the value of chronic animal toxicology studies of pharmaceutical compounds: a retrospective analysis

18
FUNDAMENTAL AND APPLIED TOXICOLOGY 5, 1007-1024 (1985) ISSUES The Value of Chronic Animal Toxicology Studies of Pharmaceutical Compounds: A Retrospective Analysis CYNTHIAE.LUMLEYAND STUARTR.WALKER Centre for Medicines Research, Carshalton, Surrey, England The Value of Chronic Animal Toxicology Studies of Pharmaceutical Compounds: A Retro- spective Analysis. LUMLEY, C. E., AND WALKER, S. R. (1985). Fundam. Appl. Toxicol. 5, 1007- 1024. Extensive animal studies are carried out during the development of new medicines to assess toxicity and predict their safety for use in man. There are, however, differences of opinion con- cerning the nature of safety evaluation studies required prior to marketing. Any prospect of rationalizing the number and design of animal studies must stem from a reappraisal of conventional animal testing procedures and better use of available data on the toxicity of compounds previously investigated. The Centre for Medicines Research has therefore established a toxicology databank containing comprehensive data from repeated-dose animal safetyevaluation studies provided by pharmaceutical companies. Thirteen companies within the United Kingdom have provided tox- icological data for 32 pharmaceutical compounds studied in the rat, dog, or primate, resulting in 45 case studies for which both short-term (~6 months) and long-term (>6 months) tests had been completed. A comprehensive analysis of these studies has been carried out to determine what new findings, if any, become apparent in studies after 6 months. The results do not support the need for animal toxicity studies of longer than 6 months duration, apart from those designed to investigate carcinogenicity. 8 1985 society of Totic&gy. Toxicity studies in animals provide useful ev- The main objectives of repeated-dose tox- idence about potential hazards to man, and icity studies (with the exception of carcino- the scientific community, the research-based genicity investigations) are to reveal physio- drug industry, and drug regulatory authorities logical and/or pathological changes induced regard them as indispensable in the overall as- by repeated administration of the substance sessment of new medicines. However, there under consideration, to determine the dose- are major differences of opinion with regard response relationship of these changes, and to to the amount and nature of toxicity testing establish the maximum “no effect” dose for that is necessary during drug development. In each species (Poggiolini, 1983; Traina, 1983). particular the duration of chronic repeated- The ultimate goals are to collect data which dose animal studies is a subject of considerable will both aid in the decision as to whether the controversy. This is illustrated by the differ- drug should be tested in man (Dayan, 198 1; ences in international recommendations for Kesterson, 1982) and subsequently to indicate the minimum periods of repeated-dose ad- problems likely to be encountered during long- ministration to animals to support marketing term clinical administration. According to authorization (Table 1). It appears that the Traina (1983), the only difference between the duration of the animal studies is empirically conditions of subchronic (l-3 months) and related to the proposed duration of human ex- chronic (6-18 months) toxicity studies is the posure. dose. In a subchronic study doses are given 1007 0272-0590185 $3.00 Copyri&t 0 1985 by the Society of Toxicology. All rights of reproduction in any form reserved.

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FUNDAMENTAL AND APPLIED TOXICOLOGY 5, 1007-1024 (1985)

ISSUES

The Value of Chronic Animal Toxicology Studies of Pharmaceutical Compounds: A Retrospective Analysis

CYNTHIAE.LUMLEYAND STUARTR.WALKER

Centre for Medicines Research, Carshalton, Surrey, England

The Value of Chronic Animal Toxicology Studies of Pharmaceutical Compounds: A Retro- spective Analysis. LUMLEY, C. E., AND WALKER, S. R. (1985). Fundam. Appl. Toxicol. 5, 1007- 1024. Extensive animal studies are carried out during the development of new medicines to assess toxicity and predict their safety for use in man. There are, however, differences of opinion con- cerning the nature of safety evaluation studies required prior to marketing. Any prospect of rationalizing the number and design of animal studies must stem from a reappraisal of conventional animal testing procedures and better use of available data on the toxicity of compounds previously investigated. The Centre for Medicines Research has therefore established a toxicology databank containing comprehensive data from repeated-dose animal safety evaluation studies provided by pharmaceutical companies. Thirteen companies within the United Kingdom have provided tox- icological data for 32 pharmaceutical compounds studied in the rat, dog, or primate, resulting in 45 case studies for which both short-term (~6 months) and long-term (>6 months) tests had been completed. A comprehensive analysis of these studies has been carried out to determine what new findings, if any, become apparent in studies after 6 months. The results do not support the need for animal toxicity studies of longer than 6 months duration, apart from those designed to investigate carcinogenicity. 8 1985 society of Totic&gy.

Toxicity studies in animals provide useful ev- The main objectives of repeated-dose tox- idence about potential hazards to man, and icity studies (with the exception of carcino- the scientific community, the research-based genicity investigations) are to reveal physio- drug industry, and drug regulatory authorities logical and/or pathological changes induced regard them as indispensable in the overall as- by repeated administration of the substance sessment of new medicines. However, there under consideration, to determine the dose- are major differences of opinion with regard response relationship of these changes, and to to the amount and nature of toxicity testing establish the maximum “no effect” dose for that is necessary during drug development. In each species (Poggiolini, 1983; Traina, 1983). particular the duration of chronic repeated- The ultimate goals are to collect data which dose animal studies is a subject of considerable will both aid in the decision as to whether the controversy. This is illustrated by the differ- drug should be tested in man (Dayan, 198 1; ences in international recommendations for Kesterson, 1982) and subsequently to indicate the minimum periods of repeated-dose ad- problems likely to be encountered during long- ministration to animals to support marketing term clinical administration. According to authorization (Table 1). It appears that the Traina (1983), the only difference between the duration of the animal studies is empirically conditions of subchronic (l-3 months) and related to the proposed duration of human ex- chronic (6-18 months) toxicity studies is the posure. dose. In a subchronic study doses are given

1007 0272-0590185 $3.00 Copyri&t 0 1985 by the Society of Toxicology. All rights of reproduction in any form reserved.

1008 LUMLEY AND WALKER

TABLE I

CURRENT RECOMMENDATIONS FORTHE MINIMUM DURATIONOFANIMAL TOXICITY STUDIES

Proposed duration of

human exposure

Duration of animal toxicity studies required to support marketing authorisation (studies required in a rodent (R) and a nonrodent (Non-R) species)

Canadaa EECb USA’ Japand

1 week 4-6 months 4 weeks Up to 3 months 3 months 1 month 18 months* 3 months Up to 6 months 6 months 3 months 18 months* 6 months Up to 6 months 12 months 6 months- 18 months* 6 months 12 months (Non-R) 12 months

unlimited 18 months (R)**

’ Health Protection Branch (198 I). b Alder ef al. (1980). ’ Kesterson (1982). d Koseisho (1984).

* Duration of studies should be extended according to existing toxicity data, nature of drug, proposed clinical use, and indications.

