`RESEARCH
`
`
`
`APPLICATION NUMBER:
`
`203567Orig1s000
`
`OFFICE DIRECTOR MEMO
`
`
`
`
`
`
`MEMORANDUM
`
`DEPARTMENT OF HEALTH AND HUMAN SERVICES
`FOOD AND DRUG ADMINISTRATION
`CENTER FOR DRUG EVALUATION AND RESEARCH
`
`DATE:
`TO:
`
`
`
`
`
`FROM:
`
`
`June 5, 2014
`NDA 203567 Jublia (efinaconazole) topical solution, 10%
`Dow Pharmaceutical Sciences, Inc.
`
`Julie Beitz, MD
`Director, Office of Drug Evaluation III
`
`Approval Action
`
`
`
`
`
`SUBJECT:
`
`Jublia (efinaconazole) topical solution, 10% is an azole antifungal product indicated for the
`topical treatment of onychomycosis of the toenails due to Trichophyton rubrum and
`Trichophyton mentagrophytes. Jublia is applied to affected toenails once daily for 48 weeks
`using an integrated flow‐through brush applicator. Efinaconazole is a new molecular entity.
`
`This memorandum documents my concurrence with the Division of Dermatology and Dental
`Product’s recommendation for approval of Jublia (efinaconazole) topical solution, 10%.
`Discussions regarding product labeling and postmarketing requirements and commitments have
`concluded and there are no inspectional issues that preclude approval.
`
`REGULATORY HISTORY
`
`NDA 203567 was submitted on July 25, 2012, and granted a standard review. While the clinical
`review identified no efficacy or safety issues that would preclude approval, product quality
`deficiencies were identified involving inadequate: 1) manufacturing process and controls for the
`filling/capping
` operation, 2) specifications for the drug product regarding leak
`detection, 3) integrity of the container closure system, and 4) stability data to assure the
`expiration dating period. A Complete Response letter was issued on May 13, 2013.1
`
` A
`
` post‐action meeting was held with the applicant on July 17, 2013 to discuss the applicant’s
`proposed control strategies to address the identified deficiencies. A complete response was
`submitted on December 20, 2013.
`
`The application was not discussed before an FDA Advisory Committee as there were no novel or
`complex scientific or regulatory issues that required outside expertise. Efinaconazole is an
`antifungal product in the azole class, a class which includes several approved products.
`
`PRODUCT QUALITY
`
`Jublia (efinaconazole) topical solution, 10% is a clear colorless to pale yellow solution. Each
`gram contains 100 mg of efinaconazole. Jublia contains the following inactive ingredients:
`purified water, cyclomethicone, diisopropyl adipate, alcohol, C12‐15 alkyl lactate, butylated
`
`1 For a detailed discussion of the first cycle review, see Dr. Victoria Kusiak’s memorandum dated May 13, 2013.
`
`Reference ID: 3519748
`
`(b) (4)
`
`
`
`hydroxytoluene, anhydrous citric acid, and disodium edetate. The alcohol content is
`approximately
` w/w in the product.
`
`The drug product is manufactured by Kaken Pharmaceutical Co., Ltd. (Japan) by
`
`
`
`
`
` In the complete response, the applicant proposed a new container
`closure system. Each bottle is fitted with an inside
` plug with a
` flow‐
`through brush applicator and a
` cap.
`
`The to‐be‐marketed container closure system was evaluated for chemical and physical stability,
`performance during in‐use studies, photostability, presence of extractables and leachables, and
`comparability to the container closure system that was used in phase 3 trials.
`
`Several manufacturing in‐process controls have also been implemented, including periodic
`checks of fill weight, assessment of brush alignment and cap torque, and 100% visual inspection
`of packaging integrity.
`
`The applicant’s newly proposed container closure system and controls of the filling operation
`adequately address the Agency’s previously identified deficiencies. The applicant’s stability
`studies (24 months long‐term and 6 months accelerated) support a 36 month expiration dating
`period, when stored under USP controlled room temperature conditions.
