Summary Basis of Decision for Casirivimab and Imdevimab
Summary Basis of Decision (SBD) documents provide information related to the original authorization of a product. The SBD for Casirivimab and Imdevimab is located below.
Recent Activity for Casirivimab and Imdevimab
The SBDs written for eligible drugs (as outlined in Frequently Asked Questions: Summary Basis of Decision [SBD] Project: Phase II) 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. The PAATs will be updated regularly with post-authorization activity throughout the product life cycle.
Post-Authorization Activity Table (PAAT) for Casirivimab and Imdevimab
Updated: 2024-09-20
The following table describes post-authorization activity for casirivimab and imdevimab, a product which contains the medicinal ingredients casirivimab and imdevimab. 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 02516691 – 300 mg/2.5 mL casirivimab and 300 mg/2.5 mL imdevimab, solutions, intravenous administration
DIN 02516705 – 1,332 mg/11.1 mL casirivimab and 1,332 mg/11.1 mL imdevimab, solutions, intravenous administration
Post-Authorization Activity Table (PAAT)
Activity/submission type, control number | Date submitted | Decision and date | Summary of activities |
---|---|---|---|
Authorization by Interim Order Revoked | Not applicable | 2024-06-21 | As a result of the cancellation of NDS # 256264, the authorization of Casirivimab and Imdevimab as per the Interim Order Respecting the Importation, Sale and Advertising of Drugs for Use in Relation to COVID-19 was revoked. |
NDS # 256264 | 2021-09-01 | Cancellation Letter received 2024-06-21 | Submission filed for the treatment of mild to moderate COVID-19, confirmed by direct SARS-CoV-2 viral testing, in adults and adolescents (12 years of age and older weighing at least 40 kg) who were at high risk for progressing to hospitalization and/or death. The sponsor cancelled the submission before Health Canada completed the review. A Summary of Cancellation was published. |
PSUR # 268136 | 2022-09-23 | Review completed 2022-12-29 |
Information filed as per the terms and conditions imposed on the authorization issued under the Interim Order Respecting the Importation, Sale and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order). Six-month PSUR #2 for the period 2022-01-19 to 2022-07-18. The sponsor was asked to provide updated assessments for the ongoing monitoring of safety events. Health Canada has recommended to move the periodic reporting intervals from every 6 months to annual. |
PSUR # 262856 | 2022-03-30 | Review completed 2022-07-13 |
Information filed as per the terms and conditions imposed on the authorization issued under the Interim Order Respecting the Importation, Sale and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order). Six-month PSUR #1 for the period 2021-07-19 to 2022-01-18. The sponsor was asked to provide updated assessments for the ongoing monitoring of safety events. |
Product Monograph update control # 249830 | Not applicable | Approved 2022-06-07 |
An Advisement Letter was issued by Health Canada on 2022-04-28, requesting the sponsor revise the Product Monograph (PM) to update the antiviral resistance information. The sponsor submitted changes to the Microbiology section of the PM; these were reviewed and considered acceptable. |
Health Product Risk Communication | Not applicable | Posted 2022-01-07 |
Health Product Risk Communication posted (Casirivimab and Imdevimab – High Risk of Treatment Failure Due to Circulation of severe acute respiratory syndrome coronavirus 2 [SARS-CoV-2] Omicron Variant), containing new safety information for healthcare professionals. |
Monthly safety report Control # 256732 |
2021-09-16 | Review completed 2021-12-07 |
Information filed as per the terms and conditions imposed on the authorization issued under the Interim Order Respecting the Importation, Sale and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order). Monthly safety reports #1, 2 and 3 for the period 2021-06-01 to 2021-08-31. The current post-market safety data are consistent with the labelled safety profile of Casirivimab and Imdevimab. Health Canada has recommended to move the periodic reporting intervals from monthly to every 6 months. |
Risk Management Plan update Control # 255269 |
2021-07-30 | Review closed 2021-09-16 |
The Core (European Union [EU]) Risk Management Plan (RMP) and Canadian Addendum were filed as per the terms and conditions imposed on the authorization issued under the Interim Order Respecting the Importation, Sale and Advertising of Drugs for Use in Relation to COVID-19. Deficiencies continue to identified, but will be addressed as part of the review of the new drug submission for Casirivimab and Imdevimab filed under the Food and Drug Regulations. |
Dear Healthcare Professional Letter | Not applicable | Posted 2021-07-30 |
Dear Healthcare Professional Letter posted (Authorization of Casirivimab and Imdevimab with English-only Labels for Use in Relation to the COVID-19 Pandemic), containing important information about supply and product safety for healthcare professionals. |
Drug product (DIN 02516705) market notification | Not applicable | Date of first sale: 2021-07-29 |
The manufacturer notified Health Canada of the date of first sale in accordance with section 8 of the Interim Order Respecting the Importation, Sale and Advertising of Drugs for Use in Relation to COVID-19. |
Application # 249830 | 2021-02-24 | Authorized (subject to terms and conditions) 2021-06-09 |
Authorization issued (with imposed terms and conditions) under the Interim Order Respecting the Importation, Sale and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order). |
Summary Basis of Decision (SBD) for Casirivimab and Imdevimab
Date SBD issued: 2021-07-07
The following information relates to the interim authorization for Casirivimab and Imdevimab.
Casirivimab and Imdevimab
Drug Identification Number (DIN):
- DIN 02516691 - 300 mg/2.5 mL casirivimab and 300 mg/2.5 mL imdevimab, solutions, intravenous administration
- DIN 02516705 - 1,332 mg/11.1 mL casirivimab and 1,332 mg/11.1 mL imdevimab, solutions, intravenous administration
Hoffmann-La Roche Ltd.
New Drug Submission Control Number: 249830
On June 9, 2021, Health Canada issued an authorization under the Interim Order Respecting the Importation, Sale and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order) to Hoffmann-La Roche Limited for the drug products casirivimab and imdevimab. The Interim Order, signed by the Minister of Health on September 16, 2020, establishes new authorization pathways with the intent to expedite the authorization for the importation, sale and advertising of drugs used in relation to coronavirus disease 2019 (COVID-19), while taking into consideration urgent public health needs caused by COVID-19.
The interim authorization of casirivimab and imdevimab, to be administered together, was based on limited quality (chemistry and manufacturing), non‑clinical (pharmacology and toxicology), and clinical (pharmacology, safety, and efficacy) information submitted. Following review of the available information, Health Canada considers that sufficient evidence has been provided to support the conclusion that the potential benefits associated with the combination of casirivimab and imdevimab outweigh the potential risks, having regard to the uncertainties relating to the benefits and risks and the necessity of addressing the urgent public health need related to COVID-19. Based on these considerations, the benefit-risk profile of casirivimab and imdevimab, when administered together, is considered favourable for the treatment of mild to moderate COVID-19, confirmed by direct severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) viral testing, in adults and adolescents (12 years of age and older weighing at least 40 kg) who are at high risk for progressing to hospitalization and/or death.
The use of the combination of casirivimab and imdevimab are permitted under an interim authorization delivered in accordance with section 5 of the Interim Order Respecting the Importation, Sale, and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order). The interim authorization of casirivimab and imdevimab is subject to terms and conditions that need to be met by the sponsor to ascertain the continued quality, safety, and efficacy of the products. The terms and conditions may be amended at any time. Furthermore, this authorization may be revoked if new information does not support the safe and effective use of the products.
For further information on authorization under this pathway, refer to Health Canada’s Interim Order Respecting the Importation, Sale, and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order) and the Information and Application Requirements for Drugs Authorized under the Interim Order: Guidance Document.
1 What was approved?
Casirivimab and imdevimab are monoclonal antibodies against the spike protein of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), the causative agent of coronavirus disease 2019 (COVID-19).
