CENTER FOR DRUG EVALUATION AND

RESEARCH

APPLICATION NUMBER:

208437Orig1s000

NON-CLINICAL REVIEW(S)
 Pharmacology and Toxicology Secondary Review for NDA 208437

Date: May 18, 2017

To: NDA 208437

Lonhala Magnair (Glycopyrrolate) inhalation solution for nebulization
using the PARI eFlow nebulizer
Sunovion Respiratory Development, Inc.

From: Carol M. Galvis, PhD

Acting Pharmacology and Toxicology Team Leader
Division of Pulmonary, Allergy, and Rheumatology Products (DPARP)

Recommendation
I concur with Dr. L. S. Leshin’s review dated April 25, 2017 that recommended approval
of NDA 208437 from the nonclinical pharmacology and toxicology perspective. There
are no outstanding nonclinical issues.

Background
Sunovion Respiratory Development, Inc. submitted a 505(b)(2) NDA 208437 on July 29,
2016, for Lonhala Magnair, a glycopyrrolate inhalation solution for oral inhalation via
nebulization using the PARI eFLow Closed System (CS) nebulizer. The proposed
indication is for the long-term maintenance treatment of airflow obstruction in patients
with chronic obstructive pulmonary disease (COPD), including chronic bronchitis and/or
emphysema.

Sunovion is relying on the nonclinical safety information from previously approved

glycopyrrolate products (Robinul Tablets under NDA 12-827, Robinul Injection under
NDA 17-558, and Cuvposa Oral Solution under NDA 22-571). To support the inhalation
route of administration, the applicant conducted inhalation toxicology studies in rats (1-
month and 6-month studies) and dogs (1-month study). However, during development
of this product, other glycopyrrolate products for inhalation were approved, including
Seebri Neohaler (under NDA 207923), which is now owned by Sunovion. Therefore, the
nonclinical information discussed below and used for NDA 208437 labeling purposes
was obtained from the Seebri Neohaler approved label (October 2015).

Summary of Pharmacology and Toxicology Data

Glycopyrrolate is a long-acting muscarinic antagonist which is often referred to as an
anticholinergic. It has similar affinity to the subtypes of muscarinic receptors M1 to M5.
In the airways, it exhibits pharmacological effects through inhibition of M3 receptor at the
smooth muscle leading to bronchodilation.

The applicant submitted inhalation toxicology studies in rats (1-month and 6-month
studies) and dogs (1-month study). No new toxicities were identified in these studies.
Because the proposed dose (25 mcg BID via nebulization - actually delivers
approximately 56.8% of this dose, or approximately 14.2 mcg BID) is similar to the
approved dose of Seebri Neohaler (15.6 mcg BID), it was not necessary to review these
studies to support safety of this new product.

Labeling

Reference ID: 4099912

 The nonclinical sections of the drug label (Section 8, Section 12.1, and Section 13)
followed the approved label of Seebri Neohaler. For Section 8, the Pregnancy and
Lactation Labeling Rule (PLLR) format was followed. The final language for the
nonclinical sections of the label was discussed with the applicant during this review
cycle. The Division and Sunovion reached agreement for these sections of the label.

Reference ID: 4099912

 ---------------------------------------------------------------------------------------------------------
This is a representation of an electronic record that was signed
electronically and this page is the manifestation of the electronic
signature.
---------------------------------------------------------------------------------------------------------
/s/
----------------------------------------------------
CAROL M GALVIS
05/18/2017

Reference ID: 4099912

 DEPARTMENT OF HEALTH AND HUMAN SERVICES
PUBLIC HEALTH SERVICE
FOOD AND DRUG ADMINISTRATION
CENTER FOR DRUG EVALUATION AND RESEARCH

PHARMACOLOGY/TOXICOLOGY NDA/BLA REVIEW AND EVALUATION

Application number: 208437

Supporting document/s: 2
Applicant’s letter date: July 29, 2016
CDER stamp date: July 29, 2016
Product: SUN-101, Glycopyrrolate Inhalation Solution
Indication: Treatment of airflow obstruction in patients with
chronic obstructive pulmonary disease (COPD)
including chronic bronchitis and/or emphysema.
Applicant: Sunovion Respiratory Development, Inc.
Review Division: DPARP
Reviewer: L.S. Leshin, D.V.M., Ph.D.
Acting Team Leader: Carol Galvis, Ph.D.
Division Director: Badrul A. Chowdhury, M.D., Ph.D.
Project Manager: Sadaf Nabavian
Template Version: September 1, 2010
Disclaimer

Except as specifically identified, all data and information discussed below and
necessary for approval of NDA 208437 are owned by Sunovion Respiratory
Development, Inc. or are data for which Sunovion Respiratory Development, Inc. has
obtained a written right of reference. Any information or data necessary for approval of
NDA 208437 that Sunovion Respiratory Development, Inc. does not own or have a
written right to reference constitutes one of the following: (1) published literature, or (2)
a prior FDA finding of safety or effectiveness for a listed drug, as reflected in the drug’s
approved labeling. Any data or information described or referenced below from reviews
or publicly available summaries of a previously approved application is for descriptive
purposes only and is not relied upon for approval of NDA 208437.

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TABLE OF CONTENTS

1 EXECUTIVE SUMMARY ......................................................................................... 5

1.1 INTRODUCTION .................................................................................................... 5
`1.2 BRIEF DISCUSSION OF NONCLINICAL FINDINGS ...................................................... 5
1.3 RECOMMENDATIONS ............................................................................................ 6
2 DRUG INFORMATION .......................................................................................... 13
2.1 DRUG ............................................................................................................... 13
2.2 RELEVANT INDS, NDAS, BLAS AND DMFS ......................................................... 14
2.3 DRUG FORMULATION ......................................................................................... 16
2.4 COMMENTS ON NOVEL EXCIPIENTS ..................................................................... 16
2.5 COMMENTS ON IMPURITIES/DEGRADANTS OF CONCERN ....................................... 16
2.6 PROPOSED CLINICAL POPULATION AND DOSING REGIMEN .................................... 18
2.7 REGULATORY BACKGROUND .............................................................................. 18
3 STUDIES SUBMITTED .......................................................................................... 20
3.1 STUDIES REVIEWED ........................................................................................... 20
3.2 STUDIES NOT REVIEWED ................................................................................... 20
3.3 PREVIOUS REVIEWS REFERENCED...................................................................... 21
4 PHARMACOLOGY ................................................................................................ 21
5 PHARMACOKINETICS/ADME/TOXICOKINETICS .............................................. 21
6 GENERAL TOXICOLOGY ..................................................................................... 23
6.1 SINGLE-DOSE TOXICITY ..................................................................................... 23
6.2 REPEAT-DOSE TOXICITY .................................................................................... 23
7 GENETIC TOXICOLOGY ...................................................................................... 23
8 CARCINOGENICITY ............................................................................................. 23
8 REPRODUCTIVE AND DEVELOPMENTAL TOXICOLOGY ................................ 23
10 SPECIAL TOXICOLOGY STUDIES ................................................................... 23
11 INTEGRATED SUMMARY AND SAFETY EVALUATION ................................. 24
12 APPENDIX/ATTACHMENTS ............................................................................. 26

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Table of Tables
Table 1: Glycopyrrolate Related Impurities (from Applicant’s Table 12) ....................... 17
Table 2: References Supporting the 505(b)(2) NDA .................................................... 19
Table 3: SUN-101 Toxicology Studies (from Applicant’s Table 1, Module 2) ............... 23
Table 4: Nonclinical Safety Margins for Lonhala Magnair ............................................ 24

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Table of Figures
Figure 1: Metabolism of Glycopyrrolate ........................................................................ 22

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1 Executive Summary
1.1 Introduction
This NDA is for a drug and device combination product consisting of SUN-101
(glycopyrrolate) Inhalation Solution with a PARI eFlow Closed System (CS) nebulizer.
It is indicated for the long-term maintenance treatment of airflow obstruction in
patients with chronic obstructive pulmonary disease (COPD) including chronic
bronchitis and/or emphysema. The tradename, Lonhala Magnair, was submitted to
IND 110,663 on January 29, 2016 and accepted May 27, 2016. Lonhala refers to the
drug product, glycopyrrolate, and Magnair refers to the PARI eFlow CS nebulizer
system. The drug-device combination was developed under IND 110,663 by
Elevation Pharmaceuticals Inc. (submitted on April 13, 2011). The company’s name
was later changed to Sunovion Respiratory Development Inc. (SD-20, September 5,
2012).

Glycopyrrolate is a long-acting, cholinergic muscarinic antagonist that is approved in

liquid formulations for intravenous, intramuscular, and oral administration. Inhalation
formulations of dry powder and aerosols are also approved. This would be the first
nebulized glycopyrrolate product. The proposed dose is 25 mcg twice daily.