** Although 18-month studies in rodents are indicated in the guidelines, in practice I2-month studies appear to be sufficient.

that will establish the nature of the com- pound’s toxicity while in a chronic study doses are employed that will demonstrate if this or some other toxicity is manifested after pro- longed exposure at less stressful levels. It is common experience that doses used in sub- chronic studies may be higher than those in chronic investigations. Both Goldenthal (1968) and D’Aguanno (1972) consider that in certain instances longer studies may some- how compensate for unforeseen shortcomings in experimental design.

It has been suggested that the potential of any drug to produce organ damage in the test species (except carcinogenicity) can be esti- mated through well-designed studies of 3 to 6 months (Barnes and Denz, 1954; WHO, 1966; ABPI, 1968; Paget, 1968; Peck, 1968; D’Ag- uanno, 1972; Page, 1977; Gross, 1982; Hey- wood, 1983). In contrast, a WHO publication (WHO, 1978) declares that “Acute and sub- acute tests are of limited value in predicting chronic effects because:

(a) chemicals may produce different toxic responses when administered over a prolonged period; and

(b) during the aging process, factors such as altered tissue sensitivity, changing metabolic

and physiological capability and spontaneous disease may influence the degree and nature of toxic responses.”

The implication is therefore that longer- term studies are necessary, although an alter- native may be short-term studies in aging an- imals if there were adequate evidence to sup- port supposition (b). There have been claims that data in the files of the FDA (Goldenthal, 1968; D’Aguanno, 1972), the National Cancer Institute (Page, 1977), Huntingdon Research Centre (Worden, 1978), and the Canadian Health Protection Branch (HPB) (G. Freder- ick, 1984, personal communication) have demonstrated new toxic effects becoming ev- ident after dosing for 6 months or longer. Al- though no specific examples have been pub- lished, Goldenthal ( 1968), D’Aguanno ( 1972), and Worden (1978) cite general effects that were apparently not detected within 6 months with certain therapeutic classes of drug. How- ever, the design and nature of such studies must be very carefully considered before it can be concluded that they provide any justifica- tion for longer-term investigations.

Although the value of repeated-dose studies of longer than 6 months has not been conclu- sively established, there has been a growing

VALUE OF LONG-TERM ANIMAL TOXICOLOGY 1009

tendencv for rezulatorv agencies to reauire tablish a toxicology databank, for which the methodology

tests of increasing duration(Gross, 1979). On and data acquisition have been previously described in

the other hand, Gross (1982) stated that safety detail (Lumley and Walker, 1985a,b). To preserve the

cannot be achieved by simply prolonging confidentiality of the data, the company names and the compounds were given CMR codes before being entered

studies. into the Centre’s microcomputer. The databank is also One method of assessing the value of more password protected at several levels and all analyses were

carried out in-house. prolonged tests of medicines would be to make a retrospective analysis of the data available from both shorter-term (~6 months) and lon- ger-term (>6 months) studies. There appear to have been very few published attempts to do this, and these have been constrained by reliance on limited data from one laboratory (Peck, 1968) or by dependence solely on results from the literature (McNamara, 1976). Both these studies supported the conclusion that toxicological studies beyond 3-6 months are usually unnecessary.

Invaluable but dormant toxicological data are contained in the archives of the toxicology departments of pharmaceutical companies, chemical companies, and the regulatory agen- cies. Using data supplied by many companies, the Centre for Medicines Research (CMR) has established a unique computer-based toxicol- ogy databank to enable retrospective analyses to be carried out (Lumley and Walker, 1985a,b). This paper describes a retrospective analysis based on the comparison of shorter- term (~6 months) and longer-term (>6 months) repeated-dose animal toxicology in- vestigations to determine what new findings, if any, become apparent in studies lasting more than 6 months.

METHODS

Eleven pharmaceutical companies with research and development activities dire&d from the United Kingdom have provided comprehensive repeated-dose toxicology data. Compounds that had been tested and evaluated be- tween 1965 and 1982 were included if information from both shorter-term (~6 months) and longer-term (>6 months) experiments which the companies considered to be comparable was available. Two additional companies provided information for such compounds where the data were generated by the European subsidiary. Some infor- mation for compounds which had been studied in two or more species was also provided. Carcinogenicity studies were excluded unless a combined carcinogenicity/toxicity study was carried out. These data have been used to es-

The UK database contains 74 compounds, 58 of which were tested in more than one species. This has resulted in 145 case studies; a case study being defined as the full information for one compound tested in one species for one or more time period(s). Ninety-three case studies in- clude tests carried out for a maximum period of 6 months or less, while in 52 case studies tests lasted longer than 6 months.

To determine whether any new information was ob- tamed from repeated-dose toxicity studies of longer than 6 months, it was necessary to have comparable studies of differing duration for each compound or complete interim and final analyses in a single study of appropriate total duration, Two or more studies were considered to be comparable if the same compound had been administered to the same species by the same route. Studies where a different strain or breed of the same species had been used were not excluded, and no differentiation was made be- tween oral administration by gavage, as tablets or capsules, or in the diet. Studies carried out in different institutions were also included when the company involved considered them to be comparable. The 52 long-term studies are summarized in Fig. I. For 5 out of the 52, data were avail- able only from long-term studies (two 1 I-month studies and three 12-month studies) and in 2 cases the routes of administration were different in the short- and long-term studies. There are 45 long-term studies (>6 months) for which comparable short-term (~6 months) data were available for analysis.

RESULTS

Analysis of the data shows that in 20 out of 45 case studies all toxicological effects were seen within 6 months (Fig. 1). The 25 case studies in which apparently new findings were seen after 6 months are summarized in Table 2. These 25 case studies were discussed in de- tail at a meeting attended by the toxicologists who had provided the data and representatives from academia. The comments and conclu- sions reached by this group with regard to each case are included in Table 2.

Figure 1 shows that in 9 of these 25 case studies no 6-month data were available and therefore definitive conclusions could not be

1010 LUMLEY AND WALKER

52 LONG-TERM CASE STUDIES

LONG-TERM +

-5 i!! 2

45

NO SHORT-TERM STUDIES

FOR COMPARISON

ROUTES OF ADMINISTRATION DIFFERENT

IN LONG- AND SHORT- TERM STUDIES

LONG-TERM STUDIES &6M) WITH

COMPARABLE SHORT-TERM STUDIES &6M)

NEW EFFECTS SEEN AFTER 6 MONTHS

3 CONSIDERED OF NO TOXICOLOGICAL SIGNIFICANCE (SHIVERING,

COLOURATION OF GUT CONTENTS) (TABLE 2: NOS. 7, 16, 20)

20 13 ALL EFFECTS SEEN SOME APPARENTLY NEW

WITHIN 6 MONTHS FINDINGS IN THE LONG-TERM STUDY

9 NO 6 MONTH STUbY 7 NEW EFFECTS: EXTENSION

(TABLE 2: Nos. 4. 5, 6, 9, 13.19, 22, 23, 24, ) TERM STUDY

(TABLE 2: NOS. 3, 8, 10, 12,

16, 17, 25,)