Casirivimab and imdevimab, to be administered together, are indicated for the treatment of mild to moderate COVID-19, confirmed by direct SARS-CoV-2 viral testing, in adults and adolescents (12 years of age and older weighing at least 40 kg) who are at high risk for progressing to hospitalization and/or death.
Casirivimab and imdevimab are not authorized for use in patients:
- who are hospitalized due to COVID-19; or
- who require oxygen therapy due to COVID-19; or
- who require an increase in baseline oxygen flow rate due to COVID-19 in those on chronic oxygen therapy due to underlying non-COVID-19-related comorbidity.
Treatment with the combination of casirivimab and imdevimab has not been shown to benefit patients hospitalized due to COVID-19. Monoclonal antibodies, such as casirivimab and imdevimab, may be associated with worse clinical outcomes when administered to hospitalized patients with COVID-19 requiring high-flow oxygen or mechanical ventilation.
Circulating SARS-CoV-2 viral variants may be associated with resistance to monoclonal antibodies. Health professionals should routinely review the antiviral resistance information in the Product Monograph for casirivimab and imdevimab (Section 15 - Microbiology) for details regarding specific variants and resistance, which may be updated regularly.
The combination of casirivimab and imdevimab is not authorized for use in patients younger than 12 years of age or adolescents weighing less than 40 kg. The safety and efficacy of the combination of casirivimab and imdevimab has not been directly assessed in pediatric patients (younger than 18 years of age) in clinical studies. The recommended dosing regimen in patients 12 to 17 years of age, weighing at least 40 kg, is expected to result in comparable serum exposures of casirivimab and imdevimab as those observed in adults based on an allometric scaling approach (which accounted for the effect of body weight changes associated with age on clearance and volume of distribution). Close monitoring in this patient population is highly recommended.
No dosage adjustment is required in patients over 65 years of age.
Casirivimab and imdevimab are contraindicated in patients who are hypersensitive to these drugs or to any ingredient in the formulations, including any non-medicinal ingredients, or component of the container.
Casirivimab and imdevimab are presented individually as solutions that must be administered together as a single intravenous infusion. Each carton contains two vials per package: one vial of 300 mg/2.5 mL of casirivimab and one vial of 300 mg/2.5 mL imdevimab or one vial of 1,332 mg/11.1 mL of casirivimab and one vial of 1,332 mg/11.1 mL imdevimab. In addition to the medicinal ingredients, the solutions contain L-histidine, L-histidine monohydrochloride 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 Product Monograph for casirivimab and imdevimab, approved by Health Canada and available through the Drug Product Database and on the Health Canada COVID-19 vaccines and treatments portal.
2 Why was Casirivimab and Imdevimab approved?
Health Canada considers that sufficient evidence has been provided to support the conclusion that the benefits associated with the combination of casirivimab and imdevimab outweigh the risks, having regard to the uncertainties relating to the benefits and risks and the necessity of addressing the urgent public health need related to coronavirus disease 2019 (COVID-19). Based on these considerations, the benefit-risk profile of casirivimab and imdevimab, when administered together, is considered favourable for the treatment of mild to moderate COVID-19, confirmed by direct severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) viral testing, in adults and adolescents (12 years of age and older weighing at least 40 kg) who are at high risk for progressing to hospitalization and/or death.
The use of casirivimab and imdevimab, when administered together, is permitted under an authorization issued in accordance with section 5 of the Interim Order Respecting the Importation, Sale, and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order). The interim authorization of casirivimab and imdevimab is subject to terms and conditions that need to be met by the sponsor to ascertain the continued quality, safety, and efficacy of the products.
Circulating SARS-CoV-2 viral variants may be associated with resistance to monoclonal antibodies. Health professionals should routinely review the antiviral resistance information in the Product Monograph for casirivimab and imdevimab (Section 15 - Microbiology) for details regarding specific variants and resistance, which may be updated regularly.
Coronavirus disease 2019 is the infectious disease caused by the novel coronavirus, SARS-CoV-2, which has spread rapidly and globally since its emergence in late 2019. In Canada, there have been 1,396,798 confirmed cases of COVID-19 and 25,843 deaths as of June 9, 2021, the date of authorization of casirivimab and imdevimab. Coronavirus disease 2019 is predominantly a respiratory illness that can affect other organs. The SARS-CoV-2 virus is passed from person to person primarily by droplets and aerosols from the nose or mouth when an infected person coughs, sneezes, or speaks. People with COVID-19 can be asymptomatic, or can experience a range of symptoms from mild to severe illness. Symptoms may appear 1 to 14 days after exposure to the virus. Symptoms may include fever (≥38 °C) or chills, cough, shortness of breath, breathing difficulties, fatigue, muscle or body aches, headache, loss of taste or smell, sore throat, congestion or runny nose, nausea or vomiting, and diarrhea. Severe COVID-19 can progress to include pneumonia, severe acute respiratory syndrome, multi-organ failure, and death. The highest disease burden is in older adults and individuals with certain underlying medical conditions such as high blood pressure, obesity, heart disease, chronic kidney disease, type 2 diabetes, cancer, and pulmonary obstructive disease. In addition, the emergence of new variants of concern may increase the rate of transmission as well as the severity of disease among the wider population.
Care for individuals who have COVID-19 has improved with clinical experience, and clinical management of COVID-19 with a variety of therapies has continued to improve. Health Canada has authorized, under the Interim Order Respecting the Importation, Sale, and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order), several vaccines (Pfizer-BioNTech COVID-19 Vaccine, COVID-19 Vaccine Moderna, AstraZeneca COVID-19 Vaccine, Covishield, and Janssen COVID-19 Vaccine) for protection against COVID-19. Two therapies have also been authorized, (Veklury and Bamlanivimab). Nevertheless, there remains an urgent need for treatment options in the context of the ongoing pandemic. Casirivimab and imdevimab, two monoclonal antibodies used in combination, represents the third therapy to be authorized in Canada for the treatment of COVID-19.
Casirivimab and imdevimab are two non-competing, fully human immunoglobulin G1 (IgG1 variant) monoclonal antibodies that bind specifically to the receptor-binding domain of the spike glycoprotein of SARS-CoV-2. This action neutralizes virus infectivity by blocking binding of the virus to angiotensin-converting enzyme 2 (ACE2) receptors.
The authorization of casirivimab and imdevimab under the Interim Order was primarily based on the interim results of the ongoing pivotal Phase I/II/III (cohort 1), placebo-controlled, double-blind, randomized, single-dose study of casirivimab and imdevimab administered in combination to outpatients diagnosed with mild to moderate COVID-19 illness (Study R10933-10987-COV-2067, hereafter referred to as Study COV-2067). Phase III (cohort 1) of the study demonstrated evidence of the efficacy of casirivimab and imdevimab, administered together, in reducing the risk of hospitalization due to COVID-19 or all-cause death in patients who were considered to be at high risk of hospitalization due to COVID-19. In this portion of the study, 4,567 patients were randomized to receive a single intravenous infusion of a 1,200 mg dose (600 mg casirivimab + 600 mg imdevimab; number of patients [n] = 838), a 2,400 mg dose (1,200 mg casirivimab + 1,200 mg imdevimab; n = 1,529), an 8,000 mg dose (4,000 mg of casirivimab + 4,000 mg imdevimab; n = 700), or placebo (n = 1,500). At the start of Phase III, the two selected doses of casirivimab + imdevimab were 8,000 mg and 2,400 mg. However, based on Phase I/II analyses showing that the 8,000 mg and 2,400 mg doses reduced viral load similarly, the Phase III protocol was amended to compare 2,400 mg and 1,200 mg doses with placebo. The data from the 8,000 mg treatment arm were presented descriptively without formal comparison against placebo. Patients with a positive SARS-CoV-2 quantitative reverse transcription polymerase chain reaction (RT-qPCR) result from a nasopharyngeal swab at randomization, and with at least one risk factor for severe COVID-19, were included in the analysis of the primary endpoint.