The Applicant is pursuing a 505(b)(2) NDA pathway, relying on nonclinical safety

information from previous glycopyrrolate NDAs to support their application and
labeling. The nonclinical information relies on previously demonstrated safety from
approved products Robinul Injection (NDA 17-558), Robinul Tablets (NDA 12-827),
and Cuvposa oral solution (NDA 22-571). The Applicant conducted additional
inhalation toxicology studies to support the new inhalation route of administration.
However, during development of SUN-101 Inhalation Solution, other inhalation
glycopyrrolate products were approved, lessening the essential need for the
Applicant’s nonclinical inhalation studies. These products were formulated as a dry
powder (Seebri Neohaler; NDA 207923), dry powder in combination with indacaterol
(Utibron Neohaler; NDA 207930), and an aerosol in combination with formoterol
fumarate (Bevespi Aerohaler NDA 208294). Furthermore, during the NDA review
cycle, the Applicant notified the FDA on March 16, 2017 (SD-15) that they acquired
ownership of Seebri Neohaler on January 27, 2017. Utibron Neohaler was also
acquired, effective January 27, 2017. The Applicant now owns data that supported
the approval of these two 505(b)(1) applications, but in the current NDA is
requesting approval of a nebulizer, a different drug delivery device. However, as
noted below, significant issues were found by the CDRH review of the device that will
affect approval of this application.
`1.2 Brief Discussion of Nonclinical Findings
Due to the reliance on previously approved glycopyrrolate products for safety
through the 505(b)(2) NDA pathway, few nonclinical studies were submitted. The
nonclinical program consisted of 1-month repeated-dosing inhalation studies in rats
and dogs, followed by a 6-month repeated-dosing inhalation study in rats. The
applicant acquired ownership of Seebri Neohaler on January 27, 2017 (during the
application review period), and could rely solely on that data to support the safety of
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glycopyrrolate for the inhalation route of administration. The Applicant’s nonclinical

inhalation toxicity studies, conducted prior to approval of any inhalation product for
glycopyrrolate, produced results that were generally similar to those approved
products.

The toxicities in the rat associated with inhaled glycopyrrolate in 1- and 6-month
studies included reduced body weight and food intake; dilated pupils; increased red
blood cell counts, hemoglobin, and hematocrit; increased lung weight associated
with alveolar macrophages; laryngeal inflammation; and increased porphyrin
secretion of the Harderian gland. The following findings were observed in the 1-
month inhalation study in dogs: dilated pupils, dry mouth, reduced body weight and
food consumption, emesis, and thymus atrophy with a reduction in thymus weights.
All these effects were partly or completely reversible during a recovery phase. Two
impurities of the drug substance, α-cyclopentylmandalic acid (CPMA) and benzoic
acid, were also assessed for safety. Neither of these compounds were detected in
the drug substance (Batch 2017234) used in the 6-month inhalation study and these
were not tested for their presence in the earlier drug substance (Batch
GCP/013/2009-2010) used in the 1-month inhalation studies in rats and dogs.

CPMA is also a major human metabolite of glycopyrrolate formed upon hydrolysis of

glycopyrrolate (corresponding to metabolite M9). CPMA lacks glycopyrrolate’s
pharmacological profile, but its potential pharmacology and toxicity is unknown. It is
also present in the mouse, rat, rabbit, but there is no animal data concerning the
quantitative levels or bioactivity. The safety of CPMA is confounded with the safety of
glycopyrrolate due to CPMA’s unavoidable presence as a metabolite in humans.
Benzoic acid is a potential oxidative degradant that was formed in forced degradation
studies. These two compounds lack mutagenic structural alerts and are negative in
genotoxic tests. While the systemic safety of CPMA is established, the local safety
from inhalation of CPMA has not been established and the specifications were
reduced from those proposed by the Applicant to those requested by the CMC
(b) (4)
reviewer to NMT % for both compounds.
1.3 Recommendations
1.3.1 Approvability

The application may be approved from the nonclinical perspective.

1.3.2 Additional Non Clinical Recommendations

None

1.3.3 Labeling

The Applicant’s proposed label sections containing or supported by nonclinical

information are presented below. For each section, the Applicant’s label is presented,
followed by the Reviewer’s recommended changes and explanation for the changes.
During the review period, the applicant acquired Seebri Neohaler, an approved
glycopyrrolate inhalation product. Therefore, the proposed label was modified to
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resemble the label for Seebri Neohaler where possible. Additions to the Applicant’s
label are indicated by underlining, and deletions are indicated by strikeouts. An
agreement was reached with the applicant during this review cycle for these labeling
sections.

FULL PRESCRIBING INFORMATION: CONTENTS*

(b) (4)

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 NDA 208437 Reviewer: L.S. Leshin
(b) (4)

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 Reviewer Recommended Changes (based on current labeling practices)

(b) (4)

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(b) (4)

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 Applicant’s Proposed Label

12.1 Mechanism of Action

Glycopyrrolate is a long-acting muscarinic antagonist, which is often referred to
as an anticholinergic. It has similar affinity to the subtypes of muscarinic
receptors M1 to M5. In the airways, it exhibits pharmacological effects through
inhibition of M3 receptor at the smooth muscle leading to bronchodilation. The
competitive and reversible nature of antagonism was shown with human and
animal origin receptors and isolated organ preparations. In preclinical in vitro
as well as in vivo studies, prevention of methacholine and acetylcholine
induced bronchoconstrictive effects was dose-dependent and lasted longer
than 24 hours. The clinical relevance of these findings is unknown. The
bronchodilation following inhalation of glycopyrrolate is predominantly a site-
specific effect.

 Reviewer Recommended Changes

• No changes were recommended at this time, since this language resembles

the Seebri Neohaler label, and this is considered appropriate.

13 NONCLINICAL TOXICOLOGY

 Applicant’s Proposed Label

13.1 Carcinogenesis, Mutagenesis, Impairment of Fertility

(b) (4)

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(b) (4)

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(b) (4)

2 Drug Information
2.1 Drug
CAS Registry
596-51-0
Number
Glycopyrrolate
Generic Name
Glycopyrronium Bromide
Code Name SUN-101
Pyrolidinium,
Chemical Name 3-[(cyclopentylhydroxyphenylacetyl)oxy]-1,1-dimethyl-bromide,
3-Hydroxy-1,1-dimethylpyrrolidinium bromide α
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cyclopentylmandelate
C19H28BrNO3
Molecular Formula / 398.33
Molecular Weight Salt free form known as glycopyrronium free base MW = 318.43
and is the active moiety.
Glycopyrrolate contains two chiral centers and is a racemate of a
1:1 mixture of the R,S and S,R diastereomers (also known as
(b) (4)
threo diastereomers).
The active moiety, glycopyrronium, is the free
base form of glycopyrrolate, both R,S and S,R diastereomers are
pharmacologically active.

Structure or
Biochemical
Description

Pharmacologic
Muscarinic receptor antagonist (anticholinergic)
Class

2.2 Relevant INDs, NDAs, BLAs and DMFs

IND 110663, glycopyrrolate inhalation solution, Sunovion (formerly Elevation
Pharmaceuticals Inc.), submitted April 13, 2011
(b) (4)
DMF
DMF
DMF

Glycopyrrolate-Containing Products (excluding ANDAs)

NDA #, Owner Brand Name Route Indication Approved
Glycopyrrolate
Oral tablets
12827 1 mg/tablet
Robinul and Adjunctive therapy for treatment
(Casper (Robinul) 1961
Robinul Forte of peptic ulcers
Pharm) and 2 mg/tablet
(Robinul Forte)
14764
AH Robins Co.
0.2 mg/mL
Discontinued Robinul Information unavailable 1967
injection
marketing
1982
17558 Robinul IM or IV injection In Anesthesia 1975
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West Ward Injection Up to 8 use preoperative:

Pharms Int mg/day(0.2 • to reduce salivary,
mg/mL) tracheobronchial, and
pharyngeal secretions
• to reduce the volume and free
acidity of gastric secretions
• to block cardiac vagal
inhibitory reflexes during
induction of anesthesia and
intubation
used intraoperatively
• to counteract surgically or
drug-induced or vagal reflexes
associated arrhythmias
• protects against the peripheral
muscarinic effects (e.g.,
bradycardia and excessive
secretions) of cholinergic
agents such as neostigmine
and pyridostigmine given to
reverse the neuromuscular
blockade due to non-
depolarizing muscle relaxants
In Peptic Ulcer
• adjunctive therapy for the
treatment of peptic ulcer when
rapid anticholinergic effect is
desired or when oral
medication is not tolerated.
Oral solution for
ingestion,
3 mg
glycopyrrolate,
three times daily Treatment of severe drooling in
22571
(9 mg per day), secondary to cerebral palsy and
Shionogi Inc. Cuvposa 2010
Daily other neurodevelopmental
administration deficits
over an indefinite
period, resulting
in chronic
exposure
long-term maintenance
207923
treatment of airflow obstruction
Sunovion Seebri Inhalation
in patients with chronic
(previously Neohaler 15.6 mcg BID = 2015
obstructive pulmonary disease
Novartis) (NVA237) 31.2 mcg/day
(COPD).including chronic
bronchitis and/or emphysema
Combinations with glycopyrrolate for inhalation
207930
Sunovion Utibron long-term, maintenance
since Jan 27 Neohaler treatment of airflow obstruction
2017 dry powder in Inhalation in patients with chronic 2015
(previously combination obstructive pulmonary disease
Novartis) with indacatrol (COPD), including chronic
bronchitis and/or emphysema

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Table 1: Glycopyrrolate Related Impurities (from Applicant’s Table 12)

CPMA is also a major human metabolite of glycopyrrolate and if formed upon

hydrolysis of glycopyrrolate (corresponding to metabolite M9). It was extensively
studied for NDA 207923, but those reports were not reviewed for its approval. Briefly,
CPMA lacks glycopyrrolate’s pharmacological profile, but its potential pharmacology
and toxicity has not been studied. It is present in the mouse, rat, rabbit, but there is
no animal data concerning the quantitative tissue or blood levels, or its potential
bioactivity. The safety of CPMA is confounded with the safety of glycopyrrolate due to
CPMA’s unavoidable presence as a metabolite in humans. Glycopyrrolate has not
been used extensively as a continuous daily medication, and has only been marketed
as an inhalation formulation since 2015. Given the above lack of data, local
respiratory tract safety from inhalation of CPMA has not been established for CPMA.
(b) (4)
The Applicant proposed CPMA specification limit of NMT % at release and NMT
(b) (4)
% for the shelf life. On January 11, 2017, in response to a December 23, 2016
Request for Information, the Applicant provided a revised release specification of
(b) (4) (b)
% and a shelf-life specification for this impurity of NMT(4) % as described in ICH
Q3B(R2), due to the fact that the evidence to support a higher shelf life specification
was applicable to systemic exposure, but lacked evidence for safety due to direct
inhalation. CPMA was not measured in as a drug deposition compound in animal
inhalation toxicity studies. This revised specification is considered acceptable.

