PART I: HEALTH PROFESSIONAL INFORMATION 3

SUMMARY PRODUCT INFORMATION 3 INDICATIONS AND CLINICAL USE 3 CONTRAINDICATIONS 4 WARNINGS AND PRECAUTIONS 4 ADVERSE REACTIONS 8 DRUG INTERACTIONS 10 DOSAGE AND ADMINISTRATION 10 OVERDOSAGE 11 ACTION AND CLINICAL PHARMACOLOGY 12 STORAGE AND STABILITY 14 SPECIAL HANDLING INSTRUCTIONS 14 DOSAGE FORMS, COMPOSITION AND PACKAGING 14

PART II: SCIENTIFIC INFORMATION 15

PHARMACEUTICAL INFORMATION 15 CLINICAL TRIALS 16 DETAILED PHARMACOLOGY 16 TOXICOLOGY 38 REFERENCES 48

PART III: CONSUMER INFORMATION. 50

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FLUDARABINE PHOSPHATE FOR INJECTION

(Fludarabine Phosphate)

Route of Administration Dosage Form / Strength Clinically Relevant Nonmedicinal Ingredients
Intravenous infusion Solution/ 25 mg/mL None For a complete listing see Dosage Forms, Composition and Packaging section.

PART I: HEALTH PROFESSIONAL INFORMATION SUMMARY PRODUCT INFORMATION

INDICATIONS AND CLINICAL USE

FLUDARABINE PHOSPHATE FOR INJECTION is indicated for:

Geriatrics (> 75 years of age):

Since there are limited data for the use of fludarabine phosphate in elderly persons (> 75 years), caution should be exercised with the administration of FLUDARABINE PHOSPHATE FOR INJECTION in these patients. The total body clearance of the principal plasma metabolite 2F- ara-A shows a correlation with creatinine clearance, indicating the importance of the renal excretion pathway for the elimination of the compound. Patients with reduced kidney function demonstrated an increased total body exposure (AUC of 2F-ara-A). Limited clinical data are available in patients with impairment of renal function (creatinine clearance below 70 mL/min). Since renal impairment is frequently present in patients over the age of 70 years, creatinine clearance should be measured. If creatinine clearance is between 30 and 70 mL/min, the dose should be reduced by up to 50%, and close hematologic monitoring should be used to assess toxicity. Fludarabine phosphate treatment is contraindicated, if creatinine clearance is <30 mL/min. (See WARNINGS AND PRECAUTIONS and DOSAGE AND ADMINISTRATION).

Pediatrics:

The safety and effectiveness of fludarabine phosphate in children have not been established.

CONTRAINDICATIONS

WARNINGS AND PRECAUTIONS

Serious Warnings and Precautions

FLUDARABINE PHOSPHATE FOR INJECTION should be administered under the supervision of, or prescribed by, a qualified physician experienced in the use of antineoplastic therapy. Fludarabine phosphate can severely suppress bone marrow function. When used at high doses in dose-ranging studies in patients with acute leukemia, intravenous fludarabine phosphate was associated with severe irreversible neurologic effects, including blindness, coma, and death. This severe central nervous system toxicity occurred in 36% of patients treated intravenously with doses approximately four times greater (96 mg/m2/day for 5-7 days) than the recommended dose. In patients treated at doses in the range of the dose recommended for chronic lymphocytic leukemia (CLL) and low-grade non-Hodgkin's lymphoma (Lg-NHL), severe central nervous system toxicity occurred rarely (coma, seizures and agitation) or uncommonly (confusion). Patients should be closely observed for signs of neurologic side effects. Instances of life-threatening and sometimes fatal autoimmune hemolytic anemia have been reported to occur during or after treatment with fludarabine phosphate. The causality of the development of this complication has not been identified. Patients undergoing treatment with FLUDARABINE PHOSPHATE FOR INJECTION should be evaluated and closely monitored for signs of autoimmune hemolytic anemia (a decline in hemoglobin linked with hemolysis and a positive Coombs' test). Discontinuation of therapy with FLUDARABINE PHOSPHATE FOR INJECTION is recommended in the event of hemolysis. The transfusion of irradiated blood and the administration of corticosteroids are the most common treatment measures for autoimmune hemolytic anemia. In a clinical investigation using fludarabine phosphate in combination with pentostatin (deoxycoformycin) for the treatment of refractory CLL, there was an unacceptably high incidence of fatal pulmonary toxicity. Therefore, the use of fludarabine phosphate in combination with pentostatin is contraindicated.

General

FLUDARABINE PHOSPHATE FOR INJECTION is a potent antineoplastic agent with potentially significant toxic side effects. Patients undergoing therapy should be closely observed for signs of hematologic and nonhematologic toxicity. Periodic assessment of peripheral blood counts is recommended to detect the development of neutropenia, thrombocytopenia, anemia and leukopenia. Vaccination with live vaccines should be avoided during and after treatment with FLUDARABINE PHOSPHATE FOR INJECTION.

Gastrointestinal

In clinical trials with oral fludarabine phosphate, nausea/vomiting and/or diarrhea were reported in approximately 38% of patients. In most cases, the severity was mild to moderate (WHO toxicity grading). Only a small percentage of patients, approximately 1 % with nausea/vomiting and 5% with diarrhea, required therapy. Patients with prolonged, clinically relevant, nausea/vomiting and diarrhea should be closely monitored to avoid dehydration.

Hematologic

In patients with an impaired state of health, FLUDARABINE PHOSPHATE FOR INJECTION should be given with caution and after careful risk/benefit consideration. This applies especially to patients with severe impairment of bone marrow function (thrombocytopenia, anemia, and/or granulocytopenia), immunodeficiency or with a history of opportunistic infection. Prophylactic treatment should be considered in patients at increased risk of developing opportunistic infections (see ADVERSE REACTIONS). Bone marrow suppression, notably thrombocytopenia, anemia, leukopenia and neutropenia, may occur with administration of fludarabine phosphate and requires careful hematologic monitoring. In a Phase I study in solid tumor patients, the median time to nadir counts was 13 days (range, 3- 25 days) for granulocytes and 16 days (range, 2-32 days) for platelets. Most patients had hematologic impairment at baseline either as a result of disease or as a result of prior myelosuppressive therapy. Cumulative myelosuppression may be seen. While chemotherapy- induced myelosuppression is often reversible, administration of FLUDARABINE PHOSPHATE FOR INJECTION requires careful hematologic monitoring. Several instances of trilineage bone marrow hypoplasia or aplasia resulting in pancytopenia, sometimes resulting in death, have been reported in adult patients. The duration of clinically significant cytopenia in the cases reported has ranged from approximately 2 months to approximately 1 year. These episodes have occurred in both previously treated and untreated patients. Instances of life-threatening and sometimes fatal autoimmune phenomena (e.g. autoimmune hemolytic anemia, autoimmune thrombocytopenia, thrombocytopenic purpura, pemphigus, acquired hemophilia and Evans' syndrome) have been reported to occur during or after treatment with fludarabine phosphate in patients with or without a previous history of autoimmune processes or a positive Coombs' test and who may or may not be in remission from their disease. Steroids may or may not be effective in controlling these hemolytic episodes. One study was performed with 31 patients with hemolytic anemia related to the administration of fludarabine phosphate. Since the majority (90%) of these patients rechallenged with fludarabine phosphate developed a recurrence in the hemolytic process, rechallenge with FLUDARABINE PHOSPHATE FOR INJECTION should be avoided. The mechanisms which predispose patients to the development of this complication have not been identified. Patients undergoing treatment with fludarabine phosphate should be evaluated and closely monitored for signs of autoimmune hemolytic anemia (a decline in hemoglobin linked with hemolysis and a positive Coombs' test). Discontinuation of therapy with FLUDARABINE PHOSPHATE FOR INJECTION is recommended in the event of hemolysis. The transfusion of irradiated blood and the administration of corticosteroids are the most common treatment measures for autoimmune hemolytic anemia. Tumor lysis syndrome associated with fludarabine phosphate treatment has been reported in CLL patients with large tumor burdens. Since fludarabine phosphate can induce a response as early as the first week of treatment, precautions should be taken in those patients at risk of developing this complication. Transfusion-associated graft-versus-host disease (reaction by the transfused immunocompetent lymphocytes to the host) has been observed rarely after transfusion of non- irradiated blood in patients treated with fludarabine phosphate. Fatal outcome as a consequence of this disease has been reported with a high frequency. Therefore, to minimize the risk of transfusion-associated graft-versus-host disease, patients who require blood transfusion and who are undergoing, or who have received treatment with fludarabine phosphate should receive irradiated blood only. Disease progression and transformation (e.g. Richter's Syndrome) have been commonly reported in CLL patients.

Hepatic/Biliary/Pancreatic

No data are available concerning the use of fludarabine phosphate in patients with hepatic impairment. In this group of patients, FLUDARABINE PHOSPHATE FOR INJECTION should be used with caution and administered if the perceived benefit outweighs any potential risk.

Neurologic

When high doses of fludarabine phosphate were administered in dose-ranging studies in acute leukemia patients, a syndrome with delayed onset, characterized by blindness, coma, and death was identified. Symptoms appeared from 21 to 60 days post dosing (however, in post marketing experience, cases of neurotoxicity have been reported to occur both earlier and later than seen in clinical trials). Demyelination, especially of the occipital cortex of the brain was noted. The majority of these cases occurred in patients treated intravenously with doses approximately four times greater (96 mg/m2/day for 5-7 days) than the recommended dose. Thirteen of 36 patients (36.1%) who received fludarabine phosphate at high doses ($ 96 mg/m2/day for 5 to 7 days per course) developed severe neurotoxicity, while only one of 443 patients (0.2%) who received the drug at low doses (#40 mg/m2/day for 5 days per course) developed the toxicity. In patients treated at doses in the range of the dose recommended for CLL and Lg-NHL, severe central nervous system toxicity occurred rarely (coma, seizures and agitation) or uncommonly (confusion). The effect of chronic administration of fludarabine phosphate on the central nervous system is unknown. In some studies, however, patients tolerated the recommended dose, for relatively long treatment periods (up to 26 courses of therapy). Periodic neurological assessments are recommended.

