 541) or placebo (n = 522), plus standard of care. Randomization was stratified by study site and disease severity at enrolment. Veklury was administered intravenously at a dose of 200 mg on day 1 and at a dose of 100 mg once daily for up to 9 additional days. Approximately 33% (180/541) of the patients received a 10-day course of treatment with Veklury.

The primary clinical endpoint was time to recovery within 28 days after randomization, defined as either discharged from hospital (with or without limitations of activity and with or without home oxygen requirements) or hospitalized but not requiring supplemental oxygen and no longer requiring ongoing medical care. Based on an analysis performed after all patients had been followed up for 14 days, the median time to recovery in the overall population was 11 days in the Veklury group compared to 15 days in the placebo group (recovery rate ratio 1.32 [95% confidence interval [CI] 1.12 to 1.55], p<0.001).

The outcome differed between the two disease strata (mild to moderate disease at baseline and severe disease at baseline). Time to recovery was similar between the two treatment groups in patients with mild to moderate disease at baseline, whereas in the severe disease stratum, time to recovery was 12 days in the Veklury group and 18 days in the placebo group (recovery rate ratio 1.37 [95% CI 1.15 to 1.63]). The clinical benefit of Veklury was limited to patients with pneumonia who were receiving oxygen at baseline (recovery rate ratio 1.47 [95% CI 1.17 to 1.84]). Veklury did not reduce the time to recovery in patients who were receiving mechanical ventilation or extracorporeal membrane oxygenation at baseline (recovery rate ratio 0.95 [95% CI 0.64 to 1.42]). There was no difference in efficacy in patients randomized during the first 10 days after the onset of symptoms as compared to those with symptoms for more than 10 days. Mortality was numerically lower in the Veklury group than in the placebo group, however, the difference was not statistically significant (hazard ratio for death 0.70 [95% CI 0.47 to 1.04], based on 1,059 patients).

Viral loads were not quantified during the study. A demonstrated correlation between clinical improvement and decreased viral loads would provide definitive evidence about the antiviral activity of Veklury against SARS-CoV-2.

The submission contained incomplete information about the comorbidities of study participants and no information about concomitant medications. Therefore, it is unknown whether potential imbalances in comorbidities or differences in the medications used as standard of care (e.g., corticosteroids) between the two treatment groups may have had an impact on the outcomes during the study.

Study GS-US-540-5758

The GS-US-540-5758 study was an investigator-initiated, Phase III, randomized, placebo-controlled, double-blind trial performed at ten hospitals in Wuhan, China, in patients with severe COVID-19. Patients were randomly assigned (2:1) to receive either Veklury or placebo. Patients in the Veklury group received the drug for up to 10 days. This study was terminated early due to low enrollment of patients and therefore, it was underpowered.

The primary clinical endpoint was time to clinical improvement within 28 days after randomization. The time to clinical improvement in the Veklury group was not significantly different to that of the placebo group. The median time to clinical improvement was 21 days (interquartile range [IQR] 13.0 to 28.0) in the Veklury group vs. 23 days (IQR 15.0 to 28.0) in the placebo group; hazard ratio (HR) 1.23 (95% CI 0.87 to 1.75). The day 28 all-cause mortality was similar between the two groups, i.e., 22 (14%) patients died in the Veklury group vs. 10 (13%) patients in the placebo group; difference 1.1% (95% CI -8.1 to 10.3).

Study GS-US-540-5773 (SIMPLE-severe)

The SIMPLE-severe study is an ongoing Phase III, randomized, open-label, multicentre trial in patients with severe COVID-19 to evaluate the safety and efficacy of Veklury administered for 5 or 10 days. Veklury was administered intravenously at a dose of 200 mg on day 1 followed by 100 mg on subsequent days, for a scheduled course of 5 or 10 days depending on the study group. The most severely ill patients, i.e., patients on mechanical ventilation, were excluded from this study. Only results from an interim analysis from this study were available for review.

The primary endpoint was clinical outcome at day 14. After adjusting for baseline clinical status, participants receiving a 10-day course of Veklury had a similar distribution in clinical status at day 14 as those receiving a 5-day course of Veklury. In addition, day 14 mortality was numerically lower in the 5-day group vs. the 10-day group (8% vs. 11%).