Benzoic acid is a potential oxidative degradant that was formed in forced degradation
studies. Specification limit for benzoic acid and individual unspecified impurity (NMT
(b) (4)
%) is the identification threshold recommended by ICH Q3B(R2) for drug product
degradants.
Refer to the CMC Review for additional information concerning impurities.

eFlow CS Nebulizer Drug Delivery Device

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The drug/device combination product will be provided in two commercial

configurations:
1. Starter Kit: SUN-101 drug product (30 day twice daily supply) with a
complete nebulizer kit and nebulizer accessories.
2. Refill Kit: SUN-101 drug product (30 day twice daily supply) with a handset
and handset components (including aerosol head).
The Starter Kit is intended for new patients with the Refill kit to be subsequently
supplied every 30 days.

The device aerosol head, nebulizer chamber, blue inhalation valve, inside of the
mouthpiece, inside of the top and bottom of the handset, and medication cap are
permanent exposure, external communicating components (tissue, bone dentin). The
outside of the mouthpiece is a permanent exposure, surface-mucosal membrane
contact component. The mouthpiece is used in the FDA-cleared LC Sprint Nebulizer
(510(k) K060399) and is used in the eFlow CS without modification and was therefore
not further tested.

Biocompatibility testing was reviewed by CDRH and a number of concerns with the
methods and results were identified. Ongoing communication between the Applicant
and CDRH reviewer have not yet resolved the issues. The originally submitted
conclusions identifying potential leachables and extractables and analysis of their
potential toxicity is currently incomplete. Refer the CDRH reviews for additional
information.

2.6 Proposed Clinical Population and Dosing Regimen

Lonhala Magnair is indicated for the long-term maintenance treatment of airflow
obstruction in patients with chronic obstructive pulmonary disease (COPD), including
chronic bronchitis and/or emphysema. The recommended dose is the inhalation of
the contents of one Lonhala vial (25 mcg glycopyrrolate) twice-daily, once in the
morning and once in the evening, using Magnair.
2.7 Regulatory Background
The Applicant is pursuing a 505(b)(2) NDA pathway, relying on nonclinical safety
information from previous glycopyrrolate NDAs to support their application and
labeling. Lonhala Magnair drug-device combination was developed under IND
110,663, submitted on April 13, 2011. The original sponsor, Elevation
Pharmaceuticals Inc, notified the Division on September 5, 2012 (SD-20) that the
corporate name was changed to Sunovion.

At the Pre-IND meeting held on March 2, 2011, there was some discussion
concerning appropriate study species and design for long term inhalation toxicity
study to support the clinical program. Also discussed was the support needed to
initiate clinical dose-response studies. The IND was submitted on April 13, 2011 and
allowed to proceed. At the time of the IND submission, inhalation of glycopyrrolate
was a new route of administration and clinical studies were supported for respiratory

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tract safety by nonclinical inhalation toxicity studies in the rat and dog of 1-month
duration. This was followed by a 6-month inhalation toxicity study in the rat.

The nonclinical support also relied on systemic and organ safety previously
established for oral and intravenous routes of administration from approved products
Robinul Injection (NDA 17-558), Robinul Tablets (NDA 12-827), and Cuvposa oral
solution (NDA 22-571). However, during development of SUN-101 Inhalation
Solution, other inhalation glycopyrrolate products were approved, lessening the need
for the applicant’s nonclinical inhalation studies. These products had various
formulations, dry powder (Seebri Neohaler; NDA 207923), dry powder in combination
with indacaterol (Utibron Neohaler; NDA 207930), and an aerosol in combination with
formoterol fumarate (Bevespi Aerohaler NDA 208294). Toward the end of the review
process, the Division was notified (SD-15, March 16, 2017) that the applicant
acquired ownership of Seebri Neohaler effective January 27, 2017.

Due to the reliance on the safety of glycopyrrolate in these approved products for
safety through the 505(b)(2) pathway, it was unnecessary to review additional
nonclinical studies supporting Lonhala Magnair. The following sponsor’s table
indicates the sources of information supporting nonclinical safety of glycopyrrolate.

Table 2: References Supporting the 505(b)(2) NDA

Source of Information Information Provided
Listed Drugs
NDA 17-558 Robinul Injection Clinical Metabolism and Excretion
Secondary Pharmacodynamics
Excretion
Single-Dose Toxicity
Reproductive and Developmental Toxicology
Nonclinical Overview and Brief Summaries
NDA 12-827 Robinul Tablets Nonclinical Overview and Brief Summaries
NDA 22-571 Cuvposa oral Solution Repeat-Dose Toxicity
Genotoxicity
Nonclinical Overview and brief summaries
NDA 207923 Seebri Neohaler (EMA- Clinical Distribution
european product) SUN-101 Package Insert

Note: The applicant now owns the Seebri

Neohaler data, a 505(b)(1)

Published Literature
Casarosa 2009; Haddad 1999; Villetti Primary pharmacodynamics
2006; Trifilieff

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EMA/CHMP/508029/2012 (Seebri Secondary Pharmacodynamics

Breezehaler) Safety Pharmacology
Absorption, Distribution, Metabolism,
Note: The applicant now owns the Seebri Excretion
Neohaler data, a 505(b)(1) Repeat-Dose Toxicity
Genotoxicity
Carcinogenicity
Reproductive and Developmental Toxicology
Nonclinical Overview and Brief Summaries

PMDA Report on the Deliberation results Absorption

for Seebri Inhalation Capsules 50 mcg Metabolic Pathway
(Seebri Breezhaler) Distribution
Drug Interaction
Note: The applicant now owns the Seebri Nonclinical Overview and Brief Summaries
Neohaler data, a 505(b)(1)

Proakis 1978 Distribution

Franko 1970 Single-dose toxicity
Repeat-dose toxicity
Reproductive and Developmental Toxicology
Local Tolerance
Bartels 2013 Clinical Absorption

3 Studies Submitted
3.1 Studies Reviewed

Report Number Title Previous

Review
General Toxicology
Rat
101802A1 28-Day Inhalation Toxicity Study of EP-101 in Rats IND 110663,
With a 14-Day Recovery Period May 13, 2011
Dog
101803A1 28-Day Inhalation Toxicity Study of EP-101 in Dogs IND 110663,
with a 14-Day Recovery Period May 13, 2011
Impurities
101-805 Toxicological Qualification of a-Cyclopentylmandelic
Acid to Support a Specification Limit in an Inhalation
Drug Product
101-806 Toxicological Assessment of Alkanes and Alkenes as
Potential Leachables in lnhalation Drug Products

3.2 Studies Not Reviewed

Report Number Title
101-500 The Method Validation and Stability Determination of
a Liquid Chromatography-Mass Spectrometry
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Method for the Determination of Glycopyrrolate in

Dog and Rat Plasma
101-800 Dose Escalation and 7-Day Inhalation Toxicity Study
of EP-101 in Rats
101-804 6-Month Inhalation Toxicity and Toxicokinetic Study
of EP-101 in Rats with a 3-Month Recovery Period
101-801 Dose Escalation and 7-Day Inhalation Toxicity Study
of EP-101 in Dogs

3.3 Previous Reviews Referenced

These reviews are attached in the Appendix.

IND 110,663, Elevation Pharmaceuticals, Inc., May 13, 2011, Initial Safety Review by
Dr. Kathleen Young
IND 110,663, Elevation Pharmaceuticals, Inc., June 14, 2011, Impurity consult for
CPMA and benzoic acid by Dr. Kathleen Young

4 Pharmacology
The Applicant did not conduct pharmacology studies. The information below is from
studies conducted for Seebri Neohaler (NDA 207923) for which the Applicant
acquired ownership during the current review period.

Glycopyrrolate is a long-acting competitive cholinergic muscarinic receptor

antagonist. It has similar affinity to muscarinic receptor subtypes M 1 to M 5 . It inhibits
acetylcholine activity at sites innervated by postganglionic cholinergic nerves and on
cholinergic sensitive smooth muscles. Acetylcholine from vagal nerve stimulation
activates muscarinic receptors on smooth muscle cells, resulting in
bronchoconstriction. In the airways, inhibition of these muscarinic receptors by
glycopyrrolate results in bronchodilation. Its long duration of action for inducing
bronchial dilation is due to its slow dissociation kinetics from the M 3 receptor,
prevalent in the lower respiratory tract. At the human M 3 receptor, the [3S,2R]
enantiomer has greater biological activity (~100 times) than [3R,2S] enantiomer.
Glycopyrrolate also reduces the volume and free acidity of gastric secretions and
secretions from the pharynx, trachea, and bronchi. Also affected by inhibition of
muscarinic activity are cardiac muscles of the sinoatrial node and the atrioventricular
node, exocrine glands and autonomic ganglia.

5 Pharmacokinetics/ADME/Toxicokinetics
The applicant did not conduct ADME Studies. Nonclinical toxicokinetics for
glycopyrrolate were obtained for the 1-month inhalation toxicity studies in the rat and
dog and the 6-month inhalation toxicity rat study.

Pertinent to the presence of the major metabolite of CPMA in human plasma are
animal studies conducted for the approval of Seebri Neohaler (NDA 207923, currently
owned by the Applicant) that were not previously reviewed. Major points of those
studies are presented briefly below.

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Glycopyrrolate is metabolized mainly in blood to CPMA by Phase 1 hydroxylations.