Renal

The total body clearance of the principal plasma metabolite 2F-ara-A shows a correlation with creatinine clearance, indicating the importance of the renal excretion pathway for the elimination of the compound. Patients with reduced renal function demonstrated an increased total body exposure (AUC of 2F-ara-A). Limited clinical data are available in patients with impairment of renal function (creatinine clearance below 70 mL/min). Therefore, if renal impairment is clinically suspected, or the patient is over the age of 70 years, creatinine clearance should be measured. If creatinine clearance is between 30 and 70 mL/min, the dose should be reduced by up to 50% and close hematological monitoring should be used to assess toxicity. FLUDARABINE PHOSPHATE FOR INJECTION treatment is contraindicated, if creatinine clearance is < 30 mL/min. (See DOSAGE AND ADMINISTRATION).

Sexual Function/Reproduction

Preclinical toxicology studies in mice, rats and dogs have demonstrated dose-related adverse effects on the male reproductive system. Observations consisted of a decrease in mean testicular weights in dogs and degeneration and necrosis of spermatogenic epithelium of the testes in mice, rats and dogs. The possible adverse effects on fertility in males and females in humans have not been adequately evaluated. Therefore, it is recommended that females of child-bearing potential and males take contraceptive measures during FLUDARABINE PHOSPHATE FOR INJECTION therapy, and for at least 6 months after the cessation of FLUDARABINE PHOSPHATE FOR INJECTION therapy.

Skin

Reversible worsening or flare-ups of pre-existing skin cancer lesions has been reported to occur in some patients during or after intravenous fludarabine phosphate therapy.

Special Populations

Pregnant Women:

Fludarabine phosphate has been shown to be teratogenic in rats and in rabbits. A study in rats demonstrated a transfer of fludarabine phosphate and/or metabolites across the placental barrier.

One case of fludarabine phosphate use during early pregnancy leading to skeletal and cardiac malformation in the newborn has been reported. FLUDARABINE PHOSPHATE FOR INJECTION should not be used during pregnancy. Women of child-bearing potential should be advised to avoid becoming pregnant and to inform the treating physician immediately should this occur.

Nursing Women:

It is not known whether fludarabine phosphate is excreted in human milk.

However, there is evidence from animal data that fludarabine phosphate and/or metabolites transfer from maternal blood to milk. Therefore, breast-feeding should be discontinued during FLUDARABINE PHOSPHATE FOR INJECTION therapy.

Pediatrics:

The safety and effectiveness of fludarabine phosphate in children have not been established.

Geriatrics (> 75 years of age): DOSAGE AND ADMINISTRATION

Since there are limited data for the use of fludarabine phosphate in elderly persons (> 75 years), caution should be exercised with the administration of FLUDARABINE PHOSPHATE FOR INJECTION in these patients. The total body clearance of the principal plasma metabolite 2F-ara-A shows a correlation with creatinine clearance, indicating the importance of the renal excretion pathway for the elimination of the compound. Patients with reduced kidney function demonstrated an increased total body exposure (AUC of 2F-ara-A). Limited clinical data are available in patients with impairment of renal function (creatinine clearance below 70 mL/min). Since renal impairment is frequently present in patients over the age of 70 years, creatinine clearance should be measured. If creatinine clearance is between 30 and 70 mL/min, the dose should be reduced by up to 50%, and close hematologic monitoring should be used to assess toxicity. Fludarabine phosphate treatment is contraindicated, if creatinine clearance is <30 mL/min. (See

).

Monitoring and Laboratory Tests

During treatment, the patient's hematologic (particularly neutrophils and platelets) and serum chemistry profiles should be monitored regularly.

Effects on Ability to Drive and Operate Machines

The effect of treatment with fludarabine phosphate on the patient's ability to drive or operate machinery has not been evaluated.

ADVERSE REACTIONS

Adverse Drug Reaction Overview

The most common adverse events occurring with fludarabine phosphate use include myelosuppression (anemia, leukopenia, neutropenia and thrombocytopenia), leading to decreased resistance to infection, including pneumonia, cough, fever, fatigue, weakness, nausea, vomiting and diarrhea. Other commonly reported events include chills, edema, malaise, peripheral neuropathy, visual disturbances, anorexia, mucositis, stomatitis and skin rash. Serious opportunistic infections have occurred in patients treated with fludarabine phosphate. Fatalities as a consequence of serious adverse events have been reported. The most frequently reported adverse events and those reactions which are more clearly related to the drug are listed below according to body system regardless of their seriousness. Their frequency (very common $1/10, common $1/100 to < 1/10, uncommon $1/1000 to <1/100) is based on clinical trial data regardless of the causal relationship with fludarabine phosphate. The rare events ($1/10000 to <1/1000) were mainly identified from post-marketing experience.

Body as a Whole

Infection, fever, fatigue and weakness have been reported very commonly in patients receiving fludarabine phosphate. Malaise and chills have been commonly reported.

Hematopoietic and Lymphatic System

Hematologic events (neutropenia, thrombocytopenia and anemia) have been reported in the majority of patients treated with fludarabine phosphate. Myelosuppression may be severe and cumulative. The prolonged effect of fludarabine phosphate on the decrease in the number of T- lymphocytes may lead to increased risk of opportunistic infections, including those due to latent viral reactivation, eg. herpes zoster virus, Epstein-Barr-Virus (EBV) and progressive multifocal leukoencephalopathy. Evolution of EBV-infection/reactivation into EBV-associated lymphoproliferative disorder has been observed in immunocompromised patients. Life- threatening and sometimes fatal autoimmune hemolytic anemia has been reported to occur in patients receiving fludarabine phosphate. The majority of patients rechallenged with fludarabine phosphate developed a recurrence in the hemolytic process. (See WARNINGS AND PRECAUTIONS section for information on autoimmune hemolytic anemia associated with fludarabine phosphate). In rare cases, the occurrence of myelodysplastic syndrome (MDS) has been described in patients treated with fludarabine phosphate. The majority of these patients also received prior, concomitant or subsequent treatment with alkylating agents or irradiation. Monotherapy with fludarabine phosphate had not been associated with an increased risk of development of MDS.

Nervous System

Following administration of fludarabine phosphate at doses of 20-30 mg/m2/day in 133 patients with CLL, reported events included weakness, visual disturbances, loss of hearing, numbness, agitation, confusion, seizure and coma. Peripheral neuropathy has been commonly observed. Confusion is uncommon. Coma, seizures and agitation occur rarely. There was one case of wrist drop. (See WARNINGS AND PRECAUTIONS section for information on neurotoxicity associated with high doses of fludarabine phosphate).

Special Senses

Visual disturbances are commonly reported events in patients treated with fludarabine phosphate. In rare cases, optic neuritis, optic neuropathy and blindness have occurred.

Respiratory System

Pneumonia has been commonly reported. Pneumonia, a frequent manifestation of infection in CLL patients occurred in 16% and 22% of those treated with fludarabine phosphate in the MDACC and SWOG studies, respectively. Pulmonary hypersensitivity reactions to fludarabine phosphate (pulmonary infiltrates, pneumonitis, fibrosis) characterized by dyspnea, and cough are uncommon.

Digestive System

Gastrointestinal disturbances such as nausea and vomiting, anorexia, diarrhea, mucositis and stomatitis are commonly reported. Gastrointestinal bleeding, mainly related to thrombocytopenia, has been reported in patients treated with fludarabine phosphate.

Skin and Appendages

Skin rashes have been commonly reported in patients treated with fludarabine phosphate. In rare cases, a Stevens-Johnson syndrome or toxic epidermal necrolysis (Lyell's disease) may develop.

Cardiovascular System

One patient developed a pericardial effusion possibly related to treatment with fludarabine phosphate. Rare instances of heart failure and arrhythmia have been reported in patients treated with fludarabine phosphate.

Urogenital System

Rare cases of hemorrhagic cystitis have been reported in patients treated with fludarabine phosphate.

Metabolic an Nutritional Disorders

Tumor lysis syndrome has been reported in CLL patients treated with fludarabine phosphate. This complication may include hyperuricaemia, hyperphosphatemia, hypocalcemia, metabolic acidosis, hyperkalemia, hematuria, urate crystalluria and renal failure. The onset of this syndrome may be heralded by flank pain and hematuria. Edema has been commonly reported. Changes in hepatic and pancreatic enzymes levels are uncommon. The spectrum of adverse reactions reported in patients (n=3000) receiving fludarabine phosphate in studies of lymphomas, other leukemias and solid tumors is consistent with the above data.

DRUG INTERACTIONS

Serious Drug Interactions

In a clinical investigation using fludarabine phosphate in combination with pentostatin (deoxycoformycin) for the treatment of refractory CLL, there was an unacceptably high incidence of fatal pulmonary toxicity. Therefore, the use of fludarabine phosphate in combination with pentostatin is contraindicated.

Drug-Drug Interactions

The therapeutic efficacy of fludarabine phosphate may be reduced by dipyridamole and other inhibitors of adenosine uptake.

DOSAGE AND ADMINISTRATION

Dosing Considerations

Incompatibilities

The formulation for intravenous use must not be mixed with other drugs.

Recommended Dose and Dosage Adjustment

The usual starting dose of fludarabine phosphate is 25 mg/m2 administered intravenously over a period of approximately 30 minutes, daily for five days every 28 days. Dosage may be decreased based on evidence of hematologic or nonhematologic toxicity. Note that in patients with decreased renal function (creatinine clearance between 30 and 70 mL/min) the dose should be reduced by up to 50%. Fludarabine phosphate treatment is contraindicated, if creatinine clearance is <30 mL/min. (See WARNINGS AND PRECAUTIONS). The duration of treatment depends on the treatment success and the tolerability of the drug. FLUDARABINE PHOSPHATE FOR INJECTION should be administered up to the achievement of a maximal response (complete or partial remission, usually 6 cycles) and then the drug should be discontinued.

