Evaluation of genotoxicity testing of FDA approved large molecule therapeutics

Satin G Sawant1, Mark R Fielden1, Kurt A Black1

  • 1Comparative Biology and Safety Sciences, Amgen Inc., Thousand Oaks, CA 91320, United States.

Insights

Genotoxicity testing is generally not required for large molecule therapeutics, as they typically do not enter cells. A review of FDA-approved drugs found no genotoxic concerns, supporting current regulatory guidance.

Area of Science:

  • Pharmacology and Toxicology
  • Drug Development
  • Regulatory Science

Background:

  • Large molecule therapeutics (MW > 1000 daltons) are generally not expected to enter cells, limiting their potential to interact with DNA.
  • Consequently, genotoxicity studies are typically considered irrelevant and not required for these drug candidates.
  • Existing regulatory guidance reflects this understanding, although some sponsors have voluntarily conducted such studies.

Purpose of the Study:

  • To perform a retrospective analysis of genotoxicity studies for large molecule therapeutics approved by the U.S. Food and Drug Administration (FDA) since 1998.
  • To provide a data-driven rationale for the necessity and value of genotoxicity evaluations in the risk assessment of large molecule therapeutics.
  • To assess the relevance of genotoxicity testing for various large molecule modalities, including peptides and conjugated products.

Main Methods:

  • Identification of FDA-approved large molecule therapeutics using the Drugs@FDA database (1998-present).
  • Retrospective analysis of genotoxicity study data for identified therapeutics.
  • Evaluation of outcomes to determine the necessity and value of genotoxicity testing.

Main Results:

  • Out of 99 identified large molecule therapeutics, 53 underwent genotoxicity testing.
  • No significant positive genotoxic outcomes were observed across the tested therapeutics.
  • An exception was the peptide glucagon (GlucaGen®), which showed equivocal in vitro results as per its product labeling.

Conclusions:

  • The data support current regulatory guidance, indicating that genotoxicity testing for most large molecule modalities does not add significant value to risk assessment.
  • Testing is not supported for peptides composed solely of natural amino acids.
  • Genotoxicity testing may still be warranted for peptides containing non-natural amino acids and for small molecules within conjugated products.

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