I: OF EFFECTS SEEN IN SHORT-

2 NEW EFFECT SEEN WITHIN 6

MONTHS IN ALTERNATIVE SPECIES

(TABLE 2: NOS. 14, 21)

4 NEW EFFECTS SEEN AFTER 6 MONTHS DID NOT FURTHER INFLUENCE ANY RISK/BENEFIT ASSESSMENTS (TABLE 2: Nos. 1. 2, 11, 15)

FIG. I. Summary of long-term case studies.

drawn. In 3 case studies the new effects seen after 6 months were considered by the group to be of no toxicological significance (shivering and coloration of gut contents). In 13 case studies some apparently new findings were observed in the long-term investigations. In 7 of these 13 the group considered the new ef- fects to be a progression of effects seen in the short-term studies and so they do not justify continuing the study beyond 6 months. In a further 2 case studies the new effects were seen within 6 months in the alternate species. In the remaining 4 case studies the toxicologists have indicated that the new effects seen after

6 months did not further influence the risk appraisal of the compound.

DISCUSSION

Analysis of the data provided by 13 phar- maceutical companies on 32 compounds (45 case studies) did not provide any evidence to justify prolonging chronic toxicity studies be- yond 6 months. In those cases in which some effects required longer than 6 months to be- come apparent or measurable this was a con- sequence of several factors including the

VALUE OF LONG-TERM ANIMAL TOXICOLOGY 1011

problems involved in carrying out a retro- spective analysis and in interpreting toxico- logical findings in aging animals, as well as inconsistencies in the design of studies of dif- ferent durations.

1. Dijiculties of Retrospective Analyses

One of the major problems encountered in this retrospective analysis was that the case studies were not originally designed with a view to determining the value of long- as com- pared to short-term studies, but rather merely to perform a safety study of an individual compound. Several points must therefore be considered when attempting to do so:

(a) Time. In many instances there were several years between the conduct of the short- and long-term studies. As toxicology is a rap- idly developing science, the “state of the art” at the time of the short-term study might not have permitted all the observations that were subsequently made in the long-term study to be undertaken.

(b) Location. In several cases the short- and long-term studies were carried out at different institutions, and even in different countries. Toxicological observations, for example, CNS effects, can be subjective, or require interpre- tation by experienced experts, and this can in- troduce variation in what is reported.

(c) Reexamination. When a new patholog- ical change is noted in a long-term study, the slides prepared during the short-term study may be reexamined in more detail. With the knowledge obtained from the long-term study, the change, or its onset, may subsequently be detected in the slides from the short-term study.

(d) Animals/vehicles. Different animal strains or different vehicles have occasionally been employed in the short- and long-term studies, the significance of which was not al- ways known.

(e) Personnel. In many cases the toxicolo- gist submitted data to this study which had been generated and reported by others, often before he had even joined the company. Dif-

ferences in terminology and reporting format can create difficulties in interpretation of data.

fl Salient eficts. Considerable time and effort was required to complete the CMR questionnaires and in some instances it was not always done by the most senior toxicolo- gist. Although the original protocol requested only salient drug-related effects to be noted, often all the effects seen were recorded. These then required subsequent interpretation by the toxicologist.

2. Study Design

Study design and the procedure followed when a toxicological investigation was under- taken differed between companies. In some cases evaluation of the short-term studies was completed before the long-term study was ini- tiated, whereas in others the short- and long- term studies submitted for comparison were carried out simultaneously. Three points arise from this.

(a) Dose levels. Generally, if a subchronic study has been evaluated before commencing the long-term study, the dose levels in the latter would be based on the shorter-term results. Dose levels in chronic studies are usually cho- sen so that the top dose can be expected to produce some evidence of toxicity (D’Ag- uanno, 1972; WHO, 1978; Traina, 1983). Traina ( 1983) advises that the high dose should be selected near the midpoint of the inter- mediate and high doses of subchronic studies. However, from the data submitted it appears that the same or even higher dose levels were often used in the longer compared to the shorter-term studies (27 out of 45 case studies). In addition, as Zbinden ( 1980) and Heywood (1983) have pointed out, many target organ effects induced by artificially high doses are of no relevance to man. Moreover, higher dose levels do not necessarily result in a propor- tional increase in blood or tissue levels and one of two effects may result:

(i) A larger than expected increase in blood or tissue levels may occur due to accumulation

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s ar

e no

t av

aila

ble

in t

his

stud

y; th

e nu

mbe

r of

an

imal

s ex

amin

ed

in t

he 3

-mon

th

stud

y ( 1

0 fe

mal

es)

was

lowe

r th

an i

n th

e 12

- m

onth

st

udy

(25

fem

ales

); ta

rget

org

an

(hea

rt)

was

iden

tifie

d w

ithin

3

mon

ths

In t

his

stud

y a

3- a

nd a

n 1 I

-mon

th

stud

y ar

e co

mpa

red,

an

d it

is th

eref

ore

not

poss

ible

to

conc

lude

wh

ethe

r th

e ef

fect

s se

en a

t 18

mon

ths

would

ha

ve b

een

appa

rent

w

ithin

6

mon

ths;

in

add

ition,

do

se le

vels

use

d in

the

long

-term

st

udy

are

3X

thos

e us

ed in

the

sho

rt te

rm;

targ

et o

rgan

(liv

er)

was

iden

tifie

d w

ithin

18

mon

ths

TABL

E 2-

Con

tinue

d z

Gro

up

com

men

ts

and

conc

lusi

ons

(targ

et

;;

Stud

y Sp

ecie

s rou

te

Tim

e”

orga

ns i

dent

ified

by

the

com

pany

no

. th

er c

l (m

onth

s)

Effe

cts o

bser

ved

with

in

6 m

onth

s E

ffect

s obs

erve

d uf

te 6

mon

ths

toxi

colo

gist

wh

o pr

ovid

ed

the

data

)

7 D

og

6 12

oral

cvs

8 9

Dog

0.

5 3

Ora

l 12

cvs

Dog

Ora

l

1 C

LIN

: D

eath

, re

duce

d gr

owth

ra

te;

3 sa

livat

ion;

po

stm

edic

atio

n 12

he

art

rate

inc

; EC

G c

hang

es

cvs

CLI

N:

Body

wt

gain

ret

ard&

, fo

od

inta

ke d

ec; s

aliv

atio

n;

conv

ulsi

ons;

st

iff un

stea

dy

gait;

abn

orm

al

ECG

, va

sodi

lata

tion;

vo

miti

ng

LAB:

R

BC,

Hb,

PC

V de

c;

pota

ssiu

m,

ALT

inc

PATH

: N

o ab

norm

alitie

s

CLI

N:

Wei

ght

loss

; ECG

cha

nges

; ec

zem

atou

s le

sion

s

LAB:

Po

tass

ium

dec

PATH

: H

eart-

wei

ght

inc

-end

ocar

dial

he

mor

rhag

e/

necr

osis

.