Butyrylcholinesterases and acetylcholinesterases are involved in the ester hydrolysis.
While there may be interconversion among the enantiomers, both are cleared at
approximately similar rates. The metabolism of radiolabeled glycopyrrolate in human
liver microsomes was very low and no metabolism was found in human lung
microsomes. Liver microsomes of the mouse and rabbit, but not the rat, produced
small amounts of CPMA.

Figure 1: Metabolism of Glycopyrrolate

In a 1-month inhalation toxicity study in rats, glycopyrrolate was spiked with 9.8%
CPMA formulated as a powdered aerosol. Dose groups consisted of vehicle control,
0.13 mg/kg and 0.38 mg/kg spiked with CPMA, and 0.56 mg/kg glycopyrrolate only.
Similar responses were seen across treatment groups, with the main
histopathological finding of increased goblet cells in the nasal cavity and sinuses, and
squamous metaplasia and epithelium hyperplasia in the larynx. There were no
obvious local toxicological effects between inhaled glycopyrrolate with or without
spiked CPMA. CPMA was negative in the Ames mutagenicity and chromosome
aberration tests. The absence of a longer inhalation study, 3-months, with CPMA
spiked dosing, hindered the acceptance of the Applicant’s higher impurity
(b) (4)
specification (NMT %) for CPMA to extend shelf life.

Another inhalation study determined the toxicokinetics in blood and lung tissue of the
rat after 1-month of daily inhalation of 0.1 mg/kg/day of glycopyrrolate.
Concentrations of glycopyrrolate on day 1 and day 18 were 1800-fold and 3400-fold
higher in the lung than in plasma, respectively. There was no accumulation in plasma
over the 28 days, however lung accumulation varied from 1.7- to 2.8-fold over this
period. Lung terminal clearance was 20 hours in males and 26 hours in females,
plasma concentrations were not detectable 24 hours after the last dose.

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• decreased
implantation
sites
• reduction of
live fetuses

NOAEL: 388
Rat inhalation 1521X
EmbryoFetal 3.8 mg/kg/day ng-h/mL
Development NOAEL: 148
Rabbit inhalation 580X
4.4 mg/kg/day ng-h/mL

Pre-and NOAEL:
290 ng-
Post-Natal Rat subcutaneous 1.88 mg/kg/day 1137X
h/mL
Development

Rat: 2- M and F: 0.56 36.45

inhalation 143X
year mg/kg/day ng-h/mL
M: 93.8
Carcinogenicity Mouse: M and F
mg/kg/day,
Tg.rasH2 oral gavage 16.8 66X
F: 125.1
6-month ng-h/mL
mg/kg/day
1
Nonclinical studies used for the calculation of exposure margins were conducted to support
Seebri Neohaler (NDA 207923, now owned by the Applicant).
2
Exposure margins were calculated as animal dose/human dose (25 mcg, BID, or 50 mcg/day).
The AUC 0-24 value for human therapeutic dosing was obtained from study SUN 101-201, in which
an AUC 0-12 was 255 pg/hr/mL, for a single 50 mcg dose. For a 25 mcg, BID dose in a linear
dose-AUC relationship, the AUC0-24 was 255 pg-h/mL.

Two impurities of the drug substance, α-cyclopentylmandalic acid (CPMA) and

benzoic acid, were also assessed for safety. Neither of these compounds were
detected in the drug substance (Batch 2017234) used in the 6-month inhalation study
and these were not tested for their presence in the earlier drug substance (Batch
GCP/013/2009-2010) used in the 1-month inhalation studies in rats and dogs.

CPMA is also a major human metabolite of glycopyrrolate and if formed upon

hydrolysis of glycopyrrolate. CPMA lacks glycopyrrolate’s pharmacological profile,
but its potential pharmacology and toxicity is unknown. It is also present in the
mouse, rat, rabbit, but there is no animal data concerning the quantitative levels or
bioactivity. The safety of CPMA is confounded with the safety of glycopyrrolate due to
CPMA’s presence as a metabolite in humans. Benzoic acid is a potential oxidative
degradant that was formed in forced degradation studies. Neither compound has
mutagenic structural alerts. While the systemic safety of CPMA is established, the
local safety from inhalation of CPMA has not been established and the specifications
were reduced from those proposed by the Applicant to those requested by the CMC
(b) (4)
reviewer to NMT % for both compounds.

The drug deliver nebulizer device was subject to review by CDRH. There were a
number of concerns with the methods and results obtained for biocompatibility testing
that have not yet been adequately resolved, and these issues may result in a
Complete Response action for this NDA. However, at this time there are no safety
issues with the API, glycopyrrolate. Pending resolution of the biocompatibility testing

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and absence of any related compounds that would affect safety, the application may
be approved from the pharmacology and toxicology perspective.

12 Appendix/Attachments
Two Pharmacology and Toxicology Reviews by Dr. Kathleen Young for the
development of SUN-101 under IND 110,663 are included as Attachments. They are
reviews dated May 13, 2011 and June 14, 2011.

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Department of Health and Human Services

Public Health Service
Food and Drug Administration
Center for Drug Evaluation and Research

PHARMACOLOGY/TOXICOLOGY IND REVIEW AND EVALUATION

IND number: 110663

Sponsor: Elevation Pharmaceuticals, Inc.

Submission Type: Initial IND Submission

Supporting Doc Category/Subcategory: SDN 000; SDN 002

Submission Date/Receipt: April 13, 2011/April 14, 2011; May 11, 2011

Drug Substance: Glycopyrrolate Inhalation Solution (GIS)

Division name: Division of Pulmonary, Allergy, and Rheumatology Products

Review completion date: May 8, 2011

Reviewer name: Kathleen Young, Ph.D.

Pharmacology/Toxicology Supervisor: Timothy W. Robison, Ph.D. for Molly E.

Topper, Ph.D.

Division Director: Badrul Chowdhury, M.D., Ph.D.

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TABLE OF CONTENTS

PHARMACOLOGY/TOXICOLOGY IND REVIEW AND EVALUATION ......................... 1

1 EXECUTIVE SUMMARY ......................................................................................... 3

1.1 RECOMMENDATIONS ............................................................................................ 3
1.2 BRIEF DISCUSSION OF NONCLINICAL FINDINGS ...................................................... 3
2 DRUG INFORMATION ............................................................................................ 5

3 STUDIES SUBMITTED............................................................................................ 9
6.2 REPEAT-DOSE TOXICITY .................................................................................... 10
11 INTEGRATED SUMMARY AND SAFETY EVALUATION................................. 32

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1 Executive Summary

1.1 Recommendations

1.1.1 The proposed clinical inhalation study on GIS (# EP-101-03) is reasonably

safe to proceed from a pharmacology and toxicology point of view.

1.1.3 Additional Recommendations: We have the following non-hold

recommendations:

1. Please submit the final study reports for the 28-day inhalation
toxicity studies in rats and dogs (N111001D and N111001E) within
120 days from the initial IND 110,663 submission.

1.2 Brief Discussion of Nonclinical Findings

Glycopyrrrolate is a muscarinic antagonist with potent bronchodilatory activity,

proposed for long-term inhalation treatment of Chronic Obstructive Pulmonary
Disease (COPD) using the newly modified Glycopyrrolate Inhalation System
(GIS) eFlow nebulizer (PARI)

Glycopyrrolate has been used in the US for more than 30 years, and is approved
in IM and IV systemic injection form (Robinul® Injection, IV, IM, NDA 17-558) as
a preoperative antimuscarinic agent. Glycopyrrolate is also approved in oral,
tablet, and ophthalmic and oral solution (NDA 22-571, NDA 089170, NDA
089171, NDA 08410) forms as adjunctive therapy for the chronic treatment of
drooling and peptic ulcer (Robinul® 1 and 2 mg oral tablet, NDA 12-827), with a
maximum recommended dose (MRHD) of 8 mg/day PO.

The Sponsor is proposing to rely on Agency safety findings for the approved
NDAs 17-558 (IV and IM injection) and NDA 12-827 (oral tablet) for the non-
clinical systemic toxicity information to support the safety of the proposed clinical
study on the inhalation product.

The Sponsor’s nonclinical toxicology program is directed toward an assessment

of local toxicity in the respiratory tract. The Sponsor submitted draft (unsigned
GLP) reports of 28-day inhalation toxicology studies with rats and dogs in support
of the proposed clinical trial.

A 28-day glycopyrrolate inhalation toxicity study was conducted in Sprague-

Dawley rats with a 14-day recovery period ( Study N111001D. The rats
(b) (4)

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(n=10/sex/group with 6/sex/group toxicokinetic evaluation and 5/sex/group

recovery group rats) were administered glycopyrrolate by nose-only inhalation
once daily for 28 days at doses of 0, 0.5, 5, and 45 mg/kg/day. There was one
death with unknown relationship to treatment in a high dose male rat on Day 2,
which was replaced immediately in the high dose group. The treatment-related
effects included reversible decreased body weight gain during the 28-day dosing
period, that was statistically significant at the high dose in the males (-66%) and
females (-71%). Ophthalmoscopic examination showed primarily
pharmacodynamic effects of glycopyrrolate, including papillary dilation at the mid-
and high doses, which were reversible during the recovery period. Increased
lung weights (absolute and relative to both body weights and brain weights) were
shown at the mid- and high doses (percent differences from controls in the males
were + 33% and +30%, respectively, and +43% and +47% in the females,
respectively). The increased lung weights might correlate with increased
alvelolar macrophages found in the microscopic examination. The target organs
identified in the histopathology evaluation were the lungs, larynx and Harderian
gland. There were reversible (during recovery) increased lung alveolar
macrophages in terminal bronchioles and adjacent alveoli at all doses, with dose-
related increases in incidence and severity with severity ratings of minimal with
occasional mild. Furthermore, no inflammation or inflammatory cells were found.
The Sponsor suggested that this was supportive of a particle removal function by
the macrophages, representing normal lung function and not an inflammatory
response. There were alterations of the epithelial lining in the larynx from
pseudostratified flattened-to-low cuboidal “cobblestone” morphology to mucosal
epithelium, that was consistent with stratified squamous type/squamous
metaplasia. Laryngeal alterations were observed at all doses. These findings,
commonly observed in inhalation toxicology studies with rats (Osimitz T, et al.
2007). Toxicologic significance of histologic change in the larynx of the rat
following inhalation exposure: A critical review. Toxicology and Applied
Pharmacology 225. 229-237), are attributed to an adaptive response to irritation
and have no relevance to humans. Some (nonreversible at the highest dose)
inflammation was also found in the laryngeal tissue, which included neutrophil
and plasma cell macrophage infiltration of the submucosal glands and/or propria
stroma with increased incidences for males and females in the high dose group.
The NOAEL was 45 mg/kg/day (mean AUC male + female combined 7,255,000
pcg.h/ml) because increased lung alveolar macrophages observed at all doses
were without evidence of inflammation and therefore likely performing an inhaled
drug removal function, and epithelial lining changes in the larynx were without
inflammation, reversible at the low dose, and commonly found in inhalation
toxicity studies in rats.

