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Which nonclinical studies did approved ADCs skip?

From the FDA and EMA reviews of all 14 approved ADCs. Each answer links to the regulator's own sentence.

Check my plan against these
Short answer
14 of 14 skipped carcinogenicity; 6 of 14 skipped dedicated reproductive tox.
No genotoxicity studies0/14
No carcinogenicity study14/14
No dedicated repro tox6/14

Precedent by precedent

14 approved ADCs, with the reviewers' own words.

Adcetris

brentuximab vedotin · CD30
Genotoxicity
Conducted on MMAE: Ames and mouse lymphoma negative; rat micronucleus positive (aneugenic)
“MMAE was genotoxic in the rat bone marrow micronucleus study through an aneugenic mechanism.”
✓ VerifiedUS prescribing informationSource ↗
Carcinogenicity
Not conducted (relapsed/refractory HL and sALCL indication)
“Carcinogenicity studies with brentuximab vedotin or the small molecule (MMAE) have not been conducted.”
✓ VerifiedUS prescribing informationSource ↗
Reproductive & developmental
Rat EFD: embryo-fetal lethality at >=3 mg/kg, placental transfer; no fertility studies; testicular toxicity in rat repeat-dose
“In rats, brentuximab vedotin was clearly embryo-foetal toxic, causing loss of almost all embryos at 3 mg/kg and above.”
✓ VerifiedEMA assessment report, p. 39Source ↗

Besponsa

inotuzumab ozogamicin · CD22
Genotoxicity
Conducted: calicheamicin positive in Ames and in vitro micronucleus; ADC clastogenic in mouse micronucleus
“Inotuzumab ozogamicin was clastogenic in mice at doses ≥28 µg/kg (approximately 1.1 mg/m2 of the ADC), consistent with the known DNA-reactive activity of the calicheamicin payload.”
✓ VerifiedFDA multi-discipline review, p. 36Source ↗
Carcinogenicity
Not conducted (ICH S9); liver adenomas and preneoplastic changes in 6-month rat study
“No carcinogenicity studies were conducted or required to support a marketing application for the current indication.”
✓ VerifiedFDA multi-discipline review, p. 36Source ↗
Reproductive & developmental
Rat fertility and rat/rabbit EFD conducted: rat embryo-fetal toxicity (resorptions, low fetal weight); no PPND (ICH S9)
“Embryo-fetal development studies were conducted in rabbits and rats.”
✓ VerifiedFDA multi-discipline review, p. 35Source ↗

Datroway

datopotamab deruxtecan · Trop-2
Genotoxicity
Not conducted with ADC; DXd Ames negative, clastogenic in vitro chromosome aberration and in vivo rat micronucleus
“In genetic toxicology studies, deruxtecan was not mutagenic in an Ames assay but demonstrated clastogenic potential in an in vitro Chinese hamster lung chromosome aberration assay and an in vivo rat bone marrow micronucleus assay.”
✓ VerifiedFDA multi-discipline review, p. 47Source ↗
Carcinogenicity
Not conducted (not warranted, advanced cancer)
“Carcinogenicity studies are not warranted to support the current application.”
✓ VerifiedFDA multi-discipline review, p. 47Source ↗
Reproductive & developmental
Not conducted (genotoxic payload); testis/ovary findings in rat; embryo-fetal toxicity warning
“The Applicant did not conduct fertility or embryo-fetal development toxicology studies with datopotamab deruxtecan as DXd is genotoxic and affects actively dividing cells, and therefore, these studies are not warranted to support the proposed indication.”
✓ VerifiedFDA multi-discipline review, p. 47Source ↗

Decnupaz

pivekimab sunirine · CD123
Genotoxicity
Not conducted with ADC (ICH S9); FGN849 positive in Ames TA102, in vitro and in vivo micronucleus
“In accordance with ICH S9, genotoxicity studies have not been conducted with PVEK.”
✓ VerifiedFDA multi-discipline review, p. 61Source ↗
Carcinogenicity
Not conducted (ICH S9)
“In accordance with ICH S9, carcinogenicity studies have not been conducted with PVEK.”
✓ VerifiedFDA multi-discipline review, p. 62Source ↗
Reproductive & developmental
Not conducted (ICH S9 and FDA feedback); embryo-fetal harm expected from alkylating payload
“No reproductive and developmental studies have been conducted with PVEK, in accordance with ICH S9 and FDA feedback (Reference ID: 4704103).”
✓ VerifiedFDA multi-discipline review, p. 62Source ↗

Elahere

mirvetuximab soravtansine · FRα
Genotoxicity
Not conducted with ADC; DM4 and S-methyl-DM4 Ames negative, rat bone marrow micronucleus positive
“DM4 and S-methyl-DM4 were negative in the vitro bacterial reverse mutation assay but positive in the in vivo rat bone marrow micronucleus assay.”
✓ VerifiedFDA multi-discipline review, p. 39Source ↗
Carcinogenicity
Not conducted (ICH S9, advanced cancer)
“Carcinogenicity studies were not needed to support the advanced cancer indication, consistent with ICH S9 guidance.”
✓ VerifiedFDA multi-discipline review, p. 59Source ↗
Reproductive & developmental
Not conducted (ICH S9); DM4 genotoxic, embryotoxicity expected; FRα mutations linked to birth defects
“No reproductive or developmental animal toxicity studies were conducted with mirvetuximab soravtansine.”
✓ VerifiedFDA multi-discipline review, p. 59Source ↗