Study GS-US-540-5774 (SIMPLE-moderate)

The SIMPLE-moderate study is an ongoing Phase III, randomized, open-label, multicentre study in patients with moderate COVID-19 to evaluate the safety and efficacy of Veklury administered for 5 or 10 days. Veklury was administered intravenously at a dose of 200 mg on day 1 followed by 100 mg on subsequent days, for a scheduled course of 5 or 10 days depending on the study arm. The control arm received standard of care alone. Only results from an interim analysis from this study were available for review.

The primary efficacy endpoint was clinical status assessed by a 7-point ordinal scale on day 11. A statistically significant improvement in clinical status at day 11 for participants receiving a 5-day course of Veklury compared with those receiving standard of care alone was found (odds ratio 1.65 [95% CI 1.09 to 2.48], p = 0.017) based on the Last Observation Carried Forward (LOCF)-analysis. Based on the Observed Cases (OC)-analysis, as prespecified in the protocol, no difference was seen for either Veklury groups compared to standard of care. Data concerning the length of the hospital stay do not indicate a positive effect of Veklury (5-day course: 8 days, 10-day course: 8 days, standard of care: 7 days). For other efficacy endpoints of interest, at day 11, improvements of two or more points in the clinical ordinal scale were reported in 70.2% of participants who received a 5-day course of Veklury and 65.3% of participants who received a 10-day course of Veklury compared with 60.5% of those who received standard of care alone. Clinical recovery at day 11 was achieved in a numerically greater proportion of patients in the 5-day Veklury group (73.8%) than the 10-day Veklury group (68.4%) and the standard-of-care group (64.0%).

Indication

Only minor editorial changes were made to the initially proposed indication of Veklury. Health Canada approved the following indication:

  • Veklury (remdesivir) is indicated for the treatment of coronavirus disease 2019 (COVID-19) in adults and adolescents (aged 12 years and older with body weight at least 40 kg) with pneumonia requiring supplemental oxygen.

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

Clinical Safety

The safety of Veklury is supported primarily by data derived from the ongoing Phase III, randomized, double-blind, placebo-controlled, multicentre study NIAID ACTT-1. Additional safety data stem from the placebo-controlled study GS-US-540-5758 in patients with severe COVID-19 and two open-label SIMPLE-studies, GS-US-540-5773 in patients with severe COVID-19 and GS-US-540-5774 in patients with moderate COVID-19. The studies are described in the Clinical Efficacy section.

In study NIAID ACTT-1, the safety of Veklury was assessed in 531 hospitalized patients with COVID-19. Based on the preliminary dataset, the incidence of adverse events was comparable between the Veklury and the placebo groups. Grade 3 or 4 adverse events occurred in 156 (28.8%) patients in the Veklury group and in 172 (33.0%) patients in the placebo group. The most common adverse events in the Veklury and placebo groups were anemia or decreased hemoglobin (7.9% and 9.0%, respectively), acute kidney injury, decreased estimated glomerular filtration rate or creatinine clearance, or increased blood creatinine (7.4% and 7.3%, respectively), pyrexia (5.0% and 3.3%, respectively), hyperglycemia or increased blood glucose level (4.1% and 3.3%, respectively), and increased aminotransferase levels, including alanine aminotransferase, aspartate aminotransferase, or both (4.1% and 5.9%, respectively).

Serious adverse events occurred in 114 (21.1%) patients in the Veklury group and 141 (27.0%) patients in the placebo group. Four events (two in each treatment group) were considered by site investigators to be related to Veklury or placebo. There were 28 (5.2%) serious adverse events of respiratory failure in the Veklury group and 42 (8.0%) in the placebo group. Thirty-six patients receiving Veklury and 36 patients receiving placebo discontinued treatment before day 10 due to an adverse event or a serious adverse event other than death. There were no treatment-related deaths, as considered by the site investigators.

In the study GS-US-540-5758, adverse events were reported in 102 (66%) of 155 patients in the Veklury group and 50 (64%) of 78 patients in the placebo group. Serious adverse events occurred with a higher frequency in the placebo group compared to the Veklury group. More patients in the Veklury group discontinued study drug due to adverse events compared to the placebo group, i.e., 12% vs. 5%. The most common adverse events leading to study drug discontinuation were secondary infection, respiratory failure/acute respiratory distress syndrome, and cardiopulmonary failure.

In the SIMPLE-severe study (GS-US-540-5773), the frequency and severity of adverse events were higher in the patients receiving a 10-day course of Veklury in comparison to those receiving a 5-day course of Veklury. Elevations of transaminases and renal adverse events were reported with a higher frequency in the 10-day Veklury group compared to the 5-day Veklury group, which could be due to imbalances in some baseline characteristics, underlying disease conditions and/or concomitant medications.