The 28-day inhalation toxicity study on glycopyrrolate in dogs with 14-day

recovery period (Study N111001E) used 3 dogs/sex/dose main study, and
2/sex/dose recovery evaluation animals. The dogs received glycopyrrolate at
doses of 0, 0.06, 0.6 and 2.4 mg/kg/day by nose-only inhalation, once daily for
approximately 32-53 minute exposures. There was no mortality during the study.

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The clinical signs attributed to treatment included reversible dilated pupils

(pharmacodynamic effect) persisting for up to 3 days during the recovery period,
emesis in some control and low-dose dogs and all mid- and high dose dogs
throughout the treatment period, and dry mouth (pharmacodynamic effect) at the
mid and high doses during the first 10 dosing days. There was a decrease in
body weights in the high dose males that was completely reversible by the end of
the 14-day recovery period; the remaining groups showed body weight gains,
although less than in the controls during treatment and decreased food
consumption was found only in the high dose males. Thymus weight decreases
in the mid dose (-60%) and high dose (-46%) females were reversible during
recovery. The histopathology examination found no treatment-related effects,
including any pulmonary changes. The incidence of thymic atrophy was
increased in male treatment groups but was without dose-related increases in
severity. In the female treatment groups, thymic atrophy incidence was also
found although there was no dose-response relationship. A NOAEL can be
considered to be the low dose of 0.06 mg/kg/day (AUC combined male and
female 19450 pcg.h/ml), based on thymus weight reductions (females).

2 Drug Information
2.1 Drug Glycopyrrolate Inhalation System (GIS, EP-101)

2.1.1 CAS Registry Number: 596-51-0

2.1.2 Generic Name: Glycopyrrolate Inhalation Solution

2.1.3 Code Name: EP 101

2.1.4 Chemical Name: 3-(α-Cyclopentylmandeloyloxy)-1-,1-

dimethylpyrrolidinium bromide

2.1.5 Molecular Formula/Molecular Weight: C19H28BrNO3 / 398.33

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571), and for the chronic treatment of peptic ulcer (Robinul® 1 and 2 mg oral
tablet, NDA 12-827), with a maximum recommended dose (MRHD) of 8 mg/day
PO.

Two Phase 2 single dose studies in COPD patients using the proposed new
inhalation route have been completed by the Sponsor in the United Kingdom. In
Study EP-101, 12 subjects (ages 40-75) received GIS or placebo in a dose
escalation paradigm using the eFlow device at doses of up to 200 mcg QD.
Forty-two subjects (ages 40-75) were administered inhalation doses of 12.5-400
mcg QD vs. placebo in the 6-way crossover study EP-102. The effective dose
for bronchodilation was found to be 25-400 mcg, although no additional benefit
was found above 200 mcg.

3 Studies Submitted

3.1 Studies Reviewed

Report No. N111001D 28-Day Rat Inhalation Toxicity Study

Report No. N111001E 28-Day Dog Inhalation Toxicity Study

3.2 Studies Not Reviewed

Report No. N111001B Single Dose non-GLP Rat Inhalation Toxcitiy Study

Report No. N111001C Single Dose non-GLP Dog Inhalation Toxicity Study

Report N111001B 7-Day non-GLP Rat Inhalation Toxicity Study

Report N111001C 7-Day (non-GLP Dog Inhalation Toxicity Study

6. General Toxicology

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6.2 Repeat-Dose Toxicity

Non-GLP 7-Day dose range-finding and maximum tolerated dose studies were
conducted in rats and dogs for this submission. Rats (n=4-6/sex/dose) were
administered control vehicle or 45 mg/kg/day (calculated dose 44-49 mg/kg/day)
glycopyrrolate over 360 minutes each day for 7 days. The results showed no
deaths. However, labored respiration was observed in 1 treated female on Day
1, reddened eyes in the males and females on Day 5 until the end of the study,
persisting for less that 24 hours on Days 5-7. Body weights were reduced 6%
and 8% in the males and females, respectively over the 7-day treatment period,
but food consumption was reduced in the treated males only. There was a
treatment-related increase in lung and larynx weights (both relative to body and
brain weights) in the females. The histopathology examination identified target
organs as the lungs and larynx in both the males and females given
glycopyrrolate by inhalation. The findings included inflammation of the larynx
with increased infiltrative neutrophils within the submucosa at the base of the
epiglottis, likely due to irritation by the study drug. Also, there was an increase in
alveolar macrophages in the lungs, which were enlarged and showed vacuolation
of cytoplasm. The Day 1 AUClast values in that study were 6110 (males) and
7930 (females) ng.h/ml. The Day 1 AUCinf values were 6700 (males) and 9080
(females) ng.h/ml.

The non-GLP dose range-finding maximum tolerated dose (MTD) study was
conducted for this submission in dogs administered 0 and 2.4 mg/kg/d
glycopyrrolate by nose-only inhalation, once daily for 7 days. There were no
deaths and no effects on clinical pathology, or macroscopic and microscopic
findings. The clinical signs were primarily pharmacodynamic effects and
included mydriasis, dry mouth, emesis and decreased body weights. The Day 7
AUClast values were 331 and 485 ng.h/ml in the males and females,
respectively, and the AUCinf values were 380 in the males and 556 in the
females at the 2.4 mg/kg/day dose.

Pivotal 28-Day Repeat-Dose Inhalation Toxicology Studies for Protocol

Support

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and plasma cell macrophage infiltration of the submucosal glands and/or propria
stroma with increased incidences for males and females in the high dose group..

The NOAEL was 45 mg/kg/day (mean AUC male + female combined 7,255,000
pcg.h/ml) because increased lung alveolar macrophages observed at all doses
were without evidence of inflammation and therefore likely performing an inhaled
drug removal function, and epithelial lining changes in the larynx were without
inflammation, reversible at the low dose, and commonly found in inhalation
toxicity studies in rats.

Estimated Inhaled Dose:

Methods
Doses: 0, 0.5, 5, & 45 mg/kg/day
Frequency of dosing: Once daily for 28 days, using restraint in polycarbonate inhalation exposure tubes
Route of Nose-only inhalation
administration:
Dose volume: Cannon-style rodent nose-only inhalation exposure system average air flow rate of 8.5
L/minute (total system flow rate of 25.5 L/minute) and test atmosphere flow rate of 0.46
L/minute/exposure port
Achieved aerosol concentration results:

Formulation/Vehicle: Vehicle: citric acid, sodium chloride, sterile water for injection adjusted to pH 3.8.
Formulations and stability analyzed (25-day storage)
Particle size distribution (PSD) analysis showed
Species/Strain: Sprague-Dawley CD (SD) Rat
Number/Sex/Group: 10/sex/group
Age: 10-11 weeks at initiation of exposure
Weight: 207.8-407.8 g
Satellite groups: 6/sex/group TK, 5/sex/group 14-Day Recovery
Unique study design: Exposure durations adjusted to deliver target inhalation dose using predicted minute
volume,(Bide’s formula), group mean aerosol concentration (sexes combined), and group
mean body weights (combined sexes)
Deviation from study Staggered start of study, with Day 1 dosing in M beginning one day before Day 1 dosing
protocol: in F.
Day 1: Control F observed for clinical observations 13 minutes early.
Day 29: Clinical observations recorded twice 12
HDM replacement on Day 2 due to death in 1 HDM had no Day BW, food consumption,
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Particle Size Distribution:

Animal study identification:

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Observations and Results

Mortality: Death in 1 HDM Day 2: Animal replaced on Day 2. The

relationship of the death to treatment was questionable.

Clinical Signs
• No treatment-related clinical signs
• Incidental: alopecia in 1 MDF Day 4-29, 1 HDTKM eye opacity Day 7-29,
1 MDTKF eye abnormalities (clear discharge, red discharge, blood
collection trauma)

Body Weights
• Body weight gains were decreased >10% for all male and female
treatment groups. ↓ BWG treatment-related during 28-day dosing phase
significant at the high dose in the males (-66%) and females (-71%).
• No differences from controls after 14-day recovery (reversible)
• The results of the BWG measurements are presented in the following
table from the Sponsor:

• BWG from Day 1-28: -63% in the HDM and -71% in HDF vs. controls
• BWG from Day 28-42: -13% in HDM and -5% in HDF vs. controls
• BWG trends similar in TK rats, although statistically significant in M on Days
22 and 28 vs. controls

The group mean body weights are presented in the following graphs from the Sponsor:

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Food Consumption
• No statistically significant treatment-related effects

Ophthalmoscopy

Methods: pupillary dilation via instillation of 1% Tropicamide Ophthalmic

Solution prior to examination on Day 1 and after 14-day recover, but on Day 28
examination used only in control & vehicle rats, as the MD and HD rats’ pupils
were dilated by treatment

Results:

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• Pupillary dilation at MD and HD at Week 4 evaluation

• Reversible during recovery period
• Pharmacodynamic effect

ECG: Not conducted

Hematology
Percent increases were as follows for the MD and HD male rats (vs. control M,
statistically significant at the HD) in red blood cell parameters as follows:

RBC: +6% (MD and HD)

Hemoglobin: +5% (MD) and +9% (HD)

Hematocrit: + 5% (MD) and +8% (HD)

Percent increases were as follows for the MD and HD female rats (vs. control F,
statistically significant at the HD):

RBC: +2% (MD) and +9% (HD)

Hemoglobin: +3% (MD) and + 9% (HD)

Hematocrit: + 3% (MD) and +10% (HD)

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Hematology changes were reversible during the recovery period.