The study successfully demonstrated statistically significant reductions in the rates of hospitalizations and/or deaths among treated patients compared to those who received placebo. The treatment effect was considered moderate, but potentially meaningful, with absolute risk reductions (for hospitalization/death) of 2.2% and 3.3% for the 1,200 mg and 2,400 mg treatment arms, respectively, compared to placebo. The relative risk reductions were 70.4% (1,200 mg vs. placebo) and 71.3% (2,400 mg vs. placebo). It is uncertain how changes in the expected event rate, which could arise by targeting patients who are at the highest risk of COVID-19-related complications or due to changes in the dynamics of the pandemic, might affect either the absolute or the relative risk reduction estimates.
Patients who entered the study without at least one protocol-specified baseline risk factor generally did not experience events of hospitalization or death, regardless of the treatment received (casirivimab and imdevimab or placebo). Therefore, based on information available at the time of authorization, no treatment benefit is expected among this population, and the combined use of the products is not authorized for use among COVID-19 patients who are not considered at high risk of hospitalization or death. The Dosage and Administration section of the Product Monograph for casirivimab and imdevimab provides guidance for prescribers to help determine the risk of hospitalization and/or death in patients with mild to moderate COVID-19. In addition, it lists the risk factors as applied in the Phase III (Cohort 1) portion of the pivotal study.
Clinical findings from the Phase I and II portions of the study support a direct effect of the combination of casirivimab and imdevimab on viral load. Statistically significant differences were observed between the placebo and each of the 2,400 mg and 8,000 mg treatment arms in the time-weighted average reduction in viral load from baseline when compared to placebo up to Day 7 after treatment. These findings were confirmed among high-risk patients enrolled in the Phase III portion of the study who received either placebo, 1,200 mg casirivimab and imdevimab or 2,400 mg casirivimab and imdevimab.
The pivotal Study COV-2067 also evaluated the risks of treatment. The results of the study suggest that the safety profile of a single combined dose of 2,400 mg (1,200 mg casirivimab + 1,200 mg imdevimab) is relatively unremarkable. Combined doses of up to 8,000 mg (4,000 mg casirivimab + 4,000 mg imdevimab) were administered without any notable increase in the rates of serious adverse events or adverse events of special interest. The most important adverse reactions associated with this combination treatment are infusion-related reactions, hypersensitivity reactions, and anaphylactic reactions. These types of reactions are of concern for monoclonal antibodies in general and were rarely observed in all phases of the ongoing clinical study. The Product Monograph for casirivimab and imdevimab provides warnings regarding each of these potential adverse reactions and advises prescribers that the products should only be administered in a setting where health care professionals have the necessary means to treat such severe reactions. In addition, direction is given to monitor patients for at least 1 hour post infusion.
The relatively low risk of adverse events observed with the combination of casirivimab and imdevimab may be partially due to the mechanism of action, which involves direct binding to the SARS-CoV-2 spike protein and no interaction with any receptor expressed in human tissue. Furthermore, single-dose administration may help to minimize the incidence of hypersensitivity and/or anaphylactic reactions.
No adolescents (12 years of age and older) were included in the available clinical studies with the combination of casirivimab and imdevimab. Preliminary population pharmacokinetic modelling and simulation predicted similar pharmacokinetic exposures following a 2,400 mg dose in adolescent patients weighing greater than 40 kg to those observed in adult patients. The sponsor is currently enrolling pediatric patients into Study COV-2067, and must file the results of this study to Health Canada for evaluation as part of the terms and conditions imposed on this authorization.
The inclusion of high-risk adolescents in the indication is based predominantly on extrapolation of the safety findings in adult patients. Importantly, there is no strong evidence that supports any particular risk factor as being predictive of severe outcomes among the pediatric/adolescent population, and therefore, the Product Monograph for casirivimab and imdevimab does not specify any for this group of patients. However, given the potential for risk factors to be identified as the pandemic progresses, high-risk adolescents have been included in the indication, which allows prescribers to determine if, and when, they should be treated. Notably, the Product Monograph for casirivimab and imdevimab explicitly states that the products have not been studied in this population.
As part of the terms and conditions that need to be met by the sponsor to ascertain the continued quality, safety, and efficacy of the products, Health Canada requested that the sponsor agree to several commitments to be addressed post-market. Commitments include (but are not limited to) providing a Canadian Risk Management Plan (RMP) for casirivimab and imdemivab. 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 products.
Despite several uncertainties, including the identification of meaningful risk factors as well as the potential efficacy among high-risk adolescent patients, given the emergency context of the COVID-19 pandemic, Health Canada considers that casirivimab and imdevimab, when administered together, offer potential benefits for mild to moderate COVID-19 patients at high risk of COVID-19-related hospitalization and/or death, with an acceptable safety profile and an overall favourable benefit-risk balance.
Pursuant to section 5 of the Interim Order, the drug products casirivimab and imdevimab, intended to be administered together, have been authorized for sale in Canada, with associated terms and conditions set out to ascertain the continued quality, safety, and efficacy of the products. At any time, the terms and conditions may be amended. In addition, the authorization may be revoked if new information would not support the safe and effective use of the products.
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 Casirivimab and Imdevimab?
The application for authorization of casirivimab and imdevimab was filed on February 24, 2021, in accordance with section 3 of the Interim Order Respecting the Importation, Sale and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order).
The intent of the Interim Order (signed by the Minister of Health on September 16, 2020) is to expedite the authorization of COVID-19 drugs. The Interim Order allows the Minister to account for the urgent public health needs relating to COVID-19 in deciding whether to authorize a COVID-19 drug based on the provided evidence of safety, efficacy, and quality. As outlined in the Information and Application Requirements for Drugs Authorized under the Interim Order: Guidance Document, the clinical, non-clinical, and quality (chemistry and manufacturing) information submitted in an application for authorization under the Interim Order may not be as comprehensive as that contained in a typical drug submission. The Interim Order sets out a modified set of application requirements with the potential for a rolling submission of information, which allows Health Canada to begin its assessment using the information submitted by the applicant and accept new evidence as it becomes available until the application is deemed complete. This process can reduce time to authorization for these important drugs while maintaining appropriate standards of safety, efficacy, and quality.
The information for this application was provided on a rolling basis. Following an expedited review of the limited clinical, non-clinical, and quality data submitted, Health Canada determined that sufficient evidence was provided to support the conclusion that the potential benefits associated with the combination of casirivimab and imdevimab outweigh the potential risks, having regard to the uncertainties relating to the benefits and risks and the necessity of addressing the urgent public health need related to COVID-19. An authorization for the sale of casirivimab and imdevimab, with imposed terms and conditions, was issued by Health Canada on June 9, 2021.
Submission Milestones: Casirivimab and Imdevimab
Submission Milestone | Date |
---|---|
Pre-application meetings | 2021-01-20 |
Initial application filed by sponsor | 2021-02-24 |
Initial non-clinical data submitted by sponsor | 2021-02-24 |
Initial quality data submitted by sponsor | 2021-02-24 |
Initial clinical data submitted by sponsor | 2021-02-24 |
Health Canada quality evaluation complete | 2021-05-20 |
Final Product Monograph (English) submitted by sponsor | 2021-05-20 |
Final Product Monograph (French) submitted by sponsor | 2021-05-26 |
Health Canada clinical/medical evaluation complete | 2021-06-04 |
Health Canada non-clinical evaluation complete | 2021-06-04 |
Health Canada labelling review complete | 2021-06-07 |
Terms and Conditions finalized by Health Canada | 2021-06-08 |
Interim authorization issued by Director General, Biologic and Radiopharmaceutical Drugs Directorate, Health Canada | 2021-06-09 |
The Canadian authorization decision was based on a critical assessment of the data package submitted to Health Canada. The reviewers also considered the sponsor's responses to information requests made by the United States Food and Drug Administration (FDA) and documents related to the emergency use authorization granted by the FDA for casirivimab and imdevimab.