LAB:

Se

rum

cho

lest

erol

de

c

PATH

: H

eart-

rela

tive

weig

ht

inc

-ven

tricu

lar

fibro

sis

--my-

dial

fib

rosi

s/

necr

osis

Li

ver-w

eigh

t in

c; h

epat

ocyt

e hy

pertr

ophy

PATH

: Li

ver-s

light

we

ight

in

c

PATH

: H

eart-

myo

card

ial

necr

osis

/ fib

rosi

s

LAB:

Er

ythr

ocyt

e co

unt

and

Hb

dec

PATH

: Ki

dney

-sm

all

area

s of

tubu

lar

dege

nera

tion

Sple

en-re

lativ

e we

ight

in

c

Live

r we

ight

in

crea

se w

as m

argi

nal

and

does

not

just

ify a

12-

mon

th

stud

y; o

nly

6 an

imal

s we

re e

xam

ined

at

6 m

onth

s an

d th

e do

se le

vels

wer

e ha

lf th

ose

used

in

the

12-m

onth

st

udy

wher

e 10

ani

mal

s we

re e

xam

ined

. Li

ver

weig

ht

incr

ease

wa

s se

en in

the

rat

with

in

1 m

onth

; th

e si

gnifi

canc

e of

live

r we

ight

ch

ange

s wi

th

no a

ccom

pany

ing

lesi

ons

is d

ebat

able

; no

ta

rget

org

ans

were

ide

ntifi

ed

in t

his

stud

y E $

Endo

card

ial

hem

orrh

age/

necr

osis

was

seen

at

2 w

eeks

; the

myo

card

ial

lesio

n 5

obse

rved

at

12 m

onth

s wa

s ju

dged

to

be

a co

nseq

uenc

e of

the

phar

mac

olog

ical

z pr

oper

ties

of th

e co

mpo

und;

al

thou

gh

< th

e 12

-mon

th

dose

s ar

e lo

wer

than

tho

se

K us

ed in

the

2-w

eek

stud

y th

ey a

re 1

.5 X

hi

gher

tha

n th

e 3-

mon

th

dose

s; ta

rget

or

gan

(hea

rt) w

as id

entif

ied

with

in

2 w

eeks

The

sple

en w

as n

ot w

eigh

ted

in t

he s

hort-

te

rm s

tudi

es;

rena

l tu

bula

r de

gene

ratio

n wa

s se

en in

onl

y l/8

hi

gh-d

ose

anim

al;

thes

e ne

w fin

ding

s do

not

just

ify a

12-

m

onth

st

udy;

targ

et o

rgan

(he

art)

was

iden

tifie

d w

ithin

3

mon

ths

10

Prim

ate

I C

LIN

: D

eath

; bo

dy w

t lo

ss; f

ood

6 in

take

dec

; con

stip

atio

n;

Ora

l 12

di

arrh

ea;

vom

iting

cvs

LAB:

An

emia

; ch

oles

tero

l de

c; S

AST

inc;

blo

od

suga

r low

11

Prim

ate

Ora

l

6 12

cvs

12

Rat

Old

CN

S

6 12

PATH

: Li

ver-d

egen

erat

ive

chan

ges

Kidn

ey-n

ecro

tic

epith

elia

l ce

lls

Gl-u

lcera

tion,

in

flam

mat

ion,

in

flam

mat

ory

infil

trate

s Ad

reno

corti

cal

hype

rpla

sia

CLI

N:

Atax

ia,

redu

ced

sens

ory

refle

xes;

su

bdue

d; h

eart

rate

dec

; eye

- or

ange

tin

ge

in

optic

di

sc;

vom

iting

; ex

cess

saliv

atio

n

LAB:

N

o ab

norm

alitie

s

PATH

: Li

ver-w

eigh

t in

c; d

epos

ition

of

yello

w p

igm

ent

Lym

ph

node

s-de

posit

ion

of y

ello

w

pigm

ent

CLI

N:

Dea

th,

body

w-t g

ain

inc/

dec;

fo

od in

take

dec

; sal

ivat

ion

inc;

con

vuls

ions

, ag

gres

sion,

hy

pers

ensi

tivity

; al

opec

ia;

absc

esse

s; re

d te

ars

LAB:

a-

glob

de

c; &

glob

ln

c; u

rea

inc;

SAS

T,

SALT

, SA

P in

c

PATH

: Li

ver-d

egen

erat

ive

chan

ges,

PA

TH:

Live

r-wei

ght

inc;

vac

uola

tion

of

fat c

onte

nt

inc

hepa

tccy

tes

CLI

N:

Leth

argy

, se

vere

hem

orrh

agic

diar

rhea

; sl

ight

ata

xia;

ski

n pa

le,

yello

w;

poor

bod

y co

nditio

n;

sign

s of

deh

ydra

tion

LAB:

U

rea

inc

PATH

: Li

ver--

occa

sion

al

hepa

tocy

te

hype

~oph

y

PATH

: H

eart-

wei

ght

dec

Trea

tmen

t-rel

ated

co

lora

tion

of ti

ssue

s

All

appa

rent

ly

addi

tiona

l fin

ding

s at

12

mon

ths

retle

ct 6

-mon

th

chan

ges

and

do

not

just

ify c

ontin

uing

th

e st

udy

beyo

nd

this

per

iod,

th

e cl

inic

al

sign

s ar

e al

l re

late

d to

Gl

chan

ges

and

this

sys

tem

is

clea

rly i

dent

ified

as

a ta

rget

by

6 m

onth

s;

alth

ough

he

patc

qte

hype

rtrop

hy

was

not

seen

unt

il 12

mon

ths,

deg

ener

ativ

e ch

ange

s we

re s

een

in t

he l

iver

with

in

6 m

onth

s an

d th

ese

were

con

sider

ed

to b

e m

ore

serio

us t

han

hype

rtrop

hy;

the

sum

e do

se le

vels

wer

e us

ed a

t 6 a

nd

12

5

mon

ths;

ta

rget

org

an (

Gl

tract

) id

entif

ied

$ w

ithin

1

mon

th

a

Col

orat

ion

of t

issu

es o

bser

ved

at 1

2 m

onth

s is

not

con

sider

ed

an a

dditio

nal

findi

ng

in

8 vi

ew o

f pi

gmen

tatio

n of

live

r an

d ly

mph

$

node

s se

en w

ithin

6

mon

ths;

onl

y 6

anim

als

were

exa

min

ed

in t

he 6

-mon

th

stud

y, t

oo

E

few

to d

etec

t org

an w

eigh

t ch

ange

; an

effe

ct

on

hear

t we

ight

wa

s ex

pect

ed

from

th

e g

phar

mac

olog

y of

this

com

poun

d an

d th

e 2

Obs

eNd

decr

ease

doe

s no

t ju

stify

a

12-

$

mon

th

stud

y; ta

rget

org

an (

Gl

tract

) wa

s 2

iden

tifie

d w

ithin

6

mon

ths

x 3 $ Th

e ne

w fin

ding

s (li

ver

weig

ht

incr

ease

and

he

pato

cyte

vac

uola

tion)

ar

e an

ext

ensi

on

8 4 of

effe

cts s

een

in t

he s

hort-

term

as

he

patic

tox

icity

was

not

ed w

ithin

6

mon

ths

(live

r fa

t con

tent

in

crea

sed

and

dege

nera

tive

chan

ges)