These changes were not regarded as dose-limiting.

The results of the treatment-related findings in the hematology evaluation are

presented in the following tables from the Sponsor:

Clinical Chemistry & Coagulation:

Methods:

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Results:

No treatment-related effects on coagulation

No effects deemed treatment-related, as differences were small in magnitude, in

one sex only and/or not dose-related

Slight increases in globulin (2.3 g/dL vs. 2.0 in controls, +16.5%), cholesterol
(116 mg/dL vs. 89 mg/dL in controls, + 30%) in main study HDF

Urinalysis: Not conducted. There were no histopathological findings in the

kidneys. Further, the systemic toxicity of glycopyrrolate has been characterized
by other routes that produced higher exposures.

Gross Pathology:

Methods: The following organs/tissues were examined on Days 29 (Main study)

and 43 (Recovery):

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Results: No treatment-related findings

Organ Weights

↑lung weights (absolute and relative to BW and brain weights) at MD and HD

Respective percent differences from controls were +33% to +44% and +30% to +
42% in the MD and HD males, and +43% to + 48% and +47% to + 57% in the
MD and HD females

There was no effect at 0.5 mg/kg/day

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Day 29 Lung Weight (g) Evaluations

Dose EP-101 (mg/kg/d INH)

0 0.5 5 45

Males (n=10)

Absolute wt. 2.172 2.258 2.895* 2.821*

Relative to 0.549 0.585 0.791* 0.780*

BW (%)

Relative to 107.49 111.13 140.77* 139.66*

brain wt. (%)

Females (n=10)

Absolute 1.669 1.786 2.390* 2.447*

Relative to 0.693 0.767 1.023* 1.091*

BW (%)

Relative to 86.25 94.77 121.78* 129.75*

brain wt. (%)

These changes might correlate with increased alveolar macrophages.

Histopathology

Adequate Battery: Yes: All tissues processed according to SOP for

histopathology

Peer Review: Internal peer performed

Target organs identified: lungs, larynx, and Harderian gland

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↑ lung alveolar macrophages with terminal bronchioles and adjacent alveoli

at all doses

Incidence in controls, LD, MD, and HD, respectively:

1, 3, 6, 6, in M

2, 0, 1, 7 in F

3, 3, 7, 13 combined incidence (M+F)

Macrophages enlarged with finely vacuolated cytoplasm

Severity: minimal, with occasional mild, no increase in severity vs. 7-d study
results

No inflammation/inflammatory cells found (Sponsor suggested this supports

conclusion that macrophage presence represented normal lung function of
particle removal and not inflammatory response

Reversed during recovery

Alteration of epithelial lining in larynx:

From pseudostratified flattened-to-low cuboidal “cobblestone” morphology

(normal) to mucosal epithelium

Incidence in controls, LD, MD, and HD, respectively:

0, 9, 10, and 10 in M

0, 2, 9, and 10 in F

Transformation consistent with stratified squamous type/squamous metaplasia)

in all treated M & F groups

Some inflammation (neutrophil, plasma cell and macrophage infiltration of

submucosal glands and/or propria stroma at HD (M & F)

Incidence in controls, LD, MD, HD, respectively:

1, 0, 0, and 4 in M

2, 0, 0, and 4 in F

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Not reversed during recovery at HD

These findings in the larynx, commonly observed in inhalation toxicology studies

with rats, are attributed to an adaptive response to irritation and have no
relevance to humans.

The results of the laryngeal examinations are presented in the following table
from the Sponsor:

Histopathological findings at the end of the treatment period

Histopathological findings at the end of the recovery period

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Excess porphyrin pigment secretion in Harderian gland in all treated M & F

groups

Associated with glandular alveolar(?) dilatation

Not reversed at MD and HD in M & F

These findings are not relevant to humans.

Toxicokinetics

No sex-related differences except higher t1/2elim and decreased clearance in F

on Day 28

T1/2 terminal long: 4.61-9.91 h on Day 1, 7.59-75.1 h on Day 28 vs. last sample
collection time point at 18 h

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Effect of repeated dosing (Day 28 vs. Day 1):

Cl lower on Day 28

T1/2 elim longer in all groups with the exception that effects in male treatment
groups were relatively small compared to female treatment groups (4X longer or
more

↑ AUCinf (accumulation) in all groups

↑AUClast at MD (M & F) but not at LD or HD

The results of the toxicokinetic evaluation are presented in the following table,
from the Sponsor;

Day 1

Day 28

Stability and Homogeneity:

Formulations found within 1.2% target solution concentrations

Stability analysis found formulations within 10% of respective target

concentrations

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Methods
Doses:

Frequency of dosing: Once daily (32-53 minute exposures) for 28 consecutive days
Route of Nose only inhalation using mask with plenum exposure system providing
administration: fresh test atmosphere independent from other animals; dose adjusted using
predicted minute volume (Bide’s formula 0.499 X combined sex group mean
BW kg)0.089), group mean aerosol concentration (combined sexes), and actual
group mean body weight (combined sexes)
Dose volume:

Formulation/Vehicle: Citric acid, sodium chloride, sterile water for injection, pH adjusted to 3.8
Species/Strain: Beagle dog
Number/Sex/Group: 3/sex/dose main study dogs
Age: 8-9 months
Weight: 9.3-11.5 kg
Satellite groups: 2/sex/dose for the 14-day recovery evaluation; All dogs underwent TK
sampling on Days 1 and 28
Unique study design: Dogs were restrained using inhalation restraint device and harness.
Formulations analyzed and stability analysis conducted on 0.25 and 10 mg/ml
formulations after 25 days storage at room temperature.
Aerosol generation and exposure systems performed as intended, with aerosol
concentrations stable over time.
Gravimetric particle size distribution (PSD) appropriate for dog INH model at

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1.9-2.5 mcm mass median aerodynamic diameter (MMAD). Estimated INH

dose/% target summarized below:

Deviation from study -Ophthalmic examinations and clinical pathology assessments added during
protocol: recovery period
-Additional deviations minor and did not affect the validity of the study (e.g. 1
MDM received clinical observation 4 minutes late, the first formulation was
validated on same day as formulation analysis, actual time of blood collection
for 1 MD dog not recorded on Day 28, etc)

Observations and Results

Mortality: No mortality in any group

Clinical Signs:
• Treatment-related dilated pupils persisting for up to 3 days during recovery
period, reversible
• Emesis in some Control and LD dogs, and all MD and HD dogs every
treatment Day
• Treatment-related dry mouth at MD and HD (1 LDF & M) first 10 treatment
days
• These are PD effects
• The clinical signs (group summaries) are presented in the following tables
from the Sponsor:

Males

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Females

Body Weights
• ↓BW in HD M (-12%) , completely reversible by end of 14-day recovery
period
• Mean Body Weight Gains (Days 1 to 28) were 0.7, 0.2, -0.3, and -0.2 kg in
the M, and 0.3, -0.1, -0.4, and -0.2 kg in the F at 0, LD, MD, HD,
respectively
• The mean body weights are presented in the following graphs from the
Sponsor:

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Males

Females

Feed Consumption
• ↓ particularly in HDM (approximately -65%) vs. controls during dosing
Days 1-12

Ophthalmoscopy
• Week 4 examination: papillary dilation at MD and HD M and F, not
observed in recovery dogs after 14 days

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ECG: Not performed. Information from the toxicology studies conducted

in beagle dogs for the approved intravenous, intramuscular, and oral
formulations will be referenced

Hematology
• Slight ↑Mean WBC (+66%) , neutrophils (+70%), monocytes (+160%) and
platelet (+35%) counts in HD F vs. control F (although also elevated at
baseline, prior to treatment Day 1, not found in M, unlikely related to EP-
101)
• ↑Monocytes in MDF (55%)

Clinical Chemistry

Sporadic effects considered unlikely due to treatment, because differences were

within variation, observed in one sex, were without clear dose response, and/or
found in parameters without relationship to toxicity (e.g., ↓AST, creatine kinase)

Urinalysis: Not done. Information from the toxicology studies conducted in

beagle dogs for the approved intravenous, intramuscular, and oral formulations
will be referenced

Gross Pathology: No treatment-related findings

Results considered to be within background, and are without a dose-response

relationship

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Organ Weights: No treatment-related findings

↓Thymus weights in MD (-60%) and HD (-46%) F (reversible)

Histopathology: No treatment-related findings

Adequate Battery: yes

Peer Review: Internal peer

In comparison to the results of the histopathology examination in the 28-day

study in rats, there were no treatment-related pulmonary changes

Thymic atrophy was found in the M and F in all groups, with higher incidence in
the treated than in the control

The incidence of thymic atrophy was increased in male treatment groups, but
was without dose-related increases in severity. In the female treatment groups,
thymic atrophy was also found, although there was no dose-response
relationship.