For further information on authorization under this pathway, refer to Health Canada's Interim Order Respecting the Importation, Sale, and Advertising of Drugs for Use in Relation to COVID-19 and the Information and Application Requirements for Drugs Authorized under the Interim Order: Guidance Document.
4 What follow-up measures will the company take?
In accordance with section 10 of the Interim Order Respecting the Importation, Sale, and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order), terms and conditions were imposed on the authorization issued in respect of casirivimab and imdevimab.
These terms and conditions set out requirements relating to clinical information, quality (chemistry and manufacturing), risk management plan (RMP) elements, and labelling, and were put in place to ascertain the continued quality, safety, and efficacy of the products.
The terms and conditions include (but are not limited to) the requirements listed below.
In relation to the clinical studies, the sponsor will:
- Provide a complete reporting of the clinical study with protocol number R10933-10987-COV-2067, titled: A master protocol assessing the safety, tolerability, and efficacy of anti-spike (S) severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) monoclonal antibodies for the treatment of ambulatory patients with coronavirus disease 2019 (COVID-19). The complete report(s) should provide the final analyses of efficacy and safety from all phases and cohorts including, but not limited to, patients at high risk of hospitalization or death, pediatric patients, and pregnant women. The information should include complete clinical study reports and associated documentation in accordance with the relevant International Council for Harmonisation (ICH) guidelines (e.g., ICH E3 Structure and Content of Clinical Study Reports, ICH M4 The Common Technical Document).
- Provide regular updates to Health Canada regarding the activity and/or clinical efficacy/effectiveness of casirivimab and imdevimab against the current and future variants of concern and variants of interest identified by the World Health Organization (WHO). The WHO lists variants of concern and variants of interest in its weekly epidemiological update on COVID-19, which can be accessed on the WHO website: https://www.who.int/emergencies/diseases/novel-coronavirus-2019/situation-reports.
- Provide updates on global regulatory strategies, including anticipated timelines, for conditional and full marketing authorization applications at least twice per year.
Additionally, the sponsor will:
- Notify Health Canada of any out-of-specification or out-of-trend results during long-term stability testing studies.
- Submit a Core (European Union) Risk Management Plan (RMP) and the Canadian RMP no later than July 31, 2021. The RMP format should follow the guidance (Guidance Document Submission of Risk Management Plans and Follow-Up Commitments) and should include the following in the context of the COVID-19 drugs submitted for authorization under the Interim Order:
- A safety specification that details the identified risks, potential risks, and missing information for the products, with a focus on risks in COVID-19 patients.
- A pharmacovigilance plan that details specific measures to be taken to identify and report safety issues in COVID-19 patients, including adverse reaction reporting, periodic reporting, and ongoing/planned studies.
- A risk minimization plan, if applicable, to manage risks that may require additional measures beyond those considered standard (for instance, labelling).
- After authorization and commencing July 1, 2021, submit monthly safety reports for the period of the interim authorization, unless otherwise determined by Health Canada.
- Submit final snapshots of all components of the electronic platform, containing Canadian-specific labelling information for casirivimab and imdevimab in French and English for Health Canada’s review and records, prior to launch of the electronic platform.
- Develop and distribute a Health Product Risk Communication, in French and English, with Health Canada approval and endorsement, to inform health care professionals about the authorization of casirivimab and imdevimab under the Interim Order with global labels for the initial supply, to expedite access of the drug in the context of the pandemic.
- The letter should direct health care professionals to the electronic platform where they can find information about Canadian-specific labelling in both official languages and should be issued prior to and alongside the distribution of casirivimab and imdevimab.
- Implement Canadian-specific bilingual labelling for casirivimab and imdevimab once supplies are transitioned to Canadian-dedicated supplies. Provide to Health Canada information on the estimated timelines and proposed strategies as soon as these are confirmed.
6 What other information is available about drugs?
Health Canada is committed to providing up‑to‑date information related to vaccines and treatments for COVID‑19. Up‑to‑date information can be found at the following links:
- See the Health Canada COVID‑19 vaccines and treatments portal for information on vaccines and treatments authorized for COVID‑19, as well as those currently under review.
- See MedEffect Canada for the latest advisories, warnings and recalls for marketed products.
- See the Drug Product Database (DPD) for the most recent Product Monographs for drugs that have been approved for use in Canada.
7 What was the scientific rationale for Health Canada's decision?
7.1 Clinical basis for decision
The application for authorization of casirivimab and imdevimab was reviewed under the Interim Order Respecting the Importation, Sale, and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order), which permitted a rolling submission and rolling review. The initial clinical data included results derived from Phases I and II of Study R10933-10987-COV-2067 (Study COV-2067 hereafter). Subsequently, the sponsor updated the submission with Phase III study results, also from Study COV-2067, which was the pivotal study assessing the safety, tolerability, and efficacy of the anti-spike severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) monoclonal antibodies casirivimab and imdevimab administered together for the treatment of ambulatory patients with coronavirus disease 2019 (COVID-19).
Following review, terms and conditions were imposed on the interim authorization of casirivimab and imdevimab to ascertain the continued quality, safety, and efficacy of the products.
Clinical Pharmacology
Casirivimab and imdevimab act together as a combination monoclonal antibody therapy. Both are non-competing, fully human immunoglobulin G1 (IgG1 variant) antiviral monoclonal antibodies, which are unmodified in the fragment crystallizable (Fc) region. Each antibody targets and binds specifically to the receptor-binding domain of the spike glycoprotein of SARS-CoV-2. This action neutralizes virus infectivity by blocking the ability of the virus to bind to angiotensin-converting enzyme 2 (ACE2) receptors. The blockage of the spike protein interaction with ACE2 receptors leads to the inhibition of infection of host cells. When administered together, casirivimab and imdevimab exhibit neutralization activity, with a concentration of 31.0 pM (0.005 μg/mL) providing inhibition of 50% of viral infection in a plaque-reduction neutralization test (PRNT50).
Casirivimab was isolated from Regeneron’s VelocImmune human antibody mouse platform. Imdevimab was isolated from the B cells of a human donor previously infected with SARS-CoV-2.
Clinical pharmacology data and analyses were limited. Based on responses to information requests posed by the United States Food and Drug Administration (FDA) and provided in the submission, the sponsor confirmed the use of a validated bioanalytical method in the measurement of serum concentrations from the Phase III pharmacokinetic substudy. At the time of review, the sponsor had not conducted an exposure-response analysis. Summary pharmacokinetic parameters that included the maximum serum concentrations (Cmax) at the end of infusion and 28 days after dosing were provided. These data suggested exposure increased in a dose-proportional manner for the single 1,200 mg to 8,000 mg intravenous doses (600 mg to 4,000 mg of each antibody), consistent with linear pharmacokinetics. The metabolic pathways of casirivimab and imdevimab have not been characterized. As human monoclonal IgG1 antibodies, both casirivimab and imdevimab are expected to be degraded into small peptides and amino acids via catabolic pathways in the same manner as endogenous IgG.
Study COV-2067 evaluated the combination of casirivimab and imdevimab in ambulatory patients with COVID-19 at combined doses of 1,200 mg (600 mg casirivimab + 600 mg imdevimab), 2,400 mg (1,200 mg casirivimab + 1,200 mg imdevimab), and 8,000 mg (4,000 mg casirivimab + 4,000 mg imdevimab). Patients treated with casirivimab and imdevimab, administered together, demonstrated a statistically significant reduction in the least squares mean viral load (log10 copies/mL) from baseline to Day 7 compared to placebo (-0.71 log10 copies/mL for 1,200 mg and -0.86 log10 copies/mL for 2,400 mg). Consistent effects were observed for the 1,200 mg and 2,400 mg treatment groups, indicating the absence of a dose effect.