; tar

get

orga

n (C

NS-

phar

mac

olog

ical

targ

et)

iden

tifie

d w

ithin

1

mon

th

TABL

E 2-

Con

tinue

d

Gro

up

com

men

ts

and

conc

lusi

ons

(targ

et

Stud

y Sp

ecie

s rou

te

Tim

d or

gans

ide

ntifi

ed

by th

e co

mpa

ny

UO.

ther

cl

(mon

ths)

E

ffect

s obs

erve

d w

ithin

6

mon

ths

Effe

cts o

bser

ved

afte

r 6 m

onth

s to

xico

logi

st

who

prov

ided

th

e da

ta)

Kidn

ey-w

eigh

t de

c;

dege

nera

tive

chan

ges

13

14

Rat

oral

CN

S

1 C

LIN

: D

eath

: bo

dv w

t. fo

od i

ntak

e C

LIN

: C

age

sore

s le

adin

g to

acu

te

The

mea

ning

of

thes

e la

bora

tory

ch

ange

s in

24

de

cf s

eda>

on’a

fter

dosin

g;

exci

tem

ent;

abno

rmal

be

havi

or;

aggr

essio

n

necr

otizi

ng

derm

atiti

s

LAB:

C

hole

ster

ol

dec;

glu

cose

dec

PATH

: Li

ver-w

eigh

t de

c, g

lyco

gen

dec

Kidn

ey-w

eigh

t de

c H

eart-

wei

ght

dec

Sple

en-w

eigh

t de

c

LAB:

R

etic

uloc

ytes

, er

ythr

ocyt

es,

hem

atoc

rit,

Hb

dec;

MC

HC

, M

CH

inc;

AST

, AL

T in

c; K

and

cr

eatin

ine

inc;

sod

ium

in

c/de

c ur

ine-

vol

inc,

dilu

te,

Na

and

K in

c

old

rats

is u

ncle

ar;

in p

artic

ular

th

e si

gnifi

canc

e of

effe

cts s

een

only

at t

he

inte

rmed

iate

do

se (

dec

in r

etic

uloc

ytes

, er

ythr

ocyt

es,

hem

atoc

rit,

Hb,

and

Inc

in

MC

HC

an

d M

CH

), an

d th

ose

para

met

ers

that

sho

w bo

th a

n in

crea

se

and

a de

crea

se a

re q

uest

iona

ble;

th

ere

are

no d

ata

betw

een

1 m

onth

an

d 24

m

onth

s ap

art

from

a 6

mon

th

im s

tudy

wh

ich

is n

ot c

ompa

rabl

e;

thes

e da

ta d

o no

t pr

ovid

e an

y ev

iden

ce i

n su

ppor

t of

lo

ng-te

rm

stud

ies;

targ

et o

rgan

(h

emop

oiet

ic sy

stem

) was

iden

tifie

d w

ithin

3

mon

ths

Dog

Ora

l

NSA

I

0.5

CLI

N:

Dea

th,

body

wt

dec;

ano

rexia

; C

LIN

: Sh

iver

ing

follo

win

g do

sing

All

maj

or

effe

cts w

ere

seen

with

in

6 1

subd

ued

afte

r do

sing;

m

onth

s; a

ll ta

rget

org

ans

(GI

tract

, liv

er,

1.5

diar

rhea

; vo

miti

ng;

kidn

eys,

eye

s) w

ere

iden

tifie

d w

ithin

1

2 sa

livat

ion;

eye

-lent

icul

ar

mon

th

6 ch

ange

s, c

omea

l ed

ema,

10

in

traoc

ular

te

nsio

n de

c

LAB:

R

ed c

ell p

aram

eter

s de

c;

LAB:

Bl

ood

in u

rine

lym

phoc

ytes

inc

/dec

; al

bum

in,

gluc

ose,

chl

orid

e de

c; c

reat

inin

e,

SAP,

BU

N

inc;

cho

lest

erol

in

c/de

c; (

u-2

glob

inc

/dec

; ur

ine-

pr

otei

n,

vol

inc;

SG

, O

P de

c; p

H i

nc/d

ec

PATH

: Li

ver-w

eigh

t in

c, f

atty

ch

ange

s, c

loud

y sw

ellin

g,

glyc

ogen

de

c Ki

dney

-wei

ght

inc,

tub

ular

di

latio

n/fa

tty

chan

ges,

gl

omer

ular

sc

hler

osis

, clo

udy

swel

ling,

co

nges

tion/

IW

XOSiS

Eye-

cata

ract

s,

dege

nera

tion,

va

cuol

atio

n H

eart-

necr

osis

/cal

cific

atio

n,

myo

card

ial

fatty

ch

ange

s/cl

oudy

sw

ellin

g Lu

ng-c

onge

stio

n,

pneu

mon

itis,

emph

ysem

a, e

dem

a G

I-hem

orrh

age,

ul

cera

tion,

in

flam

mat

ion

Thyr

oid-

colu

mna

r ep

ithel

ial

CdIS

Sple

en-e

nlar

ged,

co

nges

tion,

at

roph

y Ly

mph

no

de-s

inus

ca

tarrh

Bo

ne m

arro

w-ly

mph

o-

cyte

s dec

, m

ono-

cy

tes

inc

Pitu

itary

an

d ad

rena

ls-w

eigh

t inc

15

Prim

ate

Ora

l

NSA

I

1 C

LIN

: de

ath;

bod

y wt

and

/or

gain

6

dec;

food

inta

ke

dec;

loos

e 12

fe

ces w

ith

pass

age

of b

lood

/ m

ucus

/tiss

ue d

ebris

, ed

ema

of fa

ce, c

hest

, abd

omen

; de

terio

ratio

n in

con

dition

Inte

rstit

ial

neph

ritis

was

first

obs

erve

d at

8

mon

ths

and

is p

roba

bly

not

treat

men

t re

late

d; t

hym

us w

eigh

t de

crea

se is

pr

obab

ly

a no

nspe

cific

ef

fect

due

to

stre

ss; th

ese

findi

ngs

do n

ot ju

stify

a

12-

;5

mon

th

stud

y; d

ose

leve

ls u

sed

in t

he

12-

:

TABL

E 2-

Con

tinue

d

;;,

Gro

up

com

men

ts

and

conc

lusi

ons

(targ

et

Stud

y Sp

ecie

s rou

te

Tim

e”

orga

ns i

dent

ified

by

the

com

pany

no

. th

er c

l (m

onth

s)

Effe

cts o

bser

ved

with

in

6 m

onth

s E

ffect

s obs

erve

d af

ter

6 m

onth

s to

xico

logi

st

who

urov

ided

th

e da

ta)

16

17

Prim

ate

oral

CN

S

I 6 12

Prim

ate

Ora

l

NSA

I

1 C

LIN

: Bo

dy w

t ga

in,

food

int

ake

dec;

6

saliv

atio

n; r

ash;

poo

r wo

und

12

heal

ing;

los

s of

con

ditio

n;

18

feca

l OB+

; vo

miti

ng

LAB:

R

ed c

ell p

aram

eter

s de

c;

prot

ein,

al

bum

in

dec;

LAP

, SA

LT

dec;

urin

e-br

own,

os

mol

ality

de

c

PATH

: G

I-hem

orrh

age/

eros

ion

-sub

muc

osal

ed

ema

in

colo

n

CLI

N:

deat

h; b

ody

wt l

oss;

food

in

take

dec

; dia

rrhea

, bl

ood

in f

eces

; abd

omin

al

dist

ensi

on;

skin

ulce

ratio

n

LAB:

An

emia

; er

ythr

ocyt

e hy

poch

rom

asia

; ES

R i

nc;

retic

uloc

ytos

is;

leuc

ocyt

osis

; ur

ea i

nc;

SAP

dec;

urin

e-

bloo

d,

cast

s

mon

th

stud

y ar

e hi

gher

th

an t

hose

use

d in

the

6-m

onth

st

udy;

targ

et o

rgan

(G

I tra

ct)

was

iden

tifie

d w

ithin

3

mon

ths

PATH

: Ki

dney

-inte

rstit

ial

neph

ritis

Thym

us-w

eigh

t de

c

PATH

: Ki

dney

-epi

thel

ial

necr

obio

tic

PATH

: Ki

dney

-pap

illary

tip

nec

rosi

s/

chan

ges

in

hem

orrh

age/

edem

a co

llect

ing

tubu

les

GI-u

lcera

tion/

eros

ion

LAB:

R

BC,

Hb,

PC

V de

c; c

lotti

ng

LAB:

LD

H

inc;

SAP

inc

; po

tasi

um

dec/

te

sts

abno

rmal

; AL

T,

AST

inc

inc;

circ

ulat

ing

thyr

oid

horm

one

leve

ls d

ec; u

rine-

Epith

elia

l ne

crob

iotic

ch

ange

s we

re

obse

rved

in

the

rena

l co

llect

ing

tubu

les

with

in

6 m

onth

s; t

he k

idne

y wa

s th

eref

ore

iden

tifie

d as

a ta

rget

org

an,

and

5

the

12 m

onth

s st

udy

did

not

elic

it an

y co

mpl

etel

y ne

w to

xico

logi

cal

findi

ngs:

5

papi

llary

tip

cha

nges

wer

e se

en fi

rst a

t 12

&

mon

ths

in o

nly

l/10

high

-dos

e an

imal

G

an

d th

is d

ose

had

been

inc

reas

ed a

t 6

mon

ths;

th

ese

data

do

not

prov

ide

any

evid

ence

in

supp

ort

of lo

ng-te

rm

stud

ies.

Ta

rget

or

gans

(G

I tra

ct a

nd k

idne

ys)

were

ide

ntifi

ed

with

in

3 m

onth

s

Alth

ough

liv

er w

eigh

t in

crea

se a

nd e

nzym

e ch

ange

s we

re n

ot o

bser

ved

until

12

mon

ths,

tox

ic l

iver

inj

ury

had

been

no

ted

with

in

6 m

onth

s; e

ffect

s on

the

liver

wer

e ex

pect

ed b

ased

on

the

acut

e to

xici

ty o

f thi

s co

mpo

und,

th

e ef

fect

on

pota

ssiu

m s

een

at 1

2 m

onth

s is

pro

babl

y no

t si

gnifi

cant

in

view

of t

he v

aria

ble

chan

ge; t

he f

indi

ngs

afte

r 6

mon

ths

do

bile

pig

men

ts,

lack

of

conc

entra

ting

abilit

y

PATH

: Li

ver-t

oxic

in

jury

, ce

ntril

obul

ar

PATH

: Li

ver-w

eigh

t in

c

swel

ling

swol

len

hepa

tocy

tes

Kidn

ey-w

t in

c, d

isten

ded

tubu

les,

ne

cros

is

G&c

onge

stio

n,

hem

orrh

age,

in

flam

m.,

dege

nera

tion,

ne

cros

is,

ulce

ratio

n

18

Prim

ate

Ora

l

NSA

I

6 C

LIN

: D

eath

/kille

d du

e to

poo

r C

LIN

: Sh

iver

ing

12

cond

ition;

bo

dy w

t de

c;

leth

argy

; po

or b

ody

cond

ition;

vo

miti

ng;

bloo

d/

muc

us i

n fe

ces;

abdo

min

al

pain

; sk

in u

lcera

tion

and

pale

are

as

LAB:

N

eutro

philia

an

d ly

mph

open

ia;

WBC

in

c;

plat

elet

s in

c; a

nem

ia;

hypo

chro

mas

ia

and

anis

ocyt

osis

; ES

R in

c;

albu

min

de

c; S

AP d

ec; u

rea

dec

PATH

: N

ervo

us s

yste

m-C

SF

inc

GI

tract

-ulc

erat

ion,

ed

ema,

in

flam

mat

ory

cell

infil

trate

s Ad

rena

ls-en

larg

ed,

corti

cal

hype

rpla

sia

Thym

us-a

troph

y Su

bcut

aneo

us

edem

a; e

xces

s pe

riton

ea&e

ricar

dial

flu

id;

perit

oniti

s;

mes

ente

ric

lym

ph

node

hyp

erpl

asia

not

ther

efor

e ju

stify

a 1

Zmon

th

stud

y;

targ

et o

rgan

s (k

idne

y, l

iver

, an

d G

I tra

ct)

were

ide

ntifi

ed

with

in

6 m

onth

s

Shiv

erin

g fir

st s

een

at 1

2 m

onth

s in

2/2

5 an

imal

s is

not

a m

ajor

ef

fect

and

not

4)

suffi

cien

t re

ason

for

con

tinui

ng

the

stud

y be

yond

6 m

onth

s; t

arge

t or

gan

(GI

tract

) E;

was

iden

tifie

d w

ithin

3

mon

ths

6 i4

E

TABL

E 2-

Con

tinue

d E;