Administration

Studies in animals have shown that even in cases of misplaced injections, no relevant local irritation was observed after paravenous, intraarterial, and intramuscular administration of an aqueous solution containing 7.5 mg fludarabine phosphate/mL. It is strongly recommended that fludarabine phosphate should be only administered intravenously. No cases have been reported in which paravenously administered fludarabine phosphate led to severe local adverse reactions. However, unintentional paravenous administration should be avoided. FLUDARABINE PHOSPHATE FOR INJECTION comes prepared for parenteral use. Each mL of the solution contains 25 mg of fludarabine phosphate, 25 mg of mannitol and 3.30 mg of sodium hydroxide. The pH range of the final solution is 6.0-7.1. The product must be further diluted for intravenous infusion administration in PVC bags to a concentration of 1 mg/mL in 5% Dextrose Injection USP, or in 0.9% Sodium Chloride Injection USP.

Missed Dose

In the event that a dose is missed the opinion of an oncologist should be sought.

OVERDOSAGE

Higher than recommended doses of fludarabine phosphate have been associated with an irreversible central nervous system toxicity characterized by delayed blindness, coma and death. High doses are also associated with bone marrow suppression manifested by thrombocytopenia and neutropenia. There is no known specific antidote for fludarabine phosphate overdosage. Treatment consists of drug discontinuation and supportive therapy.

ACTION AND CLINICAL PHARMACOLOGY

Mechanism of Action

FLUDARABINE PHOSPHATE FOR INJECTION is a fluorinated analog of adenine that is relatively resistant to deamination by adenosine deaminase. Fludarabine phosphate (2F-ara-AMP) is a water-soluble prodrug, which is rapidly dephosphorylated to 2-fluoro-ara-A (2F-ara-A) and then phosphorylated intracellularly by deoxycytidine kinase to the active triphosphate 2-fluoro-ara-ATP (2F-ara-ATP). The antitumor activity of this metabolite is the result of inhibition of DNA synthesis via inhibition of ribonucleotide reductase, DNA polymerase a, d and g, DNA primase and DNA ligase. Furthermore, partial inhibition of RNA polymerase II and consequent reduction in protein synthesis occur. While some aspects of the mechanism of action of 2F-ara-ATP are as yet unclear, it is believed that effects on DNA, RNA and protein synthesis all contribute to the inhibition of cell growth, with inhibition of DNA synthesis being the dominant factor. In addition, in vitro studies have shown that exposure of CLL lymphocytes to 2F-ara-A triggers extensive DNA fragmentation and apoptosis. Two open-label studies of fludarabine phosphate have been conducted in patients with CLL refractory to at least one prior standard alkylating agent-containing regimen. Overall objective response rates were 32% in one study, and 48% in the other, with median time to response at 21 and 7 weeks respectively.

Pharmacokinetics

Cellular pharmacokinetics of fludarabine triphosphate: Maximum 2F-ara-ATP levels in leukemic lymphocytes of CLL patients were observed at a median of 4 hours and exhibited considerable variation with a median peak concentration of approximately 20 FM. 2F-ara-ATP levels in leukemic cells were always considerably higher than maximum 2F-ara-A levels in the plasma, indicating an accumulation at the target sites. In vitro incubation of leukemic lymphocytes showed a linear relationship between extracellular 2F-ara-A exposure (product of 2F-ara-A concentration and duration of incubation) and intracellular 2F-ara-A enrichment. Two independent investigations respectively reported median half-life values of 15 and 23 hours for the elimination of 2F-ara-ATP from target cells. No clear correlation was found between 2F-ara-A pharmacokinetics and treatment efficacy in cancer patients; however, the occurrence of neutropenia and hematocrit changes indicated that the cytotoxicity of fludarabine phosphate depresses hematopoiesis in a dose-dependent manner. Plasma and urinary pharmacokinetics of fludarabine (2F-ara-A): Phase I studies in humans have demonstrated that fludarabine phosphate is rapidly converted to the active metabolite, 2F- ara-A, within minutes after intravenous infusion. Consequently, clinical pharmacology studies have focused on 2F-ara-A pharmacokinetics. After single doses of 25 mg 2F-ara-AMP/m2 to cancer patients infused over 30 minutes, 2F-ara-A reached mean maximum concentrations in the plasma of 3.5 - 3.7 FM at the end of infusion. Corresponding 2F-ara-A levels after the fifth dose showed a moderate accumulation with mean maximum levels of 4.4 - 4.8 FM at the end of infusion. During a 5-day treatment cycle, 2F-ara-A plasma trough levels increased by a factor of about 2. Accumulation of 2F-ara-A over several treatment cycles does not occur. Post maximum levels decayed in three disposition phases with an initial half-life of approximately 5 minutes, an intermediate half-life of 1-2 hours and a terminal half-life of approximately 20 hours. An interstudy comparison of 2F-ara-A pharmacokinetics resulted in a mean total plasma clearance (CL) of 79 mL/min/m2 (2.2 mL/min/kg) and a mean volume of distribution (Vss) of 83 L/m2 (2.4 L/kg). The data showed a high interindividual variability. After i.v. and peroral administration of fludarabine phosphate plasma levels of 2F-ara-A and areas under the plasma level time curves increased linearly with the dose, whereas half-lives, plasma clearance and volumes of distribution remained constant independent of the dose indicating a dose-linear behaviour. After oral fludarabine phosphate doses, maximum 2F-ara-A plasma levels reached approximately 20-30% of corresponding i.v. levels at the end of infusion and occurred 1-2 hours after dosing. The mean systemic 2F-ara-A availability was in the range of 50-65% following single and repeated doses and was similar after ingestion of a solution or an immediate release tablet formulation. After oral doses of 2F-ara-AMP with concomitant food intake a slight increase (<10%) of systemic availability (AUC), a slight decrease in maximum plasma levels (Cmax) of 2F-ara-A and a delayed time to occurrence of Cmax was observed; terminal half-lives were unaffected. The mean steady-state volume of distribution (Vdss) of 2F-ara-A in one study was 96 L/m2 suggesting a significant degree of tissue binding. Another study, in which Vdss, for patients was determined to be 44 L/m2, supports the suggestion of tissue binding. Based upon compartmental analysis of pharmacokinetic data, the rate-limiting step for excretion of 2F- ara-A from the body appears to be release from tissue binding sites. Total body clearance of 2F-ara-A has been shown to be inversely correlated with serum creatinine, suggesting renal elimination of the compound.

Special Populations and Conditions

Renal Insufficiency: A pharmacokinetic study in patients with and without renal impairment revealed that, in patients with normal renal function, 40 to 60% of the administered i.v. dose was excreted in the urine. Mass balance studies in laboratory animals with 3H-2F-ara-AMP showed a complete recovery of radio-labelled substances in the urine. Another metabolite, 2F-ara- hypoxanthine, which represents the major metabolite in the dog, was observed in humans only to a minor extent. Patients with impaired renal function exhibited a reduced total body clearance, indicating the need for a reduced dose. Total body clearance of 2F-ara-A has been shown to be inversely correlated with serum creatinine, suggesting renal elimination of the compound. This was confirmed in a study of the pharmacokinetics of 2F-ara-A following administration of 2F- ara-AMP to cancer patients with normal renal function or varying degrees of renal impairment. The total body clearance of the principal metabolite 2F-ara-A shows a correlation with creatinine clearance, indicating the importance of the renal excretion pathway for the elimination of the compound. Renal clearance represented on average 40% of the total body clearance. In vitro investigations with human plasma proteins revealed no pronounced tendency of 2F-ara-A protein binding.

STORAGE AND STABILITY

Store FLUDARABINE PHOSPHATE FOR INJECTION under refrigeration between 2EC and 8EC. Do not freeze. Discard unused portion. FLUDARABINE PHOSPHATE FOR INJECTION contains no antimicrobial preservative and thus care must be taken to ensure the sterility of prepared solutions. Parenteral drug products should be inspected visually for particulate matter and discoloration prior to administration.

SPECIAL HANDLING INSTRUCTIONS

FLUDARABINE PHOSPHATE FOR INJECTION should not be handled by pregnant staff. Proper handling and disposal procedures should be observed, with consideration given to the guidelines used for cytotoxic drugs. Any spillage or waste material may be disposed of by incineration. Caution should be exercised in the preparation of FLUDARABINE PHOSPHATE FOR INJECTION solution. The use of latex gloves and safety glasses is recommended to avoid exposure in case of breakage of the vial or other accidental spillage. If the solution comes into contact with the skin or mucous membranes, the area should be washed thoroughly with soap and water. In the event of contact with the eyes, rinse them thoroughly with copious amounts of water. Exposure by inhalation should be avoided.

DOSAGE FORMS, COMPOSITION AND PACKAGING

Medicinal ingredients:

Each vial contains 50 mg of fludarabine phosphate.

Non-medicinal ingredients: Each vial contains 50 mg mannitol and 6.60 mg sodium hydroxide. pH: 6.0-7.1

Availability :

FLUDARABINE PHOSPHATE FOR INJECTION is supplied as 2 mL per vial of 50 mg fludarabine phosphate, 50 mg of mannitol and 6.60 mg of sodium hydroxide. FLUDARABINE PHOSPHATE FOR INJECTION is a single use vial. FLUDARABINE PHOSPHATE FOR INJECTION is supplied in a single vial carton. FLUDARABINE PHOSPHATE FOR INJECTION uses a latex free stopper.

PART II: SCIENTIFIC INFORMATION

PHARMACEUTICAL INFORMATION

Drug Substance

Common name: Fludarabine Phosphate Chemical name: 9H Purin-6-amine, 2-fluoro-9-(5-O-phosphone-b-D- arabinofuranosyl) Molecular formula and molecular mass: C10H13FN5O7P 365.21 Structural formula: Physicochemical Properties: Fludarabine phosphate is a white to almost white, crystalline powder. It has pKa values of 3.2 +- 0.1 and 5.8 +- 0.1 and pH value of 2.0 (9mg/mL in water). Fludarabine phosphate is freely soluble in dimethylsulphoxide and in dimethylacetamide; sparingly soluble in water; slightly soluble in methanol; insoluble in acetone and in dichloromethane.