The effects of age, renal impairment, or hepatic impairment on the pharmacokinetics of casirivimab and imdevimab are unknown. Renal impairment is not expected to impact the pharmacokinetics of casirivimab and imdevimab, as monoclonal antibodies with a molecular weight >50 kDa are known not to undergo renal elimination. Similarly, dialysis is not expected to impact the pharmacokinetics of casirivimab and imdevimab.
In pediatric patients 12 years of age and older and weighing at least 40 kg, the recommended dosing regimen is expected to result in serum exposures of casirivimab and imdevimab comparable to those observed in adults, since adults with similar body weight were included in Study COV-2067.
There are limited data on the safety and efficacy of patients ≥65 years of age. Of the 4,567 patients randomized in Study COV-2067, 14% were ≥65 years of age, and 4% were ≥75 years of age. The difference in the pharmacokinetics of casirivimab and imdevimab in geriatric patients compared to younger patients is unknown.
The clinical pharmacology data support the use of the combination of casirivimab and imdevimab for the recommended indication.
For further details, please refer to the Product Monograph for casirivimab and imdevimab, approved by Health Canada and available through the Drug Product Database and on the Health Canada COVID-19 vaccines and treatments portal.
Clinical Efficacy
Interim clinical data from the pivotal Study COV-2067 were available to evaluate the clinical efficacy of the combination of casirivimab and imdevimab for the treatment of patients with mild to moderate COVID-19.
Pivotal Study
Study COV-2067 is an ongoing Phase III, randomized, double-blinded, placebo-controlled clinical study of the combination of casirivimab and imdevimab for the treatment of adult patients with mild or moderate COVID-19 who are not hospitalized, but are considered at high risk for hospitalization and/or death due to COVID-19 progression. High-risk patients were those with one or more of the following protocol-defined risk factors: age ≥50 years; obesity (body mass index ≥30 kg/m2); cardiovascular disease, including hypertension; chronic lung disease, including asthma; type 1 or 2 diabetes mellitus; chronic kidney disease, including patients on dialysis; chronic liver disease; and patients who, in the opinion of the investigator, were immunosuppressed.
The study included adult patients (≥18 years of age) who had a positive SARS-CoV-2 diagnostic test within 72 hours prior to randomization, were not hospitalized, and had at least one or more COVID-19 symptoms that were considered mild or moderate in severity. The onset of symptoms should not have occurred >7 days before randomization, and treatment was to be initiated within 3 days of obtaining a positive SARS-CoV-2 viral test result. Key exclusion criteria included: admission to hospital for COVID-19 prior to randomization, or hospitalization for any reason at randomization; prior positive SARS-CoV-2 serologic test; and/or prior positive SARS-CoV-2 antigen or molecular diagnostic test from a sample collected ≥72 hours prior to randomization.
The study population was well-balanced between the treatment arms. The median age was 50 years (range: 18 to 96 years), with 14% of patients ≥65 years of age. Furthermore, 52% of patients were female, 84% were Caucasian, 5% were Black and all patients had one or more predefined risk factors for severe COVID-19.
In Phase III (cohort 1), 4,567 patients were randomized to receive a single intravenous infusion of the 1,200 mg combination (600 mg casirivimab + 600 mg imdevimab; number of patients [n] = 838), the 2,400 mg combination (1,200 mg casirivimab + 1,200 mg imdevimab; n = 1,529), the 8,000 mg combination (4,000 mg casirivimab + 4,000 mg imdevimab; n = 700), or placebo (n = 1,500). Initially, patients were randomized to receive either placebo, or the 2,400 mg or 8,000 mg combination of casirivimab with imdevimab. However, based on the analyses of Phase I/II data suggesting that the 2,400 mg and 8,000 mg treatment arms reduced viral load similarly, the Phase III protocol was amended to compare the 2,400 mg and 1,200 mg doses vs. placebo. Data from the 8,000 mg treatment arm were presented as a descriptive analysis only, with no formal comparison to the placebo treatment arm. Comparisons were conducted between patients randomized to specific casirivimab with imdevimab doses and patients concurrently randomized to placebo.
The full analysis set (FAS) included all randomized patients with COVID-19 symptoms, regardless of whether they had risk factors for severe COVID-19; however, the study protocol was amended to enroll only patients who were considered at high risk based on the presence of one or more protocol-defined risk factors. Consequently, the statistical analysis plan was also amended to specify that the primary and key secondary outcomes would be analyzed considering the modified FAS (mFAS), which included all patients who were in the FAS with detectable SARS-CoV-2 ribonucleic acid (RNA) by quantitative reverse transcription polymerase chain reaction (RT-qPCR) in nasopharyngeal swabs at randomization and who had one or more predefined risk factors (as listed above) for severe COVID-19. The pooled mFAS (n = 4,057) included the 8,000 mg treatment arm. As mentioned above, the mFAS excluded patients who did not have detectable SARS-CoV-2 RNA by RT-qPCR of nasopharyngeal samples taken at randomization. Health Canada requested further analysis with these patients included, and it was determined that their exclusion did not affect the study conclusions. The mFAS was used to analyze the primary and key secondary endpoints.
Considering the mFAS, 1,355 patients received the 2,400 mg combination, 736 patients received the 1,200 mg dose, and 1,341 patients received placebo. Importantly, the 1,200 mg treatment arm was only compared to concurrently enrolled placebo patients (n = 748) who were a subset of the overall placebo group. Given the dynamics of the pandemic in terms of expected event rates at different times, this approach was considered reasonable.
The primary endpoint was the rate of hospitalizations and/or all-cause death occurring through Day 29 in the mFAS. Type I error was controlled via a hierarchical testing scheme, which specified testing the 2,400 mg arm vs. placebo first. In the event that statistical significance was demonstrated, the 1,200 mg arm was to be formally tested against the group of placebo-treated patients who were enrolled concurrently with the patients in the 1,200 mg arm. Further statistical tests were also pre-specified in the statistical analysis plan. However, these tests were not considered as supportive of the recommended indication since they were limited to subgroup analyses defined by the arbitrary cut-offs for nasopharyngeal viral load or by serology status, none of which were clearly related to the rate of hospitalization or death.
In the 2,400 mg combination vs. placebo comparison, fewer events of hospitalization/death were observed among treated patients. The rate of events among patients in the placebo arm was 4.6% (62/1,341 patients) compared to 1.3% (18/1,355 patients) in the 2,400 mg treated arm. This represents an absolute risk reduction of 3.3% and a relative risk reduction of 71.3% in the number of patients with a COVID-19-related hospitalization or all-cause death (95% confidence interval [CI]: 51.7%, 82.9%, p <0.0001). The calculated number needed to treat (NNT) to prevent one hospitalization or death was 30.35 (95% CI: 29.97, 30.73). Considering the 1,200 mg treatment arm in comparison to concurrently enrolled placebo patients, the event rate among patients in the placebo arm was 3.2% (24/748 patients) compared to 1.0% (7/732 patients) in the 1,200 mg treatment arm. The absolute risk reduction was 2.2% and the relative risk reduction was 70.4% (95% CI: 31.6%, 87.1%, p = 0.0024). The calculated NNT for the 1,200 mg arm, compared to placebo was 44.30 (95% CI: 43.40, 45.22).
Overall, most events were hospitalizations related to COVID-19. In the placebo group, there were three deaths through Day 29 and two additional deaths that occurred after Day 29, for a total of five deaths through the end of study follow-up. There was one death in each treatment group.
Clinical findings from the Phase I and II portions of the study support a direct effect of casirivimab and imdevimab on viral load. Statistically significant differences were observed between the placebo and each of the 2,400 mg and 8,000 mg treatment arms in the time-weighted average reduction in viral load from baseline when compared to placebo up to Day 7 after treatment. These findings were confirmed among high-risk patients enrolled in the Phase III portion of the study who received either placebo, the 1,200 mg casirivimab and imdevimab combination or the 2,400 mg casirivimab and imdevimab combination.