`
`NONCLINICAL
`
`Efinaconazole revealed no evidence of mutagenic or clastogenic potential based on the results
`of in vitro (Ames assay and Chinese hamster lung cell chromosome aberration assay) and in vivo
`(mouse peripheral reticulocyte micronucleus assay) genotoxicity testing.
`
` A
`
` 2‐year carcinogenicity study in mice was conducted with daily topical administration of 3%,
`10% and 30% efinaconazole solution. Severe irritation was noted at the treatment site in all
`dose groups which was attributed to the vehicle. There was no treatment‐related increase in
`neoplasms.
`
`No effects on fertility were observed in male and female rats that were administered
`subcutaneous doses up to 25 mg/kg/day efinaconazole (279 times the maximum recommended
`human dose, MRHD) prior to and during early pregnancy.
`
`PREGNANCY
`
`Jublia will be classified as Pregnancy Category C and should be used during pregnancy only if the
`potential benefit justifies the potential risk to the fetus.
`
`Systemic embryofetal development studies were conducted in rats and rabbits. Subcutaneous
`doses of 2, 10, and 50 mg/kg/day efinaconazole were administered during the period of
`organogenesis (gestational days 6‐16) to pregnant female rates. In the presence of maternal
`toxicity, embryofetal toxicity (increased embryofetal deaths, decreased number of live fetuses,
`
`
`
`Reference ID: 3519748
`
`2
`
`(b) (4)
`
`(b) (4)
`
`(b) (4)
`
`(b) (4)
`
`(b) (4)
`
`
`
`and placental effects) was noted at 50 mg/kg/day (559 times the MRHD2); congenital
`malformations were not observed at this dose. No embryofetal toxicity was noted at 10
`mg/kg/day (112 times the MRHD).
`
`Subcutaneous doses of 1, 5, and 10 mg/kg/day efinaconazole were administered during the
`period of organogenesis (gestational days 6‐19) to pregnant female rabbits. In the presence of
`maternal toxicity, no embryofetal toxicity or congenital malformations were noted at 10
`mg/kg/day (154 times the MRHD).
`
`In rats, subcutaneous doses of 1, 5 and 25 mg/kg/day efinaconazole were administered from the
`beginning of organogenesis through the end of lactation. In the presence of maternal toxicity,
`embryofetal toxicity was noted at 25 mg/kg/day (89 times the MRHD), including increased
`prenatal pup mortality, reduced live litter sizes and increased postnatal pup mortality. No
`effects on postnatal development were noted at this dose. No embryofetal toxicity was noted
`at 5 mg/kg/day (17 times the MRHD).
`
`CLINICAL PHARMACOLOGY
`
`Efinaconazole is an azole antifungal product that inhibits fungal ergosterol synthesis by
`inhibiting the enzyme lanosterol 14‐‐demethylase. Inhibition of this enzyme’s activity results
`in decreased amounts of ergosterol, a constituent of fungal cell membranes, and a
`corresponding accumulation of lanosterol. Efinaconazole has been shown to be active against
`isolates of Trichophyton rubrum and Trichophyton mentagrophytes both in vitro and in clinical
`infections.
`
` maximal use pharmacokinetic trial to assess systemic exposure resulting from use of
`efinaconazole was conducted in 18 subjects with severe onychomycosis. Efinaconazole was
`applied daily for 28 days to all ten toenails and to 0.5 cm of adjacent skin. Plasma
`concentrations of efinaconazole were near steady state by day 14.
`
`Drug interactions. The potential for efinaconazole to inhibit CYP 450 enzymes 1A2, 2A6, 2C8,
`2C9, 2C19, 2D6, 2PE1, and 3A4 was evaluated in vitro using human liver microsomes.
`Efinaconazole did not inhibit the enzymatic activities of any of these CYP enzymes. The
`potential for efinaconazole to induce CYP 1A2 and CYP 3A4 was assessed in vitro using human
`primary hepatocytes; no induction of enzyme activity was observed.