CLINICAL TRIALS

Two single-arm open-label studies of fludarabine phosphate have been conducted in patients with CLL refractory to at least one prior standard alkylating-agent-containing regimen. In a study conducted by M.D. Anderson Cancer Center (MDACC), 48 patients were treated with a dose of 22-40 mg/m2 daily for 5 days every 28 days. Another study conducted by the Southwest Oncology Group (SWOG) involved 31 patients treated with a dose of 15-25 mg/m2 for 5 days every 28 days. The overall objective response rates were 48% and 32% in the MDACC and SWOG studies, respectively. The complete response rate in both studies was 13%; the partial response rate was 35% in the MDACC study and 19% in the SWOG study. These response rates were obtained using standardized response criteria developed by the National Cancer Institute CLL Working Group and achieved in heavily pre-treated patients. The ability of fludarabine phosphate to induce a significant rate of response in refractory patients suggests minimal cross- resistance with commonly used anti-CLL agents. The median time to response in the MDACC and SWOG studies was 7 weeks (range of 1 to 68 weeks) and 21 weeks (range of 1 to 53 weeks), respectively. The median duration of disease control was 91 weeks (MDACC) and 65 weeks (SWOG). The median survival of all refractory CLL patients treated with fludarabine phosphate was 43 weeks and 52 weeks in the MDACC and SWOG studies, respectively. Normalized lymphocyte count, one measure of disease regression, occurred at a median of 2 weeks (complete responders), 2 weeks (partial responders) and 22 weeks (non-responders). Rai stage improved to Stage II or better in 7 of 12 MDACC responders (58%) and in 5 of 7 SWOG responders (71%) who were Stage III or IV at baseline. In the combined studies, mean hemoglobin concentration improved from 9.0 g/dL at baseline to 11.8 g/dL at the time of response in a subgroup of anemic patients. Similarly, average platelet count improved from 63,500/mm3 to 103,300/mm3 at the time of response in a subgroup of patients who were thrombocytopenic at baseline.

DETAILED PHARMACOLOGY

Mechanism of Action

The biological activity of 2F-ara-A was assessed in a number of models. 2F-ara-A has been shown to inhibit DNA synthesis in cultured mouse leukemia L1210 cells and in an in vivo mouse L1210 leukemia model. Total RNA synthesis in vitro was not inhibited by treatment with 2F-ara- A; however, protein synthesis was reduced substantially. It has been shown that 2F-ara-A is not deaminated by adenosine deaminase, contributing to the stability of the compound. The activity, metabolism and toxicity of 2F-ara-A in the human lymphoblastoid T-cell line (CCRF-CEM) were compared with 9-b-D-arabinofuranosyl-adenine (ara-A). Inhibition of cell growth was equivalent for these two agents, provided that ara-A was protected from deamination. Similar studies conducted with CCRF-CEM showed that ara-A and 2F-ara-A exerted early killing effects preferentially during the S-phase of cell proliferation. Both compounds were converted to the triphosphate form, which accumulated intracellularly and inhibited DNA synthesis. This nucleoside metabolite, 2F-ara-ATP, was also shown to inhibit DNA polymerase a and to a lesser extent ribonucleotide reductase in mouse leukemia cells (L1210), human epithelial cells (HEp-2), and HeLa cells. In the systems tested, 2F-ara-ATP is the active metabolite which acts by inhibiting DNA polymerase a and ribonucleotide reductase thus preventing DNA synthesis. In addition, in vitro studies have shown that exposure of CLL lymphocytes to 2F-ara-A triggers extensive DNA fragmentation and apoptosis.

Antitumor Activity

The effects of schedule and route of administration on the antitumor activity of fludarabine phosphate were examined using an in vivo mouse leukemia model (implanted L1210 leukemia cells). The drug was active following intraperitoneal administration on all treatment schedules. Antitumor activity increased almost three-fold when the number of drug treatments was increased. In addition, the administration of several doses in one day was more effective than administration of one larger dose. A single administration (900 mg/kg) on day 1 produced an increased life span (ILS) of 42% while administration of a smaller dose (250 mg/kg) 3 times a day on day 1 (total dose 750 mg/kg) gave a 98% ILS. This pattern of increased activity with administration of several doses in a day was also observed with the intermittent treatment schedule. A single administration on each of 3 days (total dose 2010 mg/kg) produced an ILS of 122% while administration of a smaller dose 3 times a day over 3 days (total dose 1125 mg/kg) produced the greatest activity, a 525% ILS with 6 long-term survivors (50 day) among the tumor-bearing mice. With the administration of the drug 3 times a day on day 1, negative animal weight differences (body weight change over 5 days for test animals minus that for controls) of more than 4 grams at the highest dose evaluated suggests some acute drug toxicity. Based on equivalent total doses, administration of 3 smaller doses per day at 3-hour intervals was much more effective than a single administration for each day of treatment using the in vivo mouse leukemia model. A single oral administration of fludarabine phosphate on day 1 was not effective against the L1210 leukemia. However, when given as 5 daily oral doses, the highest non-toxic dose of the drug, defined as the dose which results in at least 7 or 8 50-day survivors among the normal mice (800 mg/kg daily on days 1-5), was effective in a maximal ILS of 50%. When the drug was administered i.v., it was more effective with daily administration for 5 days than it was with a single injection on day 1. Daily treatment for 5 days at a non-toxic dose level increased the life span of tumor-bearing mice by 71% and a higher, more toxic, treatment for 5 days produced an ILS of 95%; in contrast, in single i.v. treatment on day 1 produced a maximum ILS of 28%. The intraperitoneally (i.p.) implanted L1210 leukemia was less sensitive to fludarabine phosphate when the drug was given either intravenously (i.v.) or orally than when compared to i.p. administration. A maximal ILS value of 122% was produced following i.p. administration of 266 mg/kg on days 1-5. This same dose given by i.v. administration on days 1-5 produced an ILS value of 95%. In contrast, a dose of 1600 mg/kg given orally on days 1-5 produced only a 75% ILS. However, with both i.p. and i.v. administration, the dose that produced the maximum ILS value was toxic to the non-tumored animals. Fludarabine phosphate also demonstrated activity against the intraperitoneal implanted P388 leukemia. In two different experiments, the drug increased the life span of mice bearing the P388 leukemia by 115% and 53% following i.p. administration of 200 and 100 mg/kg injections, respectively, on days 1-9.

Cytotoxicity of Fludarabine Phosphate

Fludarabine phosphate has demonstrated significant antitumor activity against intraperitoneally (i.p.) implanted murine L1210 leukemia and the human LX-1 lung tumor xenograft. The drug has shown moderate activity against the murine subcutaneously (s.c.) implanted CD8Fl mammary epithelioma and the i.p. implanted P388 lymphocytic leukemia. Fludarabine phosphate was not active against the i.p. implanted B16 melanoma, the s.c. implanted colon tumor, or the intravenously (i.v.) implanted Lewis lung epithelioma, nor was it effective against the human CX-1 colon or MX-1 mammary xenografts in the subrenal assay.

Effects on Bone Marrow Survival and Tumor Cell Sensitivity

Fludarabine phosphate was tested in an in vitro human bone marrow cell survival assay and tumor cell sensitivity assay. The sensitivity of normal human granulocyte-macrophage colony- forming units in culture (GM-CFUC) showed a simple negative exponential curve characterized by a logarithmic decrease in survival as a function of drug concentration. Fludarabine phosphate exhibited an LD63 of 0.51ug/mL for normal human granulocyte-macrophage colony-forming units in culture (GM-CFUC). In the tumor sensitivity assay, fludarabine phosphate demonstrated an LD40 and LD78 of 0.26 and 0.77 Fg/mL, respectively. Blood and bone marrow samples obtained from patients with relapsed leukemia and lymphoma after treatment with a single dose of 20-125 mg/m2 fludarabine phosphate revealed that the area under the concentration-time curves for 2F-ara-A and 2F-ara-ATP were increased in proportion to the product dose. There was a high correlation between 2F-ara-ATP level in circulating leukemic cells and those in bone marrow cells aspirated at the same time. DNA synthetic capacity of leukemic cells was inversely related to the associated 2F-ara-ATP concentration. 2F- ara- ATP concentrations were three times higher in bone marrow cells from patients with lymphomatous bone marrow involvement than from those without evidence of marrow disease. A dose response relationship between fludarabine phosphate concentration and inhibition of DNA synthesis in leukemia cells and bone marrow cells in culture was obtained. Bone marrow progenitor cells from a normal subject and 10 patients with solid tumors, whose bone marrow was free of metastases, were treated with fludarabine phosphate and other cytotoxic drugs, using a bilayer soft agar culture. The in vitro effect of the drugs on bone marrow progenitor cells was not as toxic as expected relative to the myelosuppressive potency observed in vivo. In the case of fludarabine phosphate, it has been postulated that these findings might be related to incomplete in vitro phosphorylation to the triphosphate, 2F-ara-ATP.

Lymphocytotoxicity in Humans

Fludarabine phosphate was assessed for its lymphocytotoxicity in 11 patients receiving the investigational drug for treatment of nonhematologic cancers refractory to standard treatment. Fludarabine phosphate was administered by intravenous infusion at doses ranging from 18 mg/m2/day to 40 mg/m2/day, with each dose given on a 5-day dosing regimen. Lymphocyte subsets were determined prior to treatment and on day 5 of treatment, 4 hours after the infusion. Observations indicated that lymphocytopenia developed rapidly but was reversible. Total T- lymphocyte counts fell during all treatment regimens, with a 90% decrease in mean absolute T-cell count. All major T-lymphocyte subsets were affected. B-lymphocyte counts decreased by 50% on average. Recoveries of total mononuclear cells, total T-cells and non-T, non-B cells were reduced substantially by fludarabine phosphate treatment. B-cell recovery was not affected. These results indicate that T-cells are more sensitive than B-cells to the cytotoxic effects of fludarabine phosphate.