Reversible in all but 1MDF

Thymic Atrophy (Incidence, with mean group severity scores in

parentheses):

Dose Glycopyrrolate (mg/kg by inhalation)

0 0.06 0.6 2.4

Males 1 (1.5) 3 (2.7) 3 (1.3) 3 (2.0)

Females 0 (0) 1 (0.3) 2 (1.3) 1 (1.0)

Toxicokinetics

No gender or dose effects, and no effects of treatment duration (1 vs. 28 days)

on TK parameters, including Tmax, elimination t1/2, elimination rate constant,
Vd, AUCinf (no accumulation))

The results of the TK evaluation on Day 28 are presented in the following table:

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Stability and Homogeneity:

Analysis of formulations found test article solution concentrations within 1.2%

target

Stability analysis showed both 0.25 and 10 mg/ml formulations within 10% target
concentration range

11 Integrated Summary and Safety Evaluation

Glycopyrrrolate is a muscarinic antagonist with potent bronchodilatory activity.

The Sponsor’s Glycopyrrolate Inhalation System (GIS), a newly modified drug
delivery system, eFlow nebulizer (PARI) that delivers glycopyrrolate by inhalation
is proposed for the long-term treatment of Chronic Obstructive Pulmonary
Disease (COPD).

Glycopyrrolate has been used in the US for more than 30 years, and is approved
in IM and IV systemic injection form (Robinul® Injection, IV, IM, NDA 17-558) as
a preoperative antimuscarinic agent to reduce salivation, tracheobronchial and
pharyngeal secretions, and the volume and acidity of gastric secretion during
surgery, and for blockade of cardiac vagal inhibitory reflexes during intubation.
Glycopyrrolate is also approved in oral, tablet, and ophthalmic and oral solution

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(NDA 089170, NDA 089171, NDA 08410, and others) forms as adjunctive
therapy for the chronic treatment of drooling associated with neurological
conditions such as cerebral palsy in patients ages 3-16
and for the chronic treatment of peptic ulcer (Robinul® 1 and 2 mg oral tablet,
NDA 12-827), with a maximum recommended dose (MRHD) of 8 mg/day PO.

The Sponsor is referencing DMF , DMF , and DMF , and

(b) (4) (b) (4) (b) (4)

proposes to rely on Agency safety findings for the approved NDAs 17-558 (IV
and IM injection) and NDA 12-827 (oral tablet) for the non-clinical systemic
toxicity information to support the safety of the proposed clinical study on the (
inhalation product.

Supporting nonclinical studies: Nonclinical glycopyrrolate inhalation studies

conducted by the Sponsor in support of the safety of the proposed clinical
study included non-GLP 1-day (Studies N111001B and N111001C) and 7-
day (Studies N111001B and N11100C) dose finding and MTD studies, and
GLP 28-Day toxicity studies in rats (N111001D) and dogs (Study
N111001E). Draft (unsigned GLP and Quality statements not signed)
reports were submitted for the GLP 28-day toxicity studies in rats and
dogs. For the remainder of the nonclinical information to support the
safety of the proposed clinical study, the Sponsor submitted a summary of
the safety pharmacology, pharmacokinetics, genetic toxicity, reproductive
toxicity, and local (dermal irritation) toxicity findings in the nonclinical
studies conducted for the approved drug products. Additional information
from the published literature was summarized for this submission.

Pharmacology: A summary of the study results on primary and secondary

pharmacology studies conducted for the original approved glycopyrrolate
formulations was submitted. In vivo studies showed inhibition of gastric secretion
in rat and dog, salivary secretion in dog and lacrimation in rat. Several ex vivo
studies reported in the published literature (see Villetti et al) were conducted in
guinea pig and human isolated trachea to demonstrate pharmacodynamic effects
on respiratory system tissues by glycopyrrolate vs. tiotropium, a long-acting
muscarinic antagonist, and vs. ipratropium, a muscarinic antagonist with a short
duration of action. The results of these studies showed dose-dependent
inhibition of isolated trachea and bronchus contractions induced by carbachol.

Secondary Pharmacology: In the secondary pharmacodynamics studies,

parasympathetic inhibition by glycopyrrolate was demonstrated in mice
(mydriatic, anti-tromorine [peripheral activity]), rats (inhibition of gastric secretion
and blockade of lacrimation), and dogs (inhibition of gastric and salivary
secretion and decreased intestinal tone/motility). The results of a study reported
in the published literature (see Trifilieff A., et al. (2007). The inhaled muscarinic
receptor antagonist, glycopyrrolate, has a favorable side effect profile in brown

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Norway rat lung function model when compared with tiotropium. Chest
132(suppl): 530S) showed that glycopyrrolate dry powder and tiotropium inhibited
methacholine-induced bronchoconstriction in rats and rabbits, with a duration of
action allowing for once daily administration, The systemic toxicity findings for
glycopyrrolate were below those for tiotropium bromide.

Safety Pharmacology: There were no treatment-related effects on CNS function

in a study in mice conducted for the approved formulations. Studies on
gastrointestinal safety, also conducted for the original NDA showed inhibition of
gastric secretion in rats and dogs, and inhibition of salivary secretion and
decreased intestinal tone/motility in dogs, all pharmacodynamic effects. A
respiratory and cardiovascular safety pharmacology study in rats demonstrated
up to 24-hour inhibition of methacholine-induced (30 mcg/kg)
bronchoconstriction, salivation, hypotension and tachycardia by dry powder
glycopyrrolate (NVA237) and tiotropium when given from 1-24 hours before the
methacholine. The IV ED50 values for inhibition of methacholine effect for
glycopyrrolate were 15.7, 10.1, 2.9, and 45.9 mcg/kg, (respectively). In the
anesthetized rabbit, glycopyrrolate (20 mcg/kg) vs. tiotripium (3 mcg./kg) given
prior to methacholine (10 mcg/kg IV for 70% max bronchoconstriction) inhibited
bronconstriction for the 6h assessment period. Tiotropium inhibited bradycardia
and hypotension by 95% and 85%, respectively. Glycopyrrolate had significantly
less effect than tiotropium on cardiovascular parameters in that study.

ADME: The pharmacokinetics and ADME information was referenced from the
Summary Basis of Approval for Robinul Injectable (NDA 17-558). No distribution
or metabolism studies were conducted. Excretion is primarily as unchanged drug
in feces; at 72 hours after oral administration in rat, 70%-90% drug was excreted
in feces, and by 96 hours after dosing 99.36% radioactivity was recovered in
feces (95.77%) and urine (3.59%).

Toxicology studies with glycopyrrolate administered by other routes:

Intravenously administered glycopyrrolate showed 50X the potency of oral
administration in mouse, and 80X potency vs. oral in rat. A single dose
inhalation (nose only) MTD study in rats given 0, 15, 445, and 150 mg/kg over
360 minutes resulted in unscheduled termination in 3/6 rats at the highest dose
of 150 mg/kg. The surviving rats showed labored breathing. A single inhalation
dose escalation study in dog was terminated at the dose level of 2.4 due to
excessive clinical signs, emesis and decreased food consumption, although
there were no deaths in the dogs.

Studies on glycopyrrolate were conducted for NDA 17-558 and available in the
published literature. By the dietary route, doses of 0, 250, 500, 1000, and 2000
ppm were administered for 6-7 weeks in rats. There were no treatment-related
effects, including histopathologic changes, except for decreased body weights at
the high dose. A second dietary study in rats at 0, 400, 1300, and 4000 ppm for
30 weeks, also showed no treatment-related effects except for decreased body

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weights and food consumption at 1300 and 4000 ppm. Dogs were administered
0.4 and 2.0 mg/kg/day intravenous glycopyrrolate for 5 days each week for 4
weeks. There were no treatment-related toxicity findings, although
pharmacodynamic effects were noted, and included mydriasis, cycloplegia,
xerostomia, and occasional tachycardia. No treatment-related effect were found
when glycopyrrolate was given orally (3, 9, and 27 mg/kg/day PO by capsule for
5 weeks, and 4, 16, and 64 mg/kg/day by gavage for 27 weeks) to dogs; as in
the intravenous study in dogs, the observed effects were pharmacodynamic with
occasional cycloplegia, xerostomia, mydriasis, and occasional lacrimation,
emesis and, rhinorrhea. at the high dose of 64 mg/kg/day PO.

Genetic Toxicology: Glycopyrrolate was negative in a Standard Battery of studies

conducted for the approved oral solution label (Ames Test, Human Lymphocyte
Chromosome Aberration assay, Micronucleus assay).

Carcinogenicity: No studies have been conducted to evaluate potential

carcinogenic effects by glycopyrrolate. During the Pre-IND meeting, the
Agency advised the Sponsor that any neoplastic or preneoplastic changes
observed in the 6-month repeat-dose study may require the conduct of an
inhalation carcinogenicity study.
Reproductive Toxicology Studies:The results of the reproductive toxicity studies
conducted for the approved product Robinul injectable (NDA 17-558) and found
in the published literature showed a dose-related decrease in pregnancy rate and
survival at weaning when given by the dietary route in rats at up to 65 mg/kg/day.
Glycopyrrolate was negative for teratogenicity at up to 65 mg/kg/day dietary in
rats and 0.05-0.5 mg/kg IM in rabbits, in the presence of maternal toxicity
(decreased BWG). No studies were conducted to evaluate potential adverse
effects on pre- and postnatal development.

Irritation Studies: Local irritation studies were conducted in support of the safety
of the approved intramuscular and intravenous formulations. No irritation was
found when glycopyrrolate was administered intramuscularly in rabbits at 0.1-25
mg/ml, vs. dimetane and robaxin injection. Topical exposure in abraded rabbit
skin, at up to 2000 mg/kg was associated with edema at 632 mg/ml and above,
and slight to minimal erythema at 200 mg/kg lasting 24 hours, and longer at 632
and 2000 mg/ml. Evidence of inflammation was found with some areas of
extravasion of blood over 3 days, with subcutaneous administration of up to 2
mg/ml.