Emrelis

telisotuzumab vedotin · c-Met
Genotoxicity
Not conducted with ADC; MMAE aneugenic (positive rat micronucleus), Ames and mouse lymphoma negative
“Genetic toxicology studies were not conducted with telisotuzumab vedotin but were conducted with the MMAE payload.”
✓ VerifiedFDA multi-discipline review, p. 35Source ↗
Carcinogenicity
Not conducted (not warranted for advanced cancer)
“FDA agrees that carcinogenicity studies are not warranted to support this application.”
✓ VerifiedFDA multi-discipline review, p. 52Source ↗
Reproductive & developmental
Not conducted with ADC (ICH S9); MMAE rat EFD teratogenic; ovary/uterus and testis findings in repeat-dose
“Reproductive toxicology studies with telisotuzumab vedotin are not warranted to support this application because MMAE is genotoxic and affects actively dividing cells.”
✓ VerifiedFDA multi-discipline review, p. 52Source ↗

Enhertu

fam-trastuzumab deruxtecan · HER2
Genotoxicity
Not conducted with ADC; DXd clastogenic (rat micronucleus, CHL chromosome aberration), Ames negative
“MAAA-1181a was clastogenic in both an in vivo rat bone marrow micronucleus assay and an in vitro Chinese hamster lung chromosome aberration assay but was not mutagenic in an in vitro bacterial reverse mutation assay.”
✓ VerifiedFDA multi-discipline review, p. 42Source ↗
Carcinogenicity
Not conducted (not warranted for indication; ICH S9)
“Carcinogenicity studies are not warranted to support the licensing application of fam-trastuzumab deruxtecan-nxki for the proposed indication.”
✓ VerifiedFDA multi-discipline review, p. 43Source ↗
Reproductive & developmental
Not conducted (ICH S9: genotoxic payload, HER2 antibody oligohydramnios); fertility assessed from repeat-dose testis findings
“The Applicant did not conduct any reproductive toxicology studies with DS-8201a.”
✓ VerifiedFDA multi-discipline review, p. 43Source ↗

Kadcyla

ado-trastuzumab emtansine · HER2
Genotoxicity
Conducted on DM1: Ames negative; rat micronucleus positive (aneugenic/clastogenic); monkey micronucleus inconclusive
“DM1 was positive in an in vivo rat bone marrow micronucleus assay at exposures similar to the mean maximum concentrations of DM1 in patients in clinical trials, which is consistent with its mechanism of action.”
✓ VerifiedFDA pharmacology/toxicology review, p. 6Source ↗
Carcinogenicity
Not conducted (not required, advanced cancer)
“8 Carcinogenicity Not required and not submitted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 132Source ↗
Reproductive & developmental
Not conducted (ICH S9; relied on trastuzumab data and DM1 mechanism); fertility effects from general tox
“Based on these findings and consistent with ICH S9, embryo-fetal developmental toxicity studies were not required for the indicated patient population.”
✓ VerifiedFDA pharmacology/toxicology review, p. 6Source ↗

Mylotarg

gemtuzumab ozogamicin · CD33
Genotoxicity
Conducted: ADC clastogenic in mouse micronucleus; free calicheamicin DMH mutagenic and clastogenic in vitro
“Gemtuzumab ozogamicin was found to be clastogenic. This is consistent with the known induction of DNA breaks by calicheamicin and other enediyne antitumour antibiotics.”
✓ VerifiedEMA assessment report, p. 50Source ↗
Carcinogenicity
Not conducted; rat liver preneoplastic oval cell hyperplasia noted in tox studies
“No carcinogenicity studies have been conducted with gemtuzumab ozogamicin (see discussion on non-clinical aspects).”
✓ VerifiedEMA assessment report, p. 38Source ↗
Reproductive & developmental
Rat male/female fertility and rat EFD (one species agreed); embryolethal, teratogenic, male fertility impaired; no PPND
“Based on the unequivocally positive results obtained from a pilot study, the Agency previously agreed with the Applicant that one species would be sufficient to support an NDA application for CMA-676 in a leukemia indication.”
✓ VerifiedFDA pharmacology/toxicology review, p. 7Source ↗