Modulation of T-Cell Function by Fludarabine Phosphate

The effects of fludarabine phosphate on the growth and function of bone marrow and peripheral blood mononuclear cells (PBMC) from cancer patients were evaluated. Drug toxicity was dependent on time of incubation and concentration of fludarabine phosphate tested. After a 3- hour incubation of PBMC with 1 Fg/mL of fludarabine phosphate, there was no effect on cell number whereas, after 48 hours, the cell count was 59% of control, untreated cells. In contrast, a 3-hour or 48-hour incubation of PBMC with 100 Fg/mL of fludarabine phosphate reduced cell number to 65.7% or 63% of control, respectively. Lymphocyte subpopulations of normal PBMCs were evaluated after treatment in vitro with fludarabine phosphate for 72 hours. A dose-dependent decrease in total T-cell number was noted. Incubation with 1 Fg/mL of fludarabine phosphate reduced T-cells by 16.7%; 100 Fg/mL reduced T-cells by 42%. The subset of T-cells predominantly affected was T-helper cells, reduced by 53.5% after incubation with 100Fg/mL of fludarabine phosphate. B-cells, monocytes, and natural killer cells were not reduced, but rather increased relative to control. Fludarabine phosphate also inhibited the response of PBMC to mitogens in a dose-and time-dependent manner.

In Vitro

Testing of Fludarabine Phosphate in Glioma Cell Cultures

Fludarabine phosphate was tested for growth inhibitory effects on human glioma cells isolated from patient specimens. Cells were treated with 1-10 uM of fludarabine phosphate beginning 4 days after cells were plated. After 3 more days of incubation, cell number was determined. Inhibition of cell growth was dose-dependent and approximately equal to inhibition seen after treatment with the same concentrations of 5-fluorouracil. Dose-dependent growth inhibition was also observed when interferon-beta (1-1000 IU/mL) was incubated with glioma cell cultures. Although the combination of fludarabine phosphate and 5-fluorouracil or interferon-beta produced additive inhibitory effects, no synergistic effects were observed

Pharmacokinetics (Animals)

Fludarabine phosphate and its metabolites have been studied in mice, dogs, miniature pigs, and monkeys to elucidate their pharmacokinetic, distribution, and excretion profiles. In the mouse, dog, and monkey, the pharmacokinetics of fludarabine phosphate and its major metabolite, 2F-ara-A, generally exhibited bi-compartmental characteristics after intravenous administration, with rapid clearance and relatively large volumes of distribution. The pharmacokinetic parameters of fludarabine phosphate and its metabolites are presented in Table 1 and Table 2, located on the following pages.

Tissue Distribution, Metabolism and Excretion in Animals

Tissue distribution and excretion studies were conducted with fludarabine phosphate in mice, dogs, and monkeys at doses between 30 and 500 mg/m2. Fludarabine phosphate is metabolized to 2F-ara-A and, to a lesser extent, 2F-ara-HX in the mouse and monkey, while in the dog, 2F-ara-A and 2F-ara-HX are both major metabolites. The majority of the administered compound is metabolized and then eliminated in the urine within 24 hours after dose administration. The metabolism, distribution and excretion information is presented in Table 3 located on the following pages.

Table 1

PHARMACOKINETIC PARAMETERS OF FLUDARABINE PHOSPHATE AND 2F-ARA-A

STUDY DETAIL RESULTS
Species Dose of Test Article (mg/m 2 ) Route of Admin. Metabolite t 1/2a t 1/2b Vd (mL) Clearance mL/min Comments
Mouse (BDF 1 ) 18-25 grams 40 2F-ara-AMP I.V. 2F-ara-AMP 2F-ara-A 0.7 min 31.1 min 21.2 min 113.9 min 73.4 60.6 2.40 0.37 In mice, 2F-ara-AMP is rapidly dephosphorylated to 2F-ara-A. 2F-ara-HX was also present in serum. HPLC (Waters Associates model) and TLC were used.
500 2F-ara-AMP I.V. 2F-ara-AMP 2.5 min 26.9 min 309.1 7.97
2F-ara-A 35.7 min 184.9 min 88.0 0.33
Dog (Beagle) 7.8-10.8 kg 40 2F-ara-AMP I.V. 2F-ara-AMP 2F-ara-A 2F-ara-HX 5.3 min 15.7 min 113.5 min 30.5 min 96.6 mi ---- 142,960.0 9,552.7 ---- 3,254.0 68.5 115.5 In dogs, 2F-ara-AMP is rapidly dephosphorylated to 2F- ara-A. A larger percentage of the metabolite 2F-ara-HX was found in dog serum when compared to mice. HPLC (Waters Associates model) and TLC were used.
500 2F-ara-AMP I.V. 2F-ara-AMP 9.2 min 51.5 min 196,520.0 2,646.0
2F-ara-A 4.6 min 90.3 min 7,243.5 55.6
2F-ara-HX 112.5 min ---- --- 111.2
Dog (Beagle) 2 dogs 260 2F-ara-AMP I.V. 2F-ara-A 13 min 96 min 0.712 L/kg Vd ss 5.4 mL/min/kg Total plasma clearance is more than 2-fold greater in dog than in man. The steady-state volume of distribution in man is approximately 70% larger than in dog. The terminal slope of 2F-ara-HX decay parallels the 2F-ara-A decay. Standard chromatographic and spectral assays were used.

HPLC: High performance liquid chromatography

TLC: thin layer chromatography

Table 1(Continued)

PHARMACOKINETIC PARAMETERS OF FLUDARABINE PHOSPHATE AND 2F-ARA-A

STUDY DETAIL RESULTS
Species Dose of Test Article mg/m 2 Route of Admin. Metabolite t 1/2a t 1/2b Vd (mL) Clearance mL/min/kg Comments
Monkey 20 2F-ara- I.V. 2F-ara-AMP 56 min ---- ---- ---- 2F-ara-A crosses the blood-brain barrier with a lag time
(3 animals) AMP (plasma) of 0.5 to 2.0 hours and accumulates in the CSF. To
2.5-3.1 h 21.3-35.6h ---- ---- quantify the metabolites. HPLC was used.
2F-ara-A
(plasma)
1.1-1.8h 20.4-29.8h ----- ----
2F-ara-A
(CSF)
Mouse (BDF 1 ) 25-31 grams 30 2F-ara-A I.V. 2F-ara-A 17 min 72 min ----- ----- Standard chromatographic and spectral assays were used.
Metabolites 30 min 124 min ----- -----
Dog (Beagle) 9.7-10.3 kg 30 2F-ara-A I.V. 2F-ara-A <5 min 112 min ----- ----- Standard chromatographic and spectral assays were used.
400 2F-ara-A I.V. 2F-ara-A 130 min ---- ----- -----
Monkey 30 2F-ara-A I.V. 2F-ara-A 26 min 125 min ---- ----- 12-14% of 2F-ara-A became serum protein bound.
(Rhesus)
3.9-4.6 kg 400 2F-ara-A I.V. Phosphate 131 min ---- ----- -----
Metabolites
2F-ara-A 15 min 6.7h ----- ----

HPLC high performance liquid chromatography TLC: thin layer chromatography

Table 2

PHARMACOKINETIC PARAMETERS OF FLUDARABINE PHOSPHATE AND METABOLITES

STUDY DETAILS RESULTS
Species/Test Model Test Article Dose Route of Admin. Metabolite t 1/2 Time to C m ax C max Comments
Mouse (BD2F 1 ) P388 Tumor cell Model 1,485 mg/kg 2F-ara-AMP I.P. 2F-ara-AMP 2F-ara-A 2F-ara-A 1.2 h ascites fluid 2.1 h ascites fluid 3.8 h plasma ---- 4 h (ascites) 1-6 h (plasma) ---- ---- >1mM After separation of nucleotides by HPLC, metabolites were quantified by UV or radioactivity.
2F-ara-HX 3.0 h plasma 4 h (plasma) . 0.4 mM
2F-ara-HX ---- 4 h (ascites) ----
Mouse (BD2F 1 ) P388 Tumor cell Model 1,485 mg/kg 2F-ara-AMP I.P. ---- 2F-ara-ATP 2F-ATP ---- 4.1 h (intracellular, P388 cells) 3.7 h (intracellular, P388 cells) ---- 6 h (intracellular, P388 cells) 6 h (intracellular, P388 cells) ---- 1,036 F M 27 F M After separation of nucleotides by HPLC, metabolites were quantified by UV or radioactivity.
Swine Miniature (5 animals) 14-16.5 kg 10, 16, 25 mg/m 2 2F-ara-AMP I.P. 2F-ara-A ---- 5-140 min (peritoneal fluid) 120-240 min (plasma) 7.7-18 F g/mL (peritoneal fluid) 0.15-0.46 F g/mL (plasma) HPLC was used.

Cmax: maximal concentration I.P. : intraperitoneal

TABLE 3

METABOLISM, DISTRIBUTION AND EXCRETION OF FLUDARABINE PHOSPHATE

Species Design Compound Admin- istered Dose (mg/m 2 ) Metabolism and Distribution Elimination Metabolites
Mouse (BDF 1 ) I.V. Administration 2F-ara- AMP 40 500 The major metabolite was 2F-ara-A in mice. The liver, spleen and kidney were the major organs containing the metabolites. Elimination occurred exponentially from tissue, although the rate of elimination from serum was faster. All metabolites were excreted in the urine. 2F-ara-A 2F-ara-AMP 2F-ara-HX 2F-A Polyphosphorylated derivatives
Mouse I.V. Administration 2F-ara- AMP 40 500 2F-ara-AMP undergoes dephosphorylation to 2F-ara-A in mice. Elimination of 2F-ara-A from tissue occurs exponentially. Serum: 2F-ara-A 2F-ara-HX Tissue: 2F-ara-A 2F-ara-HX 2F-A 2F-ara- AMP 2F-ara-ADP 2F-ara-ATP
Mouse (BD2F 1 ) P388 tumor cell implant model I.P. Administration 2F-ara- AMP 1,485 (mg/kg) Peak 2F-ara-A ascites conc. occurred at 4 hr. Peak 2F-ara-HX ascites conc. occurred at 4 hr. Peak 2F-ara-A plasma conc. ( $ 1 mM) occurred at 1-6 hr. Peak 2F-ara-HX plasma conc. ( . 0.4mM) occurred at 4 hr. 2F-ara-A t 1/2 = 2.1 hr. (ascites) ---- 2F-ara-A t 1/2 = 3.8 hr. (plasma) 2F-ara-HX t 1/2 = 3 hr (plasma) 2F-ara-A (ascites & plasma) 2F-ara-HX (ascites & plasma) 2F-ara-ATP (intracellular) 2F-ara- AMP (intracellular)

TABLE 3 (Continued)