Indication
The sponsor filed the application for authorization of casirivimab and imdevimab under the Interim Order with the following indication:
- Casirivimab and imdevimab are indicated for the treatment of mild to moderate coronavirus disease 2019 (COVID-19) in adults and pediatric patients (12 years of age and older weighing at least 40 kg) with laboratory-confirmed SARS-CoV-2 infection and who are at high risk of severe COVID-19.
- High risk is defined as patients who meet at least one of the following criteria:
- Age ≥60 years
- Obesity
- Cardiovascular disease, including hypertension
- Chronic lung disease, including asthma
- Type 1 or type 2 diabetes mellitus
- Chronic kidney disease, including those on dialysis
- Chronic liver disease
- Immunosuppressed, based on investigator’s assessment. Examples include: cancer treatment, bone marrow or organ transplantation, immune deficiencies, HIV (if poorly controlled or evidence of AIDS), sickle cell anemia, thalassemia, and prolonged use of immune-weakening medications.
Health Canada revised the proposed indication to refer to patients who are at high risk of progression to hospitalization or death, instead of referring to progression to severe COVID-19. This better aligns with the dataset provided, in which the primary outcome demonstrated a statistically significant reduction in the rate of hospitalizations or deaths among treated patients compared to placebo. Health Canada also considered the inclusion of a defined set of risk factors in the indication, but determined that patient selection criteria, guided by protocol-defined risk factors in the pivotal clinical study, would be most appropriately provided within the Dosage and Administration section of the Product Monograph for casirivimab and imdevimab rather than within the indication. This approach supports health care professionals in applying clinical judgement with respect to identifying patient risk factors, which may change as new data are gathered throughout the pandemic, while providing information on the risk factors considered in the selection of patients for the pivotal clinical study. Accordingly, Health Canada approved the following indication:
- Casirivimab and imdevimab, to be administered together, are indicated for the treatment of mild to moderate coronavirus disease 2019 (COVID-19), confirmed by direct SARS-CoV-2 viral testing, in adults and adolescents (aged 12 years of age and older weighing at least 40 kg) who are at high risk for progressing to hospitalization and/or death.
Analysis of Efficacy
The recommended total dose of 2,400 mg (1,200 mg casirivimab + 1,200 mg imdevimab) administered as a single intravenous infusion over 1 hour is supported by the statistically significant reduction, compared to placebo, in hospitalizations and deaths up to Day 29 in the Phase III, cohort 1 (adults with risk factors) portion of the pivotal Study COV-2067. A third treatment arm employed a 1,200 mg total dose (600 mg casirivimab + 600 mg imdevimab), which also showed a statistically significant reduction in hospitalizations and deaths compared to placebo over the same time period. The treatment effect was considered moderate, but potentially meaningful, with absolute risk reductions (for hospitalization/death) of 2.2% and 3.3% for the 1,200 mg and 2,400 mg treatment arms, respectively, when compared to placebo. The relative risk reductions were 71.3% (2,400 mg vs. placebo) and 70.4% (1,200 mg vs. placebo).
Health Canada recommends that the 2,400 mg combined dose of casirivimab and imdevimab be maintained at least until such time that it can be confirmed that lower doses retain efficacy against variants of concern, which were not widely circulating during the examined period of the ongoing pivotal clinical study. In addition, while no comparison was made, there appeared to be a trend towards a greater reduction in hospitalizations in the 2,400 mg treatment group compared to the 1,200 mg treatment group both in the primary outcome analyses and in the landmark analyses. This may have been due to imprecision in the 1,200 mg treatment group outcomes associated with a lower sample size or due to changing event rates over time (the 1,200 mg arm was initiated late in the trial), but the reasons for the difference are uncertain. In the face of an evolving infectious agent, Health Canada is of the opinion that maximum neutralization capacity of the authorized antiviral products (as exhibited by the 2,400 mg dose) should be maintained. Notably, the 2,400 mg dose was not associated with a greater risk of adverse reactions compared to lower doses.
For more information, refer to the Product Monograph for casirivimab and imdevimab, approved by Health Canada and available through the Drug Product Database and on the Health Canada COVID-19 vaccines and treatments portal.
Clinical Safety
Pivotal Study COV-2067 Phase I, II, and III (Cohort 1)
Throughout the ongoing Study COV-2067 (described in the Clinical Efficacy section), the sponsor conducted a safety assessment that was limited to the collection of targeted treatment emergent adverse events (TEAEs). During Phases I, II, and III (cohort 1), targeted safety reporting included serious adverse events (SAEs), Grade 2 or higher infusion-related reactions, and Grade 2 or higher hypersensitivity reactions. In Phase I only, TEAEs that were Grade 3 or higher were recorded. In Phase III only, TEAEs that led to a medically attended visit (hospitalization, emergency room visit, physician’s office, telemedicine) were recorded. This limited safety reporting may have risked the under-reporting of certain adverse reactions, for example, Grade 1 infusion-related reactions or hypersensitivity reactions; however, important adverse reactions would be expected to be captured by focussing on higher-grade adverse events of special interest (AESIs), SAEs and events that led patients to seek medical care. Importantly, the following safety summary is limited to the adult population.
Phase I and II (combined safety)
The safety analysis sets included all patients who were randomized and received any study drug. In Phase I and II combined, 262 patients received placebo, 258 patients received the 2,400 mg combination (1,200 mg casirivimab + 1,200 mg imdevimab) and 260 patients received the 8,000 mg combination (4,000 mg casirivimab + 4,000 mg imdevimab). Serious adverse events occurred in 6 (2.3%) placebo patients, 4 (1.6%) patients treated with 2,400 mg casirivimab and imdevimab, and 2 (0.8%) patients treated with 8,000 mg casirivimab and imdevimab. Adverse events of special interest (≥Grade 2 infusion-related reactions/hypersensitivity reactions) were infrequent across treatment arms and occurred among 0.8% of placebo patients, 0% of 2,400 mg casirivimab and imdevimab patients and 1.5% of 8,000 mg casirivimab and imdevimab patients. Grade 3-4 TEAEs were observed with similar frequencies across treatment arms, with the highest proportion observed among placebo-treated patients at 1.5%. Serious adverse events reported in more than one patient were hypoxia and pneumonia, which each occurred in two patients who received placebo. Pneumonia was also reported in one patient who received 2,400 mg casirivimab and imdevimab.
Phase III (Cohort 1)
In the safety analysis set of Phase III (cohort 1), 1,843 patients received placebo, 827 patients received the 1,200 mg combination (600 mg casirivimab + 600 mg imdevimab), 1,849 patients received the 2,400 mg combination (1,200 mg casirivimab + 1,200 mg imdevimab), and 1,012 patients received the 8,000 mg combination (4,000 mg casirivimab + 4,000 mg imdevimab). Serious adverse events occurred in 74 (4.0%) patients treated with placebo, 9 (1.1%) patients treated with 1,200 mg casirivimab and imdevimab, 24 (1.3%) patients treated with 2,400 mg casirivimab and imdevimab, and 17 (1.7%) patients treated with 8,000 mg casirivimab and imdevimab. Adverse events of special interest (Grade ≥2 infusion-related reactions/hypersensitivity reactions) were infrequent across treatment arms, occurring in fewer than 0.5% of patients in any given treatment arm. Tabulation of SAEs by system organ class was provided in the data summary. Notably, SAEs appeared to mainly be the consequence of COVID-19 (e.g., hypoxia, dyspnea, and pneumonia), rather than due to treatment, with a greater rate of SAEs observed among patients who received placebo as compared to treated patients. Five patients (0.3%) in the placebo group died as did one patient (0.1%) in each of the casirivimab and imdevimab groups. None of the deaths were considered to be related to study treatment.