Gro

up

com

men

ts

and

conc

lusi

ons

(targ

et

ki

Stud

y Sp

ecie

s rou

te

Tim

@

orga

ns i

dent

ified

by

the

com

pany

IlO

. th

er c

l (m

onth

s)

Effe

cts o

bser

ved

with

in

6 m

onth

s E

ffect

s obs

erve

d af

rer 6

mon

ths

toxi

colo

gist

wh

o pr

ovid

ed

the

data

)

19

Prim

ate

Ora

l

NSA

I

20

Rat

oral

GI

21

Rat

oral

1 C

LIN

: Bo

dy w

t de

c; s

ubdu

ed

12

beha

vior

LAB

No

abno

rmal

ities

PATH

: N

o ab

norm

alitie

s

1 C

LIN

: Bo

dy w

t ga

in d

ec; e

xces

s 6

saliv

atio

n 12

LA

B R

BC,

PCV

dec;

chl

orid

e in

c;

CPR

, LD

H

inc

PATH

: Ki

dney

-cor

tical

tu

bula

r ne

cros

is

1 C

LIN

: Pe

rinea

l w

etne

ss; e

xces

s 3

saliv

atio

n

LAB:

H

b de

c; c

hole

ster

ol

inc

GI

PATH

: Li

ver-w

eigh

t in

c Ki

dney

-wei

ght

inc

Thyr

oid-

hist

olog

ical

chan

ges

Ther

e is

no

stud

y wi

th

a du

ratio

n be

twee

n 1

mon

th

and

12 m

onth

s an

d th

e sa

me

dose

leve

ls w

ere

used

in t

hese

two

stud

ies;

it i

s th

eref

ore

not

know

n wh

ethe

r th

e ki

dney

effe

cts w

ould

have

PA

TH:

Kidn

ey-w

eigh

t in

c; m

icro

scop

ic

been

app

aren

t w

ithin

6

mon

ths

in t

he

corti

cal

scar

ring,

foc

al

prim

ate;

in

bot

h th

e ra

t an

d th

e do

g pa

pilla

ry

chan

ges

kidn

ey c

hang

es w

ere

obse

rved

with

in

6 m

onth

s wi

th t

his

com

poun

d,

targ

et

orga

n (k

idne

y)

was

not

iden

tifie

d un

til 12

mon

ths

beca

use

ther

e wa

s no

pa

thol

ogy

exam

inat

ion

betw

een

1 an

d 12

&

mon

ths

<

PATH

: G

I-yel

low

co

lora

tion

of g

ut

cont

ents

Col

orat

ion

of g

ut c

onte

nts

seen

afte

r 6

mon

ths

does

not

jus

tify

a 12

-mon

th

%

stud

y, a

s no

thin

g of

toxi

colo

gica

l E

sign

ifica

nce

was

lear

ned

from

thi

s F

findi

ng;

targ

et o

rgan

(ef

fect

s on

body

wt

gain

) id

entif

ied

with

in

6 m

onth

s

LAB:

U

rinar

y ca

sts,

giyc

osur

ia

A ki

dney

effe

ct (w

eigh

t in

crea

se)

had

been

se

en b

y 3

mon

ths;

ur

inar

y ca

sts

and

glyc

osur

ia w

ere

seen

in t

he d

og w

ithin

3

mon

ths

so a

lthou

gh

this

is a

new

effe

ct

for

the

rat i

t is

not

a n

ew e

ffect

for

the

com

poun

d;

the

sam

e do

se le

vels

wer

e us

ed in

all

stud

ies;

one

tar

get

orga

n (li

ver)

was

iden

tifie

d w

ithin

3

mon

ths;

th

e ki

dney

was

con

clus

ivel

y id

entif

ied

as

a ta

rget

in

this

spe

cies

with

in

12 m

onth

s,

but

had

been

ide

ntifi

ed

as a

targ

et w

ithin

3

mon

ths

in t

he d

og

22

Rat

Oral

GI

1 9 18

23

Dog

1.5

12

oral

GI

24

Rat

3 18

oral

ANTI

INF

25

Rat

6

Ora

l 18

ANTI

-NE0

1 IM

MUN

OSU

P

CLI

N:

Body

wt

gain

, fo

od i

ntak

e de

c;

lack

of g

room

ing

LAB:

C

opio

us,

dilu

te

urin

e

PATH

: N

o ab

norm

alitie

s

CLI

N:

Occ

asio

nal

saliv

atio

n;

loos

enes

s of

fece

s and

vo

miti

ng;

abno

rmal

ga

it;

hype

rexc

itabi

lity;

oc

casio

nal

rela

xatio

n of

nic

tatin

g m

embr

ane

DAB

: N

o ab

norm

alitie

s

PATH

: N

o ab

norm

alitie

s

CLI

N:

Body

wt

gain

dec

LAB:

N

o ab

norm

alitie

s

PATH

: Sa

livar

y gl

and

duct

hyp

erpl

asia

CLI

N:

Dea

th;

body

wt

dec

LAB:

R

BC,

Hb

dec;

pan

cyto

peni

a;

ALT

inc

LAB:

So

dium

in

c

PATH

: Li

ver-n

ecro

sis,

m

itosi

s PA

TH:

Bone

mar

row

-hyp

opla

stic

PATH

: Li

ver-w

eigh

t in

c R

espi

rato

ry

syst

em-h

pido

sis

CLI

N:

Dea

th

Eye-

-tran

sien

t ef

fect

on t

apet

um

lucid

um

PATH

: Li

ver

and

pros

tate

-wei

ght

dec

Ther

e ar

e no

3 o

r 6

mon

th

data

and

the

ne

w ef

fect

s wer

e se

en a

t dos

es u

p to

20X

hi

gher

tha

n th

e do

ses

used

in t

he l

- m

onth

st

udy;

no

conc

lusi

ons

caa

be

draw

n as

to w

heth

er

the

new

effe

cts

would

ha

ve b

een

seen

with

in

6 m

onth

s wi

th

a di

ffere

nt s

tudy

des

ign;

targ

et o

rgan

(lu

ng)

was

iden

tifie

d w

ithin

18

mon

ths

Dos

e le

vels

in t

he 1

2-m

onth

st

udy

were

m

ore

than

tw

ice t

hose

in t

he 6

-wee

k st

udy

and

were

dou

bled

at

Wee

k 47

; ne

w 2

findi

ngs

at 1

2 m

onth

s we

re s

een

5 w

eeks

i

a&r

this

dos

e in

crea

se,

aad

inclu

ded

1 de

ath,

a d

efin

ite

eye

effe

ct in

1 a

nim

al,

8

and

an o

bscu

re e

ye e

ffect

in 2

ani

mal

s;

g no

thin

g fro

m v

isio

n te

sts s

ugge

sted

any

to

xic

effe

ct; it

is

likel

y th

at t

hese

effe

cts

6

would

ha

ve b

een

obse

rved

with

in

6 4

mon

ths

if th

e hi

gher

dos

e le

vels

had

bee

n 2

used

thro

ugho

ut

the

stud

y; n

o ta

rget

or

gans

wer

e id

entif

ied

5 2 Th

is ca

se st

udy

com

pare

s a

3- a

ad a

n 18

- $:

m

onth

st

udy;

as

ther

e ar

e no

6-m

onth

da

ta i

t is

not

pos

sible

to

conc

lude

wh

ethe

r th

ese

orga

n we

ight

cha

nges

i2

would

ha

ve b

een

seen

with

in

6 m

onth

s;