Nonclinical Inhalation Toxicology Studies: The sponsor’s nonclinical toxicology

program is directed toward an assessment of local toxicity in the respiratory tract. The
sponsor submitted draft (unsigned GLP) reports of 28-day inhalation toxicology studies
with rats and dogs in support of the proposed clinical trial.

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A 28-day glycopyrrolate inhalation toxicity study was conducted in Sprague-

Dawley rats with a 14-day recovery period ( Study N111001D) for pivotal
(b) (4)

support for the safety of the proposed clinical study in this submission (Draft
Study Report submitted). The rats (n=10/sex/group with 6/sex/group
toxicokinetic evaluation and 5/sex/group recovery group rats) were administered
glycopyrrolate by nose-only inhalation once daily for 28 days at doses of 0, 0.5,
5, and 45 mg/kg/day. There was one death in a high dose male rat on Day 2
although the relationship to treatment was unclear, the animal was replaced
immediately. The treatment-related effects included reversible decreased body
weight gain during the entire 28-day dosing period, that was statistically
significant at the high dose in the males (-66%) and females (-71%).
Ophthalmoscopic examination showed primarily pharmacodynamic effects of
glycopyrrolate, including papillary dilation at the mid- and high doses, that was
reversible during the recovery period. Increased lung weights (absolute and
relative to both body weights and brain weights) were shown at the mid- and high
doses (percent differences from controls in the males were + 33% and +30%,
respectively, and +43% and +47% in the females, respectively). The increased
lung weights might correlate with increased alveolar macrophages found in the
microscopic examination. The target organs identified in the histopathology
evaluation were the lungs, larynx and Harderian gland. There were reversible
(during recovery) increased lung alveolar macrophages in terminal bronchioles
and adjacent alveoli at all doses, with dose-related increases in incidence and
severity with severity ratings of minimal with occasional mild. Furthermore, no
inflammation or inflammatory cells were found. The Sponsor suggested that this
was supportive of a particle removal function by the macrophages representing
normal lung function and not an inflammatory response. There were alterations
of the epithelial lining in the larynx from pseudostratified flattened-to-low cuboidal
“cobblestone” morphology to mucosal epithelium, that was consistent with
stratified squamous type/squamous metaplasia. Laryngeal alterations were
observed at all doses. These findings, commonly observed in inhalation
toxicology studies with rats, are attributed to an adaptive response to irritation
and have no relevance to humans. Some (nonreversible at the highest dose)
inflammation was also found in the laryngeal tissue that included neutrophil and
plasma cell macrophage infiltration of the submucosal glands and/or propria
stroma with increased incidences for males and females in the high dose group.
The NOAEL was 45 mg/kg/day (mean AUC male + female combined 7,255,000
pcg.h/ml) because increased lung alveolar macrophages observed at all doses
were without evidence of inflammation and therefore likely performing an inhaled
drug removal function, and epithelial lining changes in the larynx were without
inflammation, reversible at the low dose, and commonly found in inhalation
toxicity studies in rats.

The 28-day inhalation toxicity study on glycopyrrolate in dogs with 14-day

recovery period (Study N111001E) used 3 dogs/sex/dose main study, and
2/sex/dose recovery evaluation animals. The dogs received glycopyrrolate at
doses of 0, 0.06, 0.6 and 2.4 mg/kg/day by nose-only inhalation, once daily for

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approximately 32-53 minute exposures. There was no mortality during the study.
The clinical signs attributed to treatment included reversible dilated pupils
(pharmacodynamic effect) persisting for up to 3 days during the recovery period,
emesis in some control and low-dose dogs and all mid- and high dose dogs
throughout the treatment period, and dry mouth (pharmacodynamic effect) at the
mid and high doses during the first 10 dosing days. There was a decreased in
body weights in the high dose males that was completely reversible by the end of
the 14-day recovery period; the remaining groups showed body weight gains,
although less than in the controls during treatment and decreased food
consumption was found only in the high dose males. Thymus weight
decreases in the mid dose (-60%) and high dose (-46%) females were reversible
during recovery. The histopathology examination found no treatment-related
effects, including any pulmonary changes. The incidence of thymic atrophy was
increased in male treatment groups, but was without dose-related increases in
severity. In the female treatment groups, thymic atrophy was also found
although there was no dose-response relationship. A NOAEL can be
considered to be the low dose of 0.06 mg/kg/day (AUC combined male and
female 19450 pcg.h/ml), based on thymus weight reductions (females).

Safety Margin Table:

Safety margins for the highest proposed clinical dose (200 µg/day) relative to
NOAELs identified in the 28-day inhalation toxicology studies with rats and dogs
are shown in the table below. There are adequate safety margins for the highest
proposed clinical dose.

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Based on adequate safety margins in the 28-day glycopyrrolate inhalation toxicity

studies in rats and dogs, the abundant database on glycopyrrolate toxicity from
nonclinical studies conducted using other routes of administration (systemic
toxicity) including intravenous, intramuscular, subcutaneous and oral, and the
extensive clinical experience of more than 30 years with glycopyrrolate for the
approved and marketed (IV, IM, and oral tablet and solution forms) glycopyrrolate
drug products as well as clinical experience using inhalation exposure in the two
completed studies for this IND, the proposed clinical study is considered to be
safe-to-proceed. Most of the treatment-related target organs identified in the 28-
day nonclinical inhalation studies for this submission were reversible following
discontinuation of dosing, and can be monitored during the proposed clinical
study.

Recommendations to the Sponsor:

We have the following non-hold comments for future development of

glycopyrrolate inhalation system:

1. Submit the final study reports for the 28-day inhalation toxicity studies
in rats and dogs (N111001D and N111001E) within 120 days of the initial
IND 110,663 submission.

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KATHLEEN A YOUNG
05/13/2011

TIMOTHY W ROBISON
05/13/2011

Reference ID: 4088884

2946600
 IND # 110663 Reviewer: Kathleen Young, Ph.D.

Department of Health and Human Services

Public Health Service
Food and Drug Administration
Center for Drug Evaluation and Research

PHARMACOLOGY/TOXICOLOGY MEMO TO FILE

IND number: 110663

Sponsor: Elevation Pharmaceuticals, Inc.
Submission Type: Initial IND Submission
Supporting Doc Category/Subcategory: SDN 000; SDN 002
Submission Date/Receipt: April 13, 2011/April 14, 2011; May 11, 2011
Drug Substance: Glycopyrrolate Inhalation Solution (GIS)
Division name: Division of Pulmonary, Allergy, and Rheumatology Products
Review completion date: June 14, 2011
Reviewer name: Kathleen Young, Ph.D.
Pharmacology/Toxicology Supervisor: Molly E. Topper, Ph.D.
Division Director: Badrul Chowdhury, M.D., Ph.D.

MEMO TO FILE

RE: The original IND for glycopyrrolate inhalation system (GIS) for the treatment of chronic
obstructive pulmonary disease (COPD) was submitted on April 13, 2011. The chemistry
reviewer submitted an Information Request (IR) to the Sponsor on May 4, 2011 during the 30-
day safety review period requesting clarification of the acceptance criteria for drug product
related substances and for the assay and impurity profile of the drug product before and after
nebulization to show stability. The Sponsor responded on May 11, 2011. The CMC reviewer
requested toxicological review and evaluation of the sponsor’s response on May 16, 2011. The
following memo is an analysis of these data. From the nonclinical perspective, the Sponsor’s
impurity specification of NMT (4) % is considered acceptable for impurities that lack a structural
(b)

alert for genotoxicity (α-cyclopentyl mandelic acid (CPMA). For the initial clinical trial of 14-
day treatment, the impurity specification of NMT % is acceptable for the known genotoxin
(b) (4)

benzoic acid for the maximum proposed clinical dose of 200 mcg/day GIS giving 2.0 mcg/day of
bsnzoic acid exposure. To support an NDA, the levels of benzoic acid should be below (4)
(b)

mcg/day.

The Chemistry, Manufacturing and Controls (CMC) reviewer, Dr. Xiaobin Shen indicated
concern regarding drug stability pre-and post-nebulization, particularly for the genotoxic
impurity benzoic acid and the impurity α-cyclopentyl mandelic acid (CPMA) (see CMC Review
of 5/25/2011). The proposed drug substance specifications in the original IND submission of
April 13, 2011 were for NMT % for each of these impurities (see Table, below), providing
(b) (4)

Reference ID: 4088884

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for up to a maximum exposure of mcg/day each impurity at the highest proposed clinical
(b) (4)

dose of 200 mcg/day GIS.

Reference ID: 4088884

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(b) (4)

Reference ID: 4088884

2960489
 IND # 110663 Reviewer: Kathleen Young, Ph.D.
(b) (4)

Reference ID: 4088884

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 IND # 110663 Reviewer: Kathleen Young, Ph.D.
(b) (4)

In conclusion, the results of the impurity analyses showed levels of CPMA and benzoic acid
impurities detected in the clinical Lots to be considerably lower than the specified levels. The
levels of CPMA and benzoic acid detected were below those specified in ICH (Q3B(R2)
Guidance for Industry of NMT(4) % and CDER Guidance for Industry of 120 mcg/day for a
(b)

potential genotoxin, respectively.

Recommendations: No additional nonclinical studies are needed for impurity qualification at

the specifications presented in this submission for the proposed 14-day Phase 2 clinical study #
EP-101-03. To support an NDA or clinical studies >12 months, benzoic acid levels should be
below mcg/day.
(b) (4)

Reference ID: 4088884

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signature.
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KATHLEEN A YOUNG
06/14/2011

MOLLY E TOPPER
06/14/2011
I concur.

Reference ID: 4088884

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LAWRENCE S LESHIN
04/25/2017

CAROL M GALVIS
04/25/2017
I concur.

Reference ID: 4088884