METABOLISM, DISTRIBUTION AND EXCRETION OF FLUDARABINE PHOSPHATE

Species Design Compound Admin- istered Dose (mg/m 2 ) Metabolism and Distribution Elimination Metabolites
Mouse I.P. 2F-ara-AMP 1,485 The peak concentration (1,036 uM) of the primary 2F-ara-ATP t 1/2 = 4.1 h (in P388 ----
(BD2F 1 ) Administration (mg/kg) intracellular metabolite, 2F-ara-ATP, was reached 6 h post cells)
drug administration in P388 cells. 2F-ara-ATP t 1/2 = 2 h (in host ----
P388 tumor cell implant model Peak levels of 2F-ara-ATP were reached at 4-6 h in bone marrow and intestinal mucosa with 2F-ara-ATP accumulated 20-fold less than in P388 cells. 2F-ara-ATP has been determined the active metabolite. tissue)
Mouse P388 tumor cell implant model I.P. Administration 2F-ara-AMP 1,485 (mg/kg) 930 uM 2F-ara-ATP was the peak intracellular concentration observed in P388 cells. Peak 2F-ara-ATP concentrations of 34 nmol/umol DNA accumulated in bone marrow. Peak 2F-ara-ATP concentrations of 23 nmol/umol DNA accumulated in the intestinal mucosa. The metabolite 2F-ara-A passed rapidly from ascites to blood in concentrations proportional to dose. DNA synthesis was inhibited to 1% of controls at 6 h. 2F-ara-ATP disappeared from P388 cells with an intracellular half-life of 4.1 hr. 2F-ara-ATP disappeared from bone marrow and intestinal mucosa with a half-life of 1.5 hr. 2F-ara-A exhibited a plasma half- life of 3.5 hr. 2F-ara-A 2F-ara-ATP

TABLE 3 (Continued)

METABOLISM, DISTRIBUTION AND EXCRETION OF FLUDARABINE PHOSPHATE

Species Design Compound Admin- istered Dose (mg/m 2 ) Metabolism and Distribution Elimination Metabolites
Dog (Beagle) I.V. Administration 2F-ara-AMP 40 500 The dog metabolizes a greater % of the compound to 2F-ara-HX than does the mouse. 2F-ara-A, 2F-ara-HX, and 2F-A are all excreted in urine. 2F-ara-A 2F-ara-HX 2F-A
Dog (Beagle) I.V. Administration 2F-ara-AMP 40 500 2F-ara-AMP undergoes dephosphorylation to 2F-ara-A in dogs. ---- 2F-ara-A
Dog (Beagle) I.V. Administration 2F-ara-AMP 260 Tissue binding of 2F-ara-A relative to plasma protein binding is substantially greater in the dog when compared to humans. 2F-ara-AMP is metabolized by dephosphorylation to 2F-ara-A with subsequent deamination to 2F-ara-HX 2F-ara-A 2F-ara-HX
Miniature Swine I.P. Infusion 2F-ara-AMP 10 16 25 Peak I.P. levels of 2F-ara-A occurred at 5-140 minutes. Peak serum levels of 2F-ara-A occurred 120-240 minutes. ---- 2F-ara-A
Monkey I.V. Administration 2F-ara-AMP 20 Peak 2F-ara-A plasma levels occurred at 7-14 minutes. Peak 2F-ara-A CSF levels occurred at 31-127 minutes. 2F-ara-A crosses the blood-brain barrier accumulating in CSF with a lag time of 0.5-2 hr. ---- 2F-ara-A
Mouse (BDF 1 ) I.V. Administration 2F-ara-A 30 42% of radioactivity found in liver, 20% in spleen, pancreas, and colon, and 15% in lung and small intestines was a phosphorylated derivative of 2F-ara-A. $ 59% of drug is excreted in urine as 2F-ara-A at 24 hr. 12% of dose was excreted as metabolite at 24 hr. 2F-ara- AMP 2F-ara-ADP 2F-ara- ATP

TABLE 3 (Continued)

METABOLISM, DISTRIBUTION AND EXCRETION OF FLUDARABINE PHOSPHATE

Species Design Compound Admin- istered Dose (mg/m 2 ) Metabolism and Distribution Elimination Metabolites
Mouse P388 tumor cell implant model I.P. Administration 2F-ara- A 234 (mg/kg) 560 uM 2F-ara-ATP was the peak intracellular concentration observed. 2F-ara-A passed rapidly from ascites to blood in concentrations proportional to dose. 2F-ara-ATP disappeared with an intracellular half-life of 2.9 hr. 2F-ara-A exhibited a plasma half- life of 2.2 hr. 2F-ara-ATP
Dog (Beagle) I.V. Administration 2F-ara- A 30 Dogs consistently metabolize greater portions of 2F-ara-A with higher levels detected in serum and urine when compared to mice. 27% of drug excreted unchanged in urine at 24 hr. 53% of drug excreted as metabolites in urine at 24 hr. ----
Dog (Beagle) I.V. Administration 2F-ara- A 400 Dogs consistently metabolize greater portions of 2F-ara-A with higher levels detected in serum and urine when compared to mice. 18% of drug excreted unchanged in urine at 24 hr. 70% of drug excreted as metabolites in urine at 24 hr. ----
Monkey (Rhesus) I.V. Administration 2F-ara- A 30 ---- 50% of drug excreted unchanged in urine at 24 hr. 26% of drug excreted as metabolites in urine at 24 hr. ----
Monkey (Rhesus) I.V. Administration 2F-ara- A 400 ---- 58% of drug excreted unchanged at 24 hr. 25% of drug excreted as metabolites at 24 hr. ----

Pharmacokinetics (Humans)

The pharmacokinetics of fludarabine phosphate given intravenously have been determined in adult patients undergoing Phase I clinical trials at the University of Texas Health Science Center at San Antonio (UT), the University of Texas System Cancer Center at the M.D. Anderson Cancer Center (MDACC) and at Ohio State University (OSU). In addition, the pharmacokinetics of intraperitoneal fludarabine phosphate was also determined at UT and the pharmacokinetics of intravenous fludarabine phosphate in pediatric patients with leukemias and solid tumors were determined at the Children's Hospital of Los Angeles, the National Cancer Institute (NCI) and the Mayo Clinic. Preliminary nonclinical and Phase I human studies demonstrated that fludarabine phosphate is rapidly converted to 2F-ara-A within minutes after intravenous infusion, and then phosphorylated intracellularly by deoxycytidine kinase to the active triphosphate, 2F-ara-ATP. Consequently, clinical pharmacology studies have focused on 2F-ara-A pharmacokinetics. Described on the following pages are three principal pharmacokinetic studies that characterize the pharmacokinetic parameters of 2F-ara-A. Despite the differences in dosage and dosing schedules between these various studies discussed on the following pages, several consistent results were obtained. For the infusion studies, a mean terminal half-life of 9.2 hours was found in the population of patients studied at UT, and a median terminal half-life of approximately 8 hours was observed in the patients studied at MDACC. These values compare favorably to the 10.16-hour mean terminal half-life reported by the OSU investigators following large intravenous bolus injections. The terminal half-life of 2F-ara-A does not appear to be dose- dependent, as the doses used in these studies ranged from 18 to 260 mg/m2. The discrepancies between the studies regarding the biphasic or triphasic elimination patterns appear to be due to differences in sampling schedules and duration of intravenous administration. In addition, sampling duration has an impact upon the calculated value of the terminal half-life (t1/2g). The majority of pharmacokinetic studies use a blood sampling duration of 24 to 30 hours, which gives a calculated terminal half-life (t1/2g) of 8 - 10 hours. However, when the sampling duration is increased to 72 hours, the additional time points give a calculated t1/2g of up to 31 hours. Because the plasma concentration of 2F-ara-A declines more than 50-fold from the peak concentration before this long elimination phase, the consequences of the relatively low 2F-ara- A concentration remaining in the plasma after 24 hours (<0.1 pmol) remain uncertain, as far as drug scheduling is concerned. In addition, both the UT and OSU investigators found a positive correlation between area under concentration-time curves and degree of neutropenia reinforcing the assertion that toxicity (myelosuppression) is dose related.

Phase I-II Study of Fludarabine in Hematologic Malignancies (Study No. T83-1275) conducted at University of Texas, San Antonio

Methods

The pharmacokinetic parameters of the principal metabolite of fludarabine phosphate, 2F-ara-A, were determined in seven adult patients (6 male; 1 female) who received fludarabine phosphate at doses of 18 or 25 mg/m2/day as a thirty-minute intravenous infusion daily for five consecutive days. Blood and urine samples were analyzed by HPLC for concentrations of 2F-ara-A. The plasma concentration-time data, which were determined by HPLC, were analyzed by non- linear least squares regression analysis (NONLIN) using a zero order infusion input with first order elimination from the central compartment. Both a two and a three compartment model were tested and the data fitted to the two compartment open model.

Pharmacokinetic Parameters

Peak plasma concentrations of 2F-ara-A ranged from 0.199 to 0.876 ug/mL and appeared to be related to the dose and rate of infusion. Mean plasma concentrations of 2 fluoro-ara-A on days 1 and 5 in patients receiving 18 mg/m2/day were 0.39 and 0.51 ug/mL, respectively. Mean plasma concentrations of 2F-ara-A on days 1 and 5 in patients receiving 25 mg/m2/day were 0.57 and 0.54 ug/mL, respectively. There was no drug accumulation during the five-day treatment period. The pharmacokinetic parameters derived from this study are presented in Table 4.