Overall, the combination of casirivimab and imdevimab appears to be well tolerated across the dosing range studied. Given the nature of the products (recombinant monoclonal antibodies), there is potential for hypersensitivity and/or anaphylactic reactions. In addition, administration by intravenous infusion is associated with the risk of infusion reactions. For these reasons, these specific risks have been included under the Warnings and Precautions of the Product Monograph for casirivimab and imdevimab.
Supportive Study
At the time of review, Study COV-20145 was an ongoing, randomized, double-blind, placebo-controlled, parallel-group study to assess the dose-response profile of single intravenous or subcutaneous doses of casirivimab and imdevimab in outpatients with SARS-CoV-2 infection. Eligible patients, consisting of adults that were either asymptomatic or had COVID-19 but no risk factors for severe COVID-19, were randomized equally to receive a single dose of the combination of casirivimab and imdevimab or placebo by either subcutaneous injection or intravenous infusion. The study enrolled 1,164 patients of whom 803 are included in the analysis.
Safety variables collected included: TEAEs, treatment-emergent SAEs, and treatment-emergent AESIs (Grade ≥2 infusion-related reactions, Grade ≥3 injection-site reactions, Grade ≥2 hypersensitivity reactions, and any TEAE that led to a hospitalization or emergency room visit, regardless of whether the visit was related to COVID-19).
Although the results of the study were not relevant with respect to efficacy for the indicated population, from a safety perspective, the study did not show any concerning safety signals. The rate of TEAEs was similar between intravenous placebo and intravenous casirivimab and imdevimab. The rate of TEAEs experienced in the subcutaneous treatment arms also appeared similar to that observed in the intravenous treatment arms. Infusion-related reactions, injection-site reactions, and hypersensitivity were not observed in this study.
Analysis of Safety
The safety of the combination of casirivimab and imdevimab was based on limited reporting of the ongoing Phase II/III Study COV-2067. Serious and unexpected adverse events that have not been previously reported with the use of the combination (casirivimab and imdevimab) may occur. At the time of authorization, the results of the study suggest that the safety profile of a single combined dose of 2,400 mg (1,200 mg casirivimab + 1,200 mg imdevimab) is relatively unremarkable.
Serious hypersensitivity reactions, including anaphylaxis, as well as infusion-related reactions have been reported with the administration of the combination of casirivimab and imdevimab. These reactions may be severe or life-threatening. In addition, a potential risk of treatment failure exists, as circulating SARS-CoV-2 viral variants may be associated with resistance to monoclonal antibodies such as casirivimab and/or imdevimab. Health care professionals should routinely review the antiviral resistance information in the Product Monograph for casirivimab and imdevimab (Section 15 - Microbiology) for details regarding specific variants and resistance, as it may be updated regularly.
Appropriate warnings and precautions are in place in the approved Product Monograph for casirivimab and imdevimab to address the identified safety concerns.
There are limited data from the use of casirivimab with imdevimab in pregnant women. The combination therapy of casirivimab and imdevimab should be used during pregnancy only if the potential benefit justifies the potential risk for the mother and the fetus considering all associated health factors.
There are no available data on the presence of casirivimab and/or imdevimab in human milk or animal milk, the effects on the breastfed infant, or the effects of the drug on milk production. Maternal immunoglobulin G (IgG) is known to be present in human milk. The developmental and health benefits of breastfeeding should be considered along with the mother's clinical need for the combination of casirivimab and imdevimab and any potential adverse effects on the breastfed child from either casirivimab and imdevimab or from the underlying maternal condition.
For more information, refer to the Product Monograph for casirivimab and imdevimab, approved by Health Canada and available through the Drug Product Database and on the Health Canada COVID-19 vaccines and treatments portal.
7.2 Non-Clinical Basis for Decision
The non-clinical data contained in the application for authorization of casirivimab and imdevimab under the Interim Order Respecting the Importation, Sale and Advertising of Drugs for Use in Relation to COVID-19 included the results of seven in vitro primary pharmacodynamics studies, six in vivo primary pharmacodynamics studies, one validation of bioanalytical methods report, two pharmacokinetics studies, and three toxicology studies (including one repeat-dose toxicology study and two ex vivo tissue cross-reactivity studies).
In vitro characterization studies demonstrated that casirivimab and imdevimab bind to the receptor-binding domain (RBD) of the SARS-CoV-2 spike protein with high affinity and block the interaction between the spike protein and the angiotensin-converting enzyme 2 (ACE2) receptor which mediates cell entry. Casirivimab and imdevimab bind non-overlapping epitopes and mediate the concentration-dependent inhibition of RBD binding to ACE2 receptor individually and in combination.
The potential for antibody-dependent enhancement (ADE) was evaluated for casirivimab and imdevimab individually and in combination. In vitro studies with authentic SARS-CoV-2 and primary human monocytic cells did not show enhancement of viral uptake in the presence of casirivimab and imdevimab. Furthermore, no evidence of ADE was detected in any of four in vivo studies. Enhanced viral replication, increased inflammation, or more severe disease were not observed in animals treated with casirivimab and imdevimab, relative to animals that received the placebo.
The combination of casirivimab and imdevimab retained activity against all variants tested when the neutralization activity of both antibodies was evaluated against vesicular stomatitis virus (VSV) pseudotyped with the 37 most common RBD variants in circulation (as of late March 2020), as well as the D614G and D614N spike protein variants. The fold change in the half-maximal inhibitory concentration [IC50] over reference virus was lower than 2 for all variants studied.
In an inhibition assay, the majority of mutants showing reduced susceptibility to one monoclonal antibody retained susceptibility to the other, and all variants retained susceptibility to the casirivimab and imdevimab combination. Additionally, neutralization potency against the variants of concern (B.1.351 (Beta), B.1.1.7 (Alpha), and P.1 (Gamma) was tested in vitro using the pseudotyped VSV-SARS-CoV-2 model. For the combination therapy (casirivimab and imdevimab), the fold change in IC50 relative to the reference pseudovirus (D614G) was 0.9 for the B.1.1.7 (Alpha) variant, 1.23 for the variant B.1.429 (Epsilon), 1.6 for the E484K mutation, 0.60 for the B.1.351 (Beta) variant, and 1.43 for the P.1 (Gamma) variant.
The efficacy of the casirivimab and imdevimab combination was also evaluated in rhesus macaque and hamster models of SARS-CoV-2 infection. Casirivimab and imdevimab promoted accelerated viral clearance, based on results from quantitative reverse transcription polymerase chain reaction (RT-PCR) assays of nasopharyngeal and oral swab samples from rhesus macaques. In hamsters, protection from weight loss was observed following treatment with the combination of casirivimab and imdevimab, along with a slight reduction in the severity of lung inflammation. However, none of the therapeutic arms in the rhesus macaque model of SARS-CoV-2 infection reached the primary endpoint (i.e., statistically significant reduction in viral load relative to placebo, as assessed by nasopharyngeal swab samples). Additionally, the observed decrease in viral load was not dose-dependent in rhesus macaques or in hamsters.
Non-clinical pharmacokinetic studies were conducted in which cynomolgus monkeys were administered single doses of casirivimab and imdevimab, individually or in combination, through either the intravenous (IV) or subcutaneous (SC) route. Concentration-time profiles in serum were characterized by an initial brief distribution phase (IV) or an absorption phase (SC). A single linear elimination phase was observed for both casirivimab and imdevimab. The pharmacokinetics of casirivimab and imdevimab did not change when administered individually or in combination, indicating that there were no pharmacokinetic interactions between the two individual antibodies. No evidence was observed of anti-drug antibodies (ADA) affecting the concentration-time profiles. Dose-proportional increases were observed in serum exposure (as measured by the maximum concentration [Cmax] or the area under the plasma concentration-time curve from time 0 to infinity [AUCinf]) following dosing of the casirivimab and imdevimab combination at 10 and 50 mg/kg of each antibody. The volume of distribution at steady state was also comparable across dose groups. The mean terminal half-life (t1/2) calculated during the elimination phase ranged from approximately 13 to 18 days across the various dose groups for casirivimab, imdevimab and casirivimab and imdevimab.