Padcev

enfortumab vedotin · Nectin-4
Genotoxicity
Not conducted with ADC; MMAE Ames and mouse lymphoma negative, rat micronucleus positive (aneugenic)
“Using the standard core battery of genetic toxicology studies recommended in the ICH S2 guidance, MMAE was reported to be genotoxic in the in vivo rat bone marrow micronucleus assay through an aneugenic mechanism.”
✓ VerifiedFDA multi-discipline review, p. 36Source ↗
Carcinogenicity
Not conducted (ICH S9, advanced cancer)
“Carcinogenicity studies were not conducted or needed to support marketing of PADCEV in patients with advanced cancer.”
✓ VerifiedFDA multi-discipline review, p. 85Source ↗
Reproductive & developmental
No fertility or PPND studies (ICH S9); preliminary rat EFD with ADC and MMAE EFD: embryolethal, teratogenic
“Fertility and early embryonic development studies were not conducted or needed to support marketing of PADCEV in patients with advanced cancer.”
✓ VerifiedFDA multi-discipline review, p. 85Source ↗

Polivy

polatuzumab vedotin · CD79b
Genotoxicity
Not conducted with ADC; MMAE Ames and mouse lymphoma negative, rat micronucleus positive (aneugenic)
“MMAE was genotoxic in the rat bone marrow micronucleus study through an aneugenic mechanism.”
✓ VerifiedFDA pharmacology/toxicology review, p. 12Source ↗
Carcinogenicity
Not conducted (not warranted for indication; ICH S9)
“Carcinogenicity studies in animals have not been performed with polatuzumab vedotin or MMAE and are not warranted for the proposed indication.”
✓ VerifiedFDA pharmacology/toxicology review, p. 12Source ↗
Reproductive & developmental
No fertility study (ICH S9); MMAE rat EFD embryolethal and teratogenic; testicular toxicity in rat repeat-dose
“A designated fertility study was not conducted with polatuzumab vedotin or MMAE and is not needed for the proposed indication.”
✓ VerifiedFDA pharmacology/toxicology review, p. 12Source ↗

Tivdak

tisotumab vedotin · Tissue factor
Genotoxicity
Not conducted with ADC; MMAE: Ames and mouse lymphoma negative, rat micronucleus positive (aneugenic)
“Genetic toxicology studies were not conducted with tisotumab vedotin; rather, the applicant submitted studies that evaluated the payload.”
✓ VerifiedFDA multi-discipline review, p. 34Source ↗
Carcinogenicity
Not conducted (ICH S9)
“Carcinogenicity studies were not conducted with tisotumab vedotin in accordance with ICH S9 guidance.”
✓ VerifiedFDA multi-discipline review, p. 34Source ↗
Reproductive & developmental
Not conducted with ADC (ICH S9); MMAE rat EFD teratogenic/embryolethal; male repro toxicity in monkey
“MMAE was teratogenic and embryo lethal when administered to pregnant rats via two intravenous doses of 0.2 mg/kg during the period of organogenesis on gestational days 6 and 13.”
✓ VerifiedFDA multi-discipline review, p. 35Source ↗

Trodelvy

sacituzumab govitecan · Trop-2
Genotoxicity
Not conducted with ADC; SN-38 Ames negative, in vitro micronucleus positive (clastogenic)
“SN-38 was negative for mutagenicity in a bacterial reverse mutation (Ames) test but was clastogenic in the in vitro mammalian cell micronucleus test.”
✓ VerifiedFDA multi-discipline review, p. 176Source ↗
Carcinogenicity
Not conducted (advanced cancer, ICH S9)
“No carcinogenicity studies were conducted or warranted to support this NDA, as the proposed indication was for advanced cancer.”
✓ VerifiedFDA multi-discipline review, p. 177Source ↗
Reproductive & developmental
Not conducted (ICH S9); SN-38 genotoxic so embryo-fetal toxicity expected; female repro organ findings in monkey
“No embryo-fetal developmental toxicology studies were conducted or warranted to support this BLA submission, based on ICH S9.”
✓ VerifiedFDA multi-discipline review, p. 176Source ↗

Zynlonta

loncastuximab tesirine · CD19
Genotoxicity
Not conducted with ADC; SG3199 clastogenic in vitro (micronucleus, chromosome aberration); Ames not assessable (cytotoxicity)
“No genotoxicity studies were conducted with ADCT-402. SG3199 was genotoxic in GLP in vitro studies (in vitro micronucleus assay and the chromosome aberration assay in human lymphocytes from whole blood).”
✓ VerifiedEMA assessment report, p. 37Source ↗
Carcinogenicity
Not conducted (ICH S9; genotoxic payload, advanced cancer)
“In accordance with ICH S9, ICH S6(R1) and ICH S1A (Guideline on the Need for Carcinogenicity Studies of Pharmaceuticals) no carcinogenicity studies were conducted or are planned with ADCT-402 or SG3199”
✓ VerifiedEMA assessment report, p. 38Source ↗
Reproductive & developmental
Not conducted (ICH S9); irreversible testicular toxicity in monkey; fertility assessed in repeat-dose study
“Reproductive and developmental toxicology studies were not conducted since cytotoxic (i.e. genotoxic) drugs that affect actively dividing cells, such as loncastuximab tesirine, are expected to be embryo/feto toxic and teratogenic.”
✓ VerifiedFDA multi-discipline review, p. 39Source ↗