Table 4

F-ARA-A KINETIC PARAMETERS

Patient BSA (m 2 ) Dose Duration of Infusion (min) Peak conc. ( F g/mL) Clearance rates (L/h/m 2 ) Volumes of distribution (L/m 2 ) t 1/2 (h)
mg/m 2 mg Day 1 Day 5 Day 1 Day 5 Plasma Tissue Vd ss Vd a b
1 1.57 18 27 32 30 0.285 0.285 13.43 28.3 115.4 48.6 0.59 7.0
2 a 1.74 18 31 25 30 0.199 0.377 1.51 28.1 1629.9 75.3 1.69 787.5
3 1.62 18 29 38 30 0.693 0.856 4.35 19.8 59.8 16.1 0.37 10.7
4 1.90 25 48 30 30 0.876 0.611 b 10.38 23.8 91.9 22.9 0.39 7.8
5 1.94 25 48 35 30 0.509 0.550 8.30 5.1 86.4 46.8 1.99 10.6
6 1.74 25 43 33 30 0.550 - C 5.28 9.9 88.6 37.0 1.26 13.9
7 2.06 25 51 30 30 0.336 0.458 b 12.71 33.8 135.2 55.2 0.59 8.44
Mean 9.1 20.1 96.2 37.8 0.60 d 9.24 d
SD 3.8 10.9 26.0 15.4 -

a

Patient omitted from calculation of mean and SD

bDay 5 levels drawn on day 4 cDay 5 levels not studied dHarmonic mean half-life The mean central compartment volume of distribution (Vd) was 37.8 L/m2 with a mean steady- state volume of distribution (Vdss) of 96.2 L/m2. The mean tissue clearance was 20.1 L/h/m2 and the mean plasma clearance was 9.1 L/h/m2. Plasma concentrations declined bi-exponentially with a harmonic mean initial half-life (t1/2a) of 0.6 hours and a harmonic mean terminal half-life (t1/2b) of 9.2 hours. As presented in Table 5, approximately 24% of the parent compound, fludarabine phosphate, was excreted in the urine as 2F-ara-A during the five-day treatment period.

Table 5

URINARY EXCRETION OF 2F-ARA-A

Patient Day 1 Day 2 % Dose in Urine Day 3 Day 4 Day 5 5-Day Average Creatinine Clearance (mL/min.)
1 14 25 31 7 53 26 76
2 72 16 19 14 9 25 73
3 28 29 29 24 7 24 37
4 25 12 20 38 - 24 77
5 20 20 14 20 13 17 59
6 14 23 27 18 357 23 50
7 17 25 35 45 8 26 73
Mean 27 21 25 24 21 24 63
S.D. 21 6 7 13 19 3 15

Correlation of Pharmacokinetic Parameters with Clinical Parameters

As presented in Table 6, a correlation was observed between decreasing absolute granulocyte count and the area under the concentration-time curve (AUC). The Spearman rank correlation coefficient between absolute granulocyte count and AUC was -0.94 which was statistically significant (p<0.02). The Spearman rank correlation coefficient was also calculated between absolute granulocyte count and total plasma clearance (TPC). Here the correlation coefficient was 0.94 which was also statistically significant (p<0.02). The correlation coefficient between creatinine clearance and TPC was 0.828 (0.05

Table 6

COMPARISON OF AUC WITH ABSOLUTE GRANULOCYTE NADIR AND CREATININE CLEARANCE

Patient Dose (mg/m 2 per day X 5) AUC a (mg * h/L) AGC b Creatinine Clearance (mL/min)
1 18 6.4 3,999 76
7 25 9.73 1,916 73
4 25 12.2 624 77
5 25 14.9 608 59
6 25 23.4 299 50
3 18 20.5 176 37

a

Days 0 - 5

b

Absolute granulocyte count

Summary and Conclusions

Intravenous doses of 18 and 25 mg/m2/day for 5 days exhibited bi-exponential decay with a mean initial half-life (t1/2a) of 0.6 hours and a mean terminal half-life (t1/2b) of 9.2 hours. The mean plasma clearance was 9.1 L/h/m2 and the mean tissue clearance was 20.1 L/h/m2. The mean Vdss was 96.2 L/m2, which is approximately twice body weight, suggesting that tissue binding of the drug occurs. In addition, there was a significant inverse correlation between AUC and absolute granulocyte count (r=-0.94, p<0.02) suggesting that myelosuppression is dose related.

Phase I-II Study of Fludarabine in Hematologic Malignancies (Study No. T83-1275) conducted at the M.D. Anderson Cancer Center

Methods

The pharmacokinetic parameters of the fludarabine phosphate metabolite, 2F-ara-A, were determined in 19 adult patients (12 male; 7 female) who received the drug as a 30-minute intravenous infusion daily for five consecutive days. Ten of the patients were diagnosed as having lymphoma and nine as having leukemia. In this study, five patients received doses of 20 mg/m2/day, five patients received doses of 25 mg/m2/day, one patient received 30 mg/m2/day, four patients received 50 mg/m2/day, two patients received 100 mg/m2/day, and an additional two patients received 125 mg/m2/day. Pharmacokinetic profiles were generally determined after the first dose of fludarabine phosphate. Plasma concentrations of 2F-ara-A and intracellular concentrations of 2F-ara-ATP were determined by HPLC. Intracellular concentrations were determined for mononuclear cells obtained from blood and bone marrow samples. The incorporation of 2F-ara-ATP into nucleic acids was determined using HPLC and liquid scintillation counting methods.

Pharmacokinetic Parameters

Plasma concentrations of fludarabine phosphate were undetectable at the times when the first samples were obtained. Of the patients receiving 20 or 25 mg/m2/day, only two had detectable peak 2F-ara-A concentrations (1.4 and 2.2 uM) and, in this group of patients, 2F-ara-A levels were completely undetectable three hours after the completion of infusion of fludarabine phosphate. At fludarabine phosphate dose levels of 50-125 mg/m2/day, the disappearance of 2F-ara-A was biphasic and independent of dose with a median initial half-life (t1/2a) of 1.41 hours and a median terminal half life (t1/2b) of approximately 8 hours. Plasma pharmacokinetic parameters for patients with relapsed leukemia (N=8, Patients #5-12) are presented in Table 7.

Table 7

PHARMACOLOGICAL CHARACTERISTICS FOR 2F-ARA-A IN THE PLASMA OF PATIENTS WITH RELAPSED LEUKEMIA

1/2a 1/2b

Patient Fludarabine phosphate dose (mg/m 2 ) 2F-ara-A Parameters
t a t b AUC c (uM *h)
5 50 3.30 d 23.90 14
6 50 0.49 >24.00 28
7 50 1.42 7.77 10
8 50 1.25 7.76 16
Median 50 1.34 7.76 e 15
9 100 1.40 8.90 15
10 100 1.87 6.88 37
11 125 0.93 d 13.00 94
12 125 2.20 6.22 37
Median 112.5 1.64 7.89 37

a

Initial rate of elimination

b

Terminal rate of elimination

c

Area under the concentration-time curve calculated to 24 h

d

As the 2-h sample was the earliest obtained, this value is based on extrapolation of the line to 30 minutes

e1/2b

The median value excluding patients 5 and 6 whose elevated creatinine levels may signal impaired renal function and thus a longer t

A wide range of variation of pharmacokinetic parameters of 2F-ara-ATP in circulating leukemic cells was observed; however, when the median peak 2F-ara-ATP concentrations of 24 hour AUC values were compared at each dosage increment (20 or 25 mg/m2, 50 mg/m2, and 100 or 125 mg/m2), a clear dose-dependence emerged (Table 8). Cellular elimination was not dose- dependent, with a half-life of approximately 15 hours at all dose levels. There was a strong correlation between the 2F-ara-ATP levels in leukemic cells obtained from peripheral blood and those found in bone marrow (r=0.84, p=0.01) suggesting that there were no pharmacological barriers in the bone marrow. Those patients with bone marrow involvement had the highest 2F- ara-ATP levels. In addition, intracellular 2F-ara-ATP levels in circulating leukemic cells at 12-14 hours after fludarabine phosphate infusion were inversely related to the DNA synthetic capacity of the cells relative to pretreatment. DNA synthesis remained maximally inhibited (>80%) until cellular concentrations of 2F-ara-ATP fell below 90 uM.

Table 8

PHARMACOLOGICAL CHARACTERISTICS OF 2F-ARA-ATP IN CIRCULATING LEUKEMIC CELLS

Patient Diagnosis Fludarabine phosphate dose (mg/m 2 ) 2F-ara-ATP Parameters Peak (uM) t1/2 a (h) AUC b (uM *h)
1 CLL c 20 42 13.3 600
2 DWDL d 20 51 16.8 840
3 DLCL c 25 15 13.7 220
4 NMCL f 25 24 >24.0 480
Median 22.5 33 15.3 540
5 AMML g 50 58 10.7 780
6 AML h 50 47 >24.0 700
7 AML 50 147 14.1 2,060
8 ALL i 50 105 12.8 1,340
Median 50 82 13.5 1,060
9 AML 100 112 >24.0 2,560
10 CML-BC j 100 1 6.0 10
11 ALL 125 747 5.2 3,470
12 ALL 125 226 >24.0 6,050
Median 112.5 169 15.0 3,015

a

Elimination half-life

b

Area under the concentration-time curves calculated to 24 h

cChronic lymphocytic leukemia dDiffuse, well-differentiated lymphoma eDiffuse, large cell lymphoma

fNodular mixed cell lymphoma gAcute myelomonocytic leukemia hAcute myeloblastic leukemia iAcute lymphoblastic leukemia

j

Chronic myelogenous leukemia in blast crisis

Summary and Conclusions

Intravenous doses of 20-125 mg/m2/day exhibited bi-exponential decay in plasma with a median initial half-life (t1/2a) of 1.41 hours and a median terminal half-life (t1/2b) of approximately 8 hours for 2F-ara-A. The median intracellular half-life for 2F-ara-ATP was approximately 15 hours. The terminal half-lives of both 2F-ara-A and 2F-ara-ATP were not dependent on the dose of fludarabine phosphate. In addition, there was a high correlation between 2F-ara-ATP levels in circulating leukemic cells and bone marrow cells aspirated at the same time. DNA synthetic capacity of leukemic cells was inversely related to intracellular 2F-ara-ATP levels. Finally, 2F- ara-ATP levels were approximately three times higher in bone marrow cells from patients with bone marrow involvement than from those patients without evidence of bone marrow disease, suggesting that tumor cells may have a greater capacity to accumulate and retain nucleoside analogue triphosphates than do normal cells.