In the SIMPLE-moderate study (GS-US-540-5774), adverse events were reported in 106 (54.9%) of 193 patients receiving Veklury for 10 days, 97 (50.8%) of 191 patients receiving Veklury for 5 days, and 90 (45.0%) of 200 patients receiving standard of care. The overall incidence of grade 3 or higher adverse events, serious adverse events, and deaths were generally comparable between the three groups.

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

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

7.2 Non-Clinical Basis for Decision

The medicinal ingredient in Veklury, remdesivir, is an adenosine nucleotide prodrug that is metabolized within host cells to form the pharmacologically active nucleoside triphosphate metabolite. Remdesivir triphosphate acts as an analog of adenosine triphosphate (ATP) and competes with the natural ATP substrate for incorporation into nascent ribonucleic acid (RNA) chains by the severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) RNA-dependent RNA polymerase, which results in delayed chain termination during replication of the viral RNA.

In vitro antiviral activity of remdesivir against SARS-CoV-2, the causative agent of coronavirus disease 2019 (COVID-19), has been shown in primary human airway epithelial cells (with a 50% effective concentration [EC50] of 0.0099 µM).

To date, the resistance profile of remdesivir is considered insufficiently characterized both in vitro and in vivo. Data indicate the presence of geographically distinct clusters of viral strains, with signature structural changes in specific viral proteins. The observed increasing genetic drift of SARS-CoV-2, evolving viral diversity, and different geographic distribution of virus strains might have a substantial effect on the efficacy of remdesivir. Furthermore, the data provided stem from an extremely limited number of sequences (fewer than 2,000). In vitro studies identified two substitutions in the viral RNA-dependent RNA polymerase at residues conserved across coronaviruses that conferred approximately 6-fold reduced susceptibility of SARS-CoV (the causative agent of SARS) to remdesivir. The cell culture development of SARS-CoV-2 resistance to remdesivir has not been assessed. In addition, no clinical data are available on the development of SARS-CoV-2 resistance to remdesivir.

Safety pharmacology data (cardiovascular, respiratory, and central nervous system parameters observed) do not indicate any obvious safety concerns. However, the exposure margins in the cardiovascular studies were low for both remdesivir and its major metabolite, GS-441524, compared to the clinical exposures at the recommended human dose.

In vitro, remdesivir is a substrate for esterases in plasma and tissue, and drug metabolizing enzymes cytochrome P450 (CYP) 2C8, CYP2D6, and CYP3A4. Remdesivir is also a substrate for organic anion transporting polypeptide (OATP) 1B1 and P-glycoprotein (P-gp) transporters. The potential of interaction of remdesivir with inhibitors/inducers of the hydrolytic pathway (esterase) or CYP2C8, CYP2D6 or CYP3A4 has not been studied. Coadministration with strong inhibitors or inducers may result in increased or decreased plasma concentration of remdesivir.

In vitro, remdesivir inhibited CYP 3A4, OATP1B1 and OATP1B3. The clinical relevance of these in vitro drug interactions has not been established.

Remdesivir induced CYP1A2 and potentially CYP3A in vitro. Coadministration of remdesivir with CYP1A2 or CYP3A4 substrates with narrow therapeutic index may lead to loss of their efficacy.

In vitro studies demonstrated an antagonistic effect of chloroquine on the intracellular metabolic activation and antiviral activity of remdesivir. Therefore, the Veklury Product Monograph states that the coadministration of Veklury with chloroquine phosphate or hydroxychloroquine sulphate is not recommended.

Toxicology studies with remdesivir were conducted in cynomologus monkeys, rats, and rhesus monkeys.

In cynomolgus monkeys, at exposures comparable to human clinical exposures, remdesivir was well tolerated, with no significant adverse effects. The No-Adverse-Effect Level was 10 mg/kg/day, which represents a similar exposure to remdesivir as the exposure at human clinical dosing. Cynomolgus monkeys have a metabolic profile for remdesivir that is somewhat similar to humans given the measureable presence of both the parent drug and its metabolites (GS-441525, GS-704277), but overall exposures at the doses used in the long-term toxicity studies were generally equivalent or lower than expected human exposures. The potential adverse effects at exposures higher than comparable human dosing are not known.