The pharmacokinetics of casirivimab and imdevimab were linear in a repeat-dose toxicology study in cynomolgus monkeys, in which the antibodies were administered individually or in combination once weekly through either the IV or SC route. Linearity was indicated by dose-proportional increases in Cmax across the IV dose groups and dose-proportional increases in exposure as measured by the area under the concentration-time curve (AUC) across the individual antibody and combination dose groups during the 4-week treatment and the 8-week recovery periods. There was no impact observed on the toxicokinetics of the individual casirivimab or imdevimab antibodies when administered in combination. Concentrations of total casirivimab and total imdevimab generally approached steady state by the fourth dose. All dose levels tested were well tolerated, with no drug-related or adverse effects evident. Based on the lack of identified adverse effects, the no-observed-adverse-effect level (NOAEL) for casirivimab and imdevimab is considered to be 150 mg/kg of individual antibody (total dose of 300 mg/kg), which was the highest dose evaluated.
In ex vivo tissue cross-reactivity studies, there was no off-target binding of total casirivimab or imdevimab in any human or monkey tissues or human fetal tissues evaluated, which was anticipated, as both antibodies bind an exogenous protein. No juvenile animal toxicology studies were conducted.
Overall, the non-clinical pharmacology and toxicology profile of casirivimab and imdevimab supports their proposed clinical use. Casirivimab and imdevimab had an acceptable safety profile and demonstrated high-affinity binding to the SARS-CoV-2 spike protein. Following treatment with both antibodies, accelerated viral clearance was observed in rhesus macaques infected with SARS-CoV-2, and hamsters infected with SARS-CoV-2 were protected from weight loss and a slight reduction in the severity of lung inflammation. However, although the in vitro pharmacology studies are proof of concept of the proposed mechanism of action of casirivimab and imdevimab, based on the in vivo pharmacology studies, the correlation between the viral load reduction and efficacy of the treatment of SARS-CoV-2 with casirivimab and imdevimab is uncertain. Additionally, the in vitro data showed that the casirivimab and imdevimab combination might retain activity against current circulating variants of concern.
The results of the non-clinical studies as well as the potential risks to humans have been included in the Product Monograph for casirivimab and imdevimab. Considering the intended use of the combination of casirivimab and imdevimab, there are no pharmacological or toxicological issues within this application which preclude authorization of the products.
For more information, refer to the Product Monograph for casirivimab and imdevimab, approved by Health Canada and available through the Drug Product Database and on the Health Canada COVID-19 vaccines and treatments portal.
7.3 Quality Basis for Decision
Limited quality (chemistry and manufacturing) data were provided in the application for authorization of casirivimab and imdevimab under the Interim Order Respecting the Importation, Sale, and Advertising of Drugs for Use in Relation to COVID-19 (Interim Order). Of note, given the intent of the Interim Order to expedite the authorization of coronavirus disease 2019 (COVID-19) drugs, data submitted may not be as comprehensive as the data contained in a typical new drug submission. Following review, terms and conditions were imposed on the interim authorization of casirivimab and imdevimab to ascertain the continued quality, safety, and efficacy of the products.
Characterization of the Drug Substances
Casirivimab and imdevimab are two non-competing, high-affinity human immunoglobulin G1 monoclonal antibodies against the severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2). Each of these antibodies binds to the receptor-binding domain of the spike protein of SARS-CoV-2, blocking viral entry into host cells.
Detailed characterization studies were performed to provide assurance that casirivimab and imdevimab consistently exhibit the desired characteristic structure and biological activity. Identity, secondary and tertiary structure, molar mass, molecular weight, size heterogeneity, purity, charge heterogeneity, chemical heterogeneity, binding, and biological activity were among the quality attributes assessed for both antibodies. Post-translational modifications including glycation, N-linked sugar chain structure, C-terminal heterogeneity, deamidation, and oxidation were also examined.
Manufacturing Process and Process Controls of the Drug Substances and Drug Products
The manufacturing processes for the casirivimab and imdevimab drug substances are nearly identical, with the main difference being the specific cell banks used to produce each antibody.
Each of the antibodies is expressed from Chinese hamster ovary (CHO) cells, which have been genetically engineered to express either casirivimab or imdevimab through recombinant deoxyribonucleic acid (DNA) technology. The cell culture is initiated, allowed to expand, and then used to inoculate a production bioreactor. As the cell culture continues to expand, the recombinant protein is produced and secreted into the culture medium.
To retrieve the antibodies, the production fermentate is first centrifuged and filtered to remove the cell debris, and then the harvested cell culture fluid undergoes chromatography. The antibodies are further purified through a series of viral inactivation, chromatography, filtration, formulation, and concentration steps. The formulated drug substance is filtered into containers using an appropriate aseptic technique, and then shipped to receiving sites under temperature-controlled conditions (≤-20 °C).
Manufacturing of the casirivimab and imdevimab drug products begins with thawing and mixing of the formulated drug substance, followed by bioburden reduction filtration and aseptic filling into glass vials. The vials are inspected visually, placed in secondary packaging, and stored at 2 °C to 8 °C.
The process performance qualification data reviewed reflected consistency in the drug substance and drug product manufacturing processes for both casirivimab and imdevimab. All process parameters, process attributes, release testing results, and stability results met predefined criteria, acceptance limits, and specifications for all validation lots.
Control of the Drug Substances and Drug Products
A multi-level control strategy has been incorporated into the overall process performance and product quality monitoring system to ensure the consistent manufacturing of acceptable product and to mitigate the risk of failures in process performance.
Specifications were determined based on historical release and stability batch data, clinical experience, manufacturing history and capability, analytical method capability, regulatory expectations, safety, and compendial requirements for protein-based products. These will be revised as additional data are accumulated. Further control is provided through release and stability trending programs. This strategy is considered acceptable within the context of the Interim Order submission.
Casirivimab and imdevimab are Schedule D (biologic) drugs and are, therefore, subject to Health Canada's Lot Release Program before sale as per Health Canada's Guidance for Sponsors: Lot Release Program for Schedule D (Biologic) Drugs. They have been placed in Lot Release Evaluation Group 3 of the Lot Release Program. Products in Lot Release Evaluation Group 3 require review by the Biologic and Radiopharmaceutical Drugs Directorate and issuance of a formal release letter prior to their release for sale on the Canadian market.
Stability of the Drug Substances and Drug Products
Based on the stability data submitted, the proposed shelf life and storage conditions for the drug substance and drug product are considered acceptable.
The available stability data support the proposed shelf life of 24 months for the casirivimab and imdevimab drug products when stored at a temperature of 2 °C to 8 °C and protected from light. Once opened, the drug products should be diluted and infused together immediately. The diluted solution may be stored for up to 4 hours at room temperature (up to 25 °C) or up to 36 hours at refrigerated temperature (2 °C to 8 °C).
Facilities and Equipment
The design, operations, and controls of the facilities and equipment involved in production are considered suitable for the activities and products manufactured.
Based on risk assessment scores determined by Health Canada, on-site evaluations of the drug substance and drug product manufacturing facilities were not deemed necessary.
The sites involved in production are compliant with Good Manufacturing Practices.
Adventitious Agents Safety Evaluation
The manufacturing processes of casirivimab and imdevimab incorporate adequate control measures to prevent contamination and maintain microbial control. Acceptable viral clearance studies have been performed to support the viral clearance capability of the process. Bioburden and endotoxin testing procedures are integrated in the control strategy and meet relevant guidelines and requirements.
The raw materials used during manufacturing originate from sources with no or minimal risk of transmissible spongiform encephalopathy or other human pathogens.