Phase I - Pharmacokinetic Study of Fludarabine (NSC-312887) (Study No. W83-328) conducted at Ohio State University

Methods

Twenty-six patients participated in this study, in which fludarabine phosphate was administered as a rapid intravenous (I.V.) infusion of 2-5 minutes duration. Seven patients received fludarabine phosphate at a dose of 260 mg/m2, one patient received a dose of 160 mg/m2, eight patients received a dose of 120 mg/m2, four patients received 100 mg/m2, and an additional six patients received 80 mg/m2. Plasma concentrations of fludarabine phosphate could not be detected five minutes after the discontinuation of the infusion. Plasma concentrations of 2F-ara- A, the principal metabolite of fludarabine phosphate, were determined by HPLC over a time period of 0-30 hours post dosing. The plasma concentration-time data were analyzed by the NONLIN computer program and fitted to a three-compartment open model with first-order elimination from the central (blood) compartment, using the equations for rapid intravenous infusion.

Pharmacokinetic Parameters

Harmonic mean half-lives, mean residence time and total body clearance of 2F-ara-A for each of the dose levels are shown in Table 9. This metabolite exhibited a very short initial half-life (mean t1/2a) of 5.42 minutes, followed by an intermediate half-life (mean t1/2b) of 1.38 hours and terminal half-life (mean t1/2g) of 10.16 hours. In the 26 patients, the terminal half-lives ranged from 4.92 to 19.7 hours. The harmonic mean residence time (Vdss/C1T) was 10.4 hours, and total body clearance (C1T) ranged from 26.5 to 120.4 mL/min/m2 with a mean of 68.98 mL/min/m2.

Table 9

F-ARA-A HARMONIC MEAN HALF-LIVES, MEAN RESIDENCE TIME, AND TOTAL BODY CLEARANCE IN PATIENTS

Dose mg/m 2 No. of Patients t 1/2a (min) t 1/2b (hour) t 1/2g (hour) MRT (hour) C1 T (mL/min/m 2 )
260 7 6.85 1.67 9.86 9.26 72.34
160 1 4.87 1.52 9.03 8.76 66.50
120 8 4.12 1.20 11.77 12.55 58.33
100 4 5.77 1.15 8.26 9.30 85.11
80 6 6.41 1.55 10.44 10.49 68.93
Mean of all patients 26 5.42 1.38 10.16 10.36 68.98
C.V. (%) - - - - - 33.7

C.V.: coefficient of variation

Table 10

F-ARA-A MEAN VOLUME PHARMACOKINETIC PARAMETERS

Dose mg/m 2 No. of Patients V 1 (L/m 2 ) V 2 (L/m 2 ) V 3 (L/m 2 ) Vd ss (L/m 2 ) Vd g (L/m 2 )
260 7 7.97 12.83 20.87 41.68 61.95
160 1 6.63 10.15 18.17 34.96 52.00
120 8 6.28 10.79 26.54 43.61 60.45
100 4 7.73 14.14 27.69 49.55 64.99
80 6 7.73 11.98 26.27 45.97 65.11
Mean of all patients 26 7.30 12.11 24.81 44.22 62.30
C.V. (%) 31.9 25.1 40.7 25.7 28.0

The mean volume parameters for each dosage level are shown in Table 10. The central compartment volume of distribution was approximately 20% of body weight (V1 = 7.30 L/m2). The steady-state volume of distribution indicated significant binding of the drug to tissue components (Vdss=44.22 L/m2). The smallest of the microscopic rate constants was k31, indicating release of drug from the deep tissue compartment to be the rate-determining step in the elimination of 2F-ara-A from the body. Table 11 lists the microscopic rate constants for the first nine patients studied.

Table 11

F-ARA-A MICROSCOPIC RATE CONSTANTS (N= 9)

Patient Dose mg/m 2 k 12 (min -1 ) k 21 (min -1 ) k 13 (min -1 ) k 31 (min -1 ) k 10 (min -1 )
W.Y. 260 0.0402 0.0341 0.00650 0.00333 0.00786
R.E. 260 0.0940 0.0418 0.00375 0.00176 0.01644
H.W. 260 0.0470 0.0360 0.00588 0.00268 0.00632
E.P. 260 0.0556 0.0379 0.01102 0.00299 0.00733
N.R. 120 0.0421 0.0314 0.00708 0.00204 0.00828
M.M 80 0.0786 0.0301 0.00909 0.00327 0.01580
J.B. 80 0.0621 0.0401 0.00917 0.00289 0.01296
R.D. 80 0.0867 0.0414 0.01239 0.00323 0.00692
E.K. 80 0.0107 0.0213 0.00240 0.00160 0.00340
Mean 0.0574 0.0349 0.00748 0.00264 0.00948
C.V. (%) 45.6 18.9 43.7 25.4 47.6

Correlation of Pharmacokinetic Parameters with Clinical Parameters

Upon completion of the pharmacokinetic studies, a multivariate correlation analysis was undertaken of all pharmacokinetic parameters with the following clinical parameters: bilirubin, serum creatinine, creatinine clearance, BUN, SGOT, SGPT, LDH, alkaline phosphatase, hemoglobin, hematocrit, baseline WBC, baseline platelets, WBC nadir, platelet nadir, WBC toxicity grade, platelet toxicity grade, nausea and vomiting grade, age and sex. Pearson correlation coefficients were substantiated by Spearman correlations. Despite the small number of patients, total body clearance correlated well with creatinine clearance and serum creatinine indicating that renal excretion is important for the elimination of the drug from the body. The volume parameters, particularly Vdss and Vdg, correlated with creatinine clearance and serum creatinine (p #0.011). A positive correlation of ClT, with hemoglobin and hematocrit was observed (p#0.035) and may be due to the metabolism of 2F-ara-A in the RBC. In addition, apparent correlations of Vdg with WBC toxicity (p=0.025) and g with hematocrit (p=0.035) were observed. Tables 12 and 13 list the correlation coefficients and p values for the above correlations.

Table 12

CORRELATION OF 2F-ARA-A PHARMACOKINETIC PARAMETERS WITH CREATININE CLEARANCE AND SERUM CREATININE

Pharmacokinetic Parameter Correlation Coefficient (r) a P Value N
Creatinine C1 T 0.71 0.002 16
Clearance V 3 0.62 0.011 16
Vd ss 0.72 0.002 16
Vd g 0.77 <0.001 16
Serum C1 T -0.48 0.013 26
Creatinine V 1 -0.44 0.025 26
Vd ss -0.49 0.011 26
Vd g -0.67 <0.001 26

a

Pearson correlation coefficients which were substantiated by Spearman correlations.

Table 13

CORRELATION OF 2F-ARA-A PHARMACOKINETIC PARAMETERS WITH OTHER CLINICAL PARAMETERS

Pharmacokinetic Parameter Clinical Parameter Correlation Coefficient (r) a P value N
C1 T BUN -0.48 0.012 26
C1 T Hgb 0.42 0.035 26
C1 T Hct 0.46 0.017 26
Vd g BUN -0.39 0.050 26
Vd g WBC tox -0.46 0.025 24
g Hct 0.41 0.035 26

a

Pearson correlation coefficients which were substantiated by Spearman correlations.

A rank ordering of the areas under the plasma concentration-time curve (AUC) for the first nine patients enrolled in the study showed good agreement with the corresponding severity of neutropenia developed by each patient (Table 14). Thus, the capacity of the compound to depress hematopoiesis appears to be dos-related.

Table 14

AREAS UNDER THE PLASMA CONCENTRATION-TIME CURVE AND NEUTROPENIA GRADE

Patient Dose (mg/m 2 ) AUC ( u M min x 10 - 3 ) Neutropenia Grade
H.W. 260 13.29 3
E.P. 260 13.19 3
R.E. 260 8.16 2
W.Y. 260 7.41 3
N.R. 120 5.58 0
R.D. 80 5.08 0
E.K. 80 4.57 1
M.M. 80 2.65 2
J.B. 80 2.54 0

TOXICOLOGY

Toxicology information from acute toxicity (Table 15 and Table 16), long term toxicity (Table 17), mutagenicity (Table 18), and reproductive studies (Table 19) is presented in the following pages.

Table 15

ACUTE TOXICITY STUDIES - MOUSE

Study Type/ Route of Administration Animal Information No. of Animals Dosage mg/kg/day Results
Single Dose Lethality Intravenous Injection Study# SIB 6101.2 Mouse (CD2F 1 ) Age: 6-8 weeks Wt. : 18.3-23.6 g 180 (90 Males, 90 Females) 0 800 967 1,170 1,414 1,710 2,068 2,500 No treatment Dose-related decrease in motor activity (reversible in survivors), tonic spasms and death. Lethal dose estimates (mg/kg) were: L D 10 L D 50 L D 90 M 979.2 1,404.2 2,013.6 F 780.2 1,235.6 1,956.9 M & F 874.4 1,321.1 1,995.9
Five Daily Dose Lethality Intravenous Injection Study# SIB 6101.3 Mouse (CD2F 1 ) Age: 6-8 weeks Wt. : 17.1-23.8 g 270 (135 Males, 135 Females) 0 325 412 523 664 843 1,070 1,358 No treatment Dose-related decrease in motor activity (reversible in survivors) and death. Lethal dose estimates (mg/kg/day) were LD 10 LD 50 LD 90 M 404.6 593.3 870.0 F 355.4 496.8 694.5 M & F 372.5 542.7 790.7

Table 15 (Continued)

ACUTE TOXICITY STUDIES - MOUSE

Study Type/ Route of Administration Animal Information No. of Animals Dosage mg/kg/day Results
Single Dose Toxicity Intravenous Injection Study # SIB 6101.7 Mouse (CD2F 1 ) Age: 6-8 weeks Wt. : 18.6-23.2 g 100 (50 Males, 50 Females) Males: 0 490 a 979 b 1404 c No treatment Females: 0 390 a 780 b 1236 c No treatment Dose-dependent effects on nervous, hematopoietic, GI, renal, and male reproductive systems. LD 50 : lethal to males and females, with females more acutely affected than males. LD 10 : mildly toxic to renal and hematopoietic systems, with decreased mean relative testicular weights. 1/2LD 10 : decrease in motor activity in a few mice, decreased mean relative testicular weights.
Five Daily Dose Toxicity Intravenous Injection Study # SIB 6101.4 Mouse (CD2F 1 ) Age: 6-8 weeks Wt. : 17.3-22.2 g 100 (50 Males, 50 Females) Males: 0 203 a 405 b 593 c No treatment Females: 0 178 