In rats and rhesus monkeys, significant renal toxicity was observed at therapeutic and supratherapeutic exposures. Intravenous administration of remdesivir to male rhesus monkeys at dosage levels of 5, 10, and 20 mg/kg/day for 7 days resulted, at all dose levels, in increased mean urea nitrogen and increased mean creatinine, renal tubular atrophy, and basophilia and casts. An unscheduled death of one animal occurred at the 20 mg/kg/day dose level. Intravenous administration of remdesivir to rats at dosage levels of over 3 mg/kg/day for up to 4 weeks resulted in findings indicative of kidney injury and/or dysfunction. Systemic exposures (area under plasma concentration versus time curve [AUC]) of the predominant circulating metabolite of remdesivir (GS-441524) were 0.1 times (monkeys at 5 mg/kg/day) and 0.3 times (rat at 3 mg/kg/day) the exposure in humans at clinical dosing. The mechanism for renal toxicity, observed in rats and rhesus monkeys, but not in cynomolgus monkeys, is uncertain. However, the relevance of these data for humans cannot be ruled out.

Mitochondrial toxicity and/or cellular toxicity was detected in vitro when human hepatocytes were treated for 3 days with remdesivir (0.1 to 30 µM). Rat and monkey hepatocytes appeared to be less sensitive to remdesivir-associated toxicity. Hepatotoxicity findings were not observed in the long-term toxicity studies of remdesivir in rats and monkeys.

Long-term animal studies to evaluate the carcinogenic potential of remdesivir have not been conducted, which is acceptable given the short treatment course (5 to 10 days) recommended for Veklury. Remdesivir did not exert genotoxicity in a battery of assays, including bacterial mutagenicity, chromosome aberration using human peripheral blood lymphocytes, and in vivo rat micronucleus assays.

In reproductive toxicity studies, decreases in corpora lutea, numbers of implantation sites and viable embryos were observed in female rats when remdesivir was administered intravenously daily at a systemically toxic dose (10 mg/kg/day) 14 days prior to mating and during conception. Exposures of the predominant circulating metabolite (GS-441524) were 1.3 times the exposure in humans at the recommended human dose. There were no effects on female reproductive performance (mating, fertility, and conception) at this dose level.

In rats and rabbits, remdesivir demonstrated few adverse effects on embryo-fetal development when administered to pregnant animals at systemic exposures (AUC) of the predominant circulating metabolite of remdesivir (GS-441524) that were up to 4 times the exposure in humans at the recommended human dose.

In rats, there were no adverse effects on pre- and postnatal development at systemic exposures (AUC) of the predominant circulating metabolite of remdesivir (GS-441524) similar to the exposure in humans at the recommended human dose.

It is unknown if the active nucleoside analog triphosphate GS-443902 and the unidentified major human metabolite M27 are formed in rats and rabbits. Accordingly, the reproductive toxicity studies may not be informative of potential risks associated with these metabolites.

The nucleoside analog metabolite GS-441524 has been detected in the blood of nursing rat pups of mothers given remdesivir. Therefore, excretion of remdesivir and/or metabolites into the milk of lactating animals can be assumed.

The results of the non-clinical studies as well as the potential risks to humans have been included in the Veklury Product Monograph. Appropriate warnings and precautionary measures are in place in the Veklury Product Monograph to address the identified safety concerns.

For more information, refer to the Veklury 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 Veklury supported the quality of the lots of Veklury manufactured to date at the proposed commercial manufacturing sites.

However, some uncertainty remains regarding the ability of the manufacturing processes and control strategy to consistently produce a drug substance and drug product of acceptable quality that is comparable to the quality of the lots used in the clinical development program of Veklury.

Nevertheless, in light of the unmet need for treatment of patients with coronavirus disease 2019 (COVID-19) and the public health emergency situation due to the COVID-19 pandemic, Health Canada considered it acceptable to include the quality issues identified in the submission as conditions in the Notice of Compliance with Conditions - Qualifying Notice of July 24, 2020. In keeping with the provisions outlined in the Notice of Compliance with Conditions (NOC/c) Guidance, the sponsor committed to addressing the quality-specific comments and providing additional quality data related to the drug substance and drug product manufacturing information and controls.

Based on the stability data submitted, a shelf life of 36 months is considered appropriate at this time for the powder for solution formulation of Veklury, and a shelf life of 12 months is acceptable for the solution formulation of Veklury.

All non-medicinal ingredients (i.e., excipients, described earlier) found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations. The level of betadex sulfobutyl ether sodium used in the formulations of Veklury was found to be acceptable by Health Canada.

None of the excipients used in the formulations of Veklury is of human or animal origin.