?i

dose

le

vels

are

the

sam

e in

bot

h st

udie

s P

and

only

5 a

nim

als

were

exa

min

ed

at 3

3

mon

ths

(15

were

exa

min

ed

at I

8 m

onth

s);

no t

arge

t or

gans

wer

e id

entif

ied

in t

his

stud

y

Chan

ge i

n th

e bo

ne m

arro

w (e

xpec

ted

base

d on

the

pha

rmac

olog

y of

the

com

poun

d)

doea

not

just

ify a

long

-term

st

udy

as p

ancy

tope

aia

indi

catin

g m

arro

w da

mag

e wa

s se

en w

ithin

1

mon

th;

sodi

um

incr

ease

was

not

con

lirm

ed

in

K

LUMLEY AND WALKER

of the compound or an active metabolite. This could be brought about by high dose levels exceeding the body’s ability to detoxify or eliminate the compound or by increasing the conversion of an inactive chemical to an active metabolite.

(ii) A smaller than expected increase in blood or tissue levels may occur due to the absorption and retention mechanisms be- coming saturated or due to the chemical stim- ulating its own metabolism.

Of the 25 case studies in which apparently new findings were seen after 6 months, similar doses were used in the long- and short-term studies in 8 (Studies 2.1, 2.4, 2.14,2.19, 2.20, 2.21, 2.24, 2.25). Higher doses were used in the long-term as compared to the short-term studies in a further 6 (Studies 2.6, 2.7, 2.15, 2.17,2.22,2.23). Thus in 14/25 cases in which apparently new effects were seen after 6 months, the maximum dose was either the same or higher in the long-term as compared to the short-term study, and this may well have had a significant influence on whether or not all toxicological effects were elicited within 3- 6 months.

(b) Number of animals. In some cases the number of animals examined in the short term was too small to allow the demonstration of the pathological changes that were observed in the long-term study. This occurred in two case studies (2.5 and 2.11).

(c) Time of pathological examination. In several cases there was a large gap between the times of pathological examinations. In one case, while there were new pathological changes at 12 months, no animals were sac- rificed for examination between 1 and 12 months (2.25). No animals were sacrificed be- tween 3 and 12 months in five case studies (2.4, 2.5, 2.8, 2.9, 2.21) and in four of them new pathological changes were observed at 12 months. Again new pathological changes were seen at 18 months in the two studies in which there was no sacrifice between 3 and 18 months (2.6, 2.24). In all, these seven cases (with no 6 months’ data) where new patho-

VALUE OF LONG-TERM ANIMAL TOXICOLOGY 1023

logical changes were seen in the long-term study, there is no way of knowing when after 1 or 3 months these would have first occurred.

No 18-month dog studies were available for this analysis and therefore no insight could be gained as to changes that might occur in this species between 12 and 18 months. Toxicol- ogists of the Canadian Health Protection Branch have attempted a retrospective analysis of data contained in their files (G. Frederick, 1984, personal communication). Although they are in a similar situation of having no 18- month dog data for comparison, their current guidelines suggest 18-month toxicological data in a nonrodent species (HPB, 198 1). This is in contrast to the American FDA and the EEC which suggest that data be provided from 12- and 6-month tests in nonrodents, respectively, in support of product licence applications.

3. Dificulties in Interpreting Toxicology Studies in Aging Animals

Comments made by the company toxicol- ogists such as “terminal effects were those of senility” and “the significance of laboratory findings in old animals is not clear” emphasize the problems associated with interpreting tox- icological effects in studies of 18 and 24 months duration in rats. A differentiation must be made between stress effects resulting from the fact that the animals are generally unwell or are having to adapt to the stress of active treatment, and direct toxic effects. This may become more difficult as the age of the animal increases and according to Paget ( 1968) changes due to age are not only difficult to distinguish from those due to the administra- tion of a drug, but they may even obscure such changes. Boorman (198 1) has emphasized the importance of taking into account the back- ground of spontaneous lesions in long-term and lifetime studies. He lists several familial and aging lesions common to the rat, including nephrosis, non-neoplastic hepatic lesions such as bile duct hyperplasia, focal chronic hepa- titis, large hepatic nuclei and cysts, myocardial fibrosis, and retinal degeneration. The ques-

tion that must always be considered is whether or not observed lesions are related to, or ex- acerbated by, the compound being tested.

CONCLUSIONS

Unfortunate experiences with marketed drugs causing severe adverse reactions, despite extensive premarketing toxicological and clinical investigations, have created an at- mosphere of public apprehension and over- caution. This has resulted in a trend toward a proliferation of preclinical requirements to be completed before obtaining marketing au- thorization, including increased durations of chronic repeated-dose toxicity tests (Gross, 1979; Aldridge, 1981; Dayan, 1984). This CMR study is the first comprehensive attempt to determine whether any new findings be- came apparent during toxicity studies of longer than 6 months duration by analyzing data ob- tained from pharmaceutical companies on in- vestigational medicines. A limited number of compounds have been assessed to date and further data are currently being collected from other European countries and the United States. The information presented in this paper does not support the need for animal toxicity studies of longer than 6 months duration (with the exception of those to assess carcinogenic- ity) as these do not add materially to the overall safety evaluation of a given compound. The scientific rationale for conventional long-term studies, and in particular the premise that they are necessary in order to compensate for pos- sible shortcomings in the design of subchronic studies, must therefore be questioned.

The ultimate test of animal safety evalua- tion studies is how well they predict adverse reactions for man and clinical information for compounds contained in the CMR database is therefore being collected. Comparisons be- tween salient findings in animals and the toxic effects observed in man will be the subject of a future paper.

ACKNOWLEDGMENTS

We are grateful to the following companies for sup porting this study and particularly for providing data: The

1024 LUMLEY AND WALKER

Boots Company plc, Beecham Pharmaceuticals, Ciba- Geigy Pharmaceuticals, Fisons plc, Glaxo Group Research Limited, May & Baker Limited, Plizer Limited, Reckitt & Colman plc, Roche Products Limited, Smith, Kline and French Research Limited, Sterling-Winthrop Group Lim- ited, Wellcome Research Limited, and Wyeth Research (UK) Limited. The group which met to discuss the data was composed of representatives from these companies and three independent toxicologists from academia. The help of our colleagues at the CMR is gratefully acknowl- edged and in particular the assistance of Mrs. Elaine Smith and Mrs. Sheila Wright with the preparation of this manu- script.

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