Regulatory Forum Commentary* Counterpoint: Dose Selection for rasH2 Mouse Carcinogenicity Studies

Dose selection for the 6-month rasH2 mouse carcinogenicity studies depends heavily on the maximum tolerated dose (MTD) obtained from 1-month range-finding studies. A retrospective evaluation of range-finding studies and pivotal 6 month rasH2 mouse studies for 11 compounds demonstrated that the MTD based on at least a 10% decrease in body weight gain, mortality, and target organ toxicity in range-finding studies appropriately identified high doses for pivotal studies for 8 of 11 compounds. Two of the selected high doses were based on decreased body weight gain alone, while 7 were based on mortality at higher doses in shorter duration range-finding studies. High-dose selection was based on the maximum feasible dose for one study. The Center for Drug Evaluation and Research, U.S. Food and Drug Administration Executive Carcinogenicity Assessment Committee often suggested different doses than those proposed by the sponsor. High mortality was observed in only one pivotal study and the high dose was lowered during the course of that study.