`
`EFFICACY
`
`The efficacy of Jublia (efinaconazole) topical solution, 10% was demonstrated in two 52‐week
`randomized, double‐blind, vehicle‐controlled trials of similar design. Subjects aged 18 years and
`older with onychomycosis involving 20‐50% of the target toenail were randomized 2:1 to either
`48 weeks of treatment with Jublia or vehicle solution. The primary efficacy endpoint, Complete
`Cure, defined as the proportion of subjects with 0% clinical involvement of the target toenail,
`negative KOH and negative fungal culture, was assessed at week 52.
`
`
`2 Multiples of human exposure were calculated based on comparisons between the maximal human AUC of 25.5 ng
`hr/mL in the maximal use clinical pharmacology trial and the AUCs for the NOAELs identified in the nonclinical studies.
`
` A
`
`
`
`Reference ID: 3519748
`
`3
`
`
`
`Trial P3‐01 enrolled 656 subjects on Jublia and 214 on vehicle solution. Trial P3‐02 enrolled 580
`subjects on Jublia and 201 on vehicle solution. Baseline demographics were similar in both
`trials. Complete Cure was significantly higher in the Jublia‐treated groups compared to the
`vehicle‐treated groups (17.8% vs. 3.3%, and 15.2% vs. 5.5%, in the two trials, respectively).
`Complete or Almost Complete Cure, defined in these trials as the proportion of subjects with
`less than or equal to 5% clinical involvement of the target toenail, negative KOH and negative
`fungal culture, was assessed at week 52. Treatment with Jublia was superior to vehicle in both
`trials (26.4% vs. 7.0%, and 23.4% vs. 7.5%, respectively).
`
`Mycologic Cure, defined as the proportion of subjects with negative KOH and negative fungal
`culture, was assessed at week 52. Treatment with Jublia was superior to vehicle in both trials
`(55.2% vs. 16.8%, and 53.4% vs. 16.9%).
`
`SAFETY
`
` A
`
` total of 1227 subjects received Jublia in the two phase 3 trials submitted in the NDA. Of these,
`1161 were exposed for at least 24 weeks and 780 were exposed for 48 weeks. In these trials,
`the most common adverse reactions were ingrown toenail and application site reactions
`(involving dermatitis, vesicles or pain). These occurred in 1‐2% of Jublia‐treated and in less than
`1% of vehicle‐treated subjects, respectively. Most adverse reactions were mild in severity.
`
`PEDIATRICS
`
`The Pediatric Use section of product labeling will state that the safety and effectiveness of Jublia
`in pediatric patients have not been established.
`
`On April 30, 2014, the Pediatric Review Committee (PeRC) recommended a partial waiver
`request in pediatric patients ages 0 to 1 year 11 months for onychomycosis of the toenails
`because necessary studies are impossible or highly impractable. The Division instead has
`recommended a partial waiver in pediatric patients ages 0 to 11 years 11 months, citing that
`culture positive onychomycosis due to Trichophyton rubrum and Trichophyton mentagrophytes
`is not prevalent in the pediatric population younger than 12 years of age. I concur with the
`Division’s recommendation.
`
`In addition, the PeRC recommended deferring submission of pediatric studies for ages 12 years
`to less than 17 years for this application because this product is ready for approval in adults and
`the pediatric studies have not been conducted.
`
`The applicant will be required to conduct the following pediatric study post‐approval:
`
`
`1) A maximum use pharmacokinetic and safety study in pediatric subjects ages 12 years to
`less than 17 years with onychomycosis of the toenails.
`
`
`TRADENAME REVIEW
`
`On March 29, 2014, the applicant was notified by the Office of Medication Error Prevention and
`Risk Management that the proposed tradename “Jublia” was acceptable.
`
`
`
`Reference ID: 3519748
`
`4
`
`
`
`---------------------------------------------------------------------------------------------------------
`This is a representation of an electronic record that was signed
`electronically and this page is the manifestation of the electronic
`signature.
`---------------------------------------------------------------------------------------------------------
`/s/
`----------------------------------------------------
`
`JULIE G BEITZ
`06/05/2014
`
`Reference ID: 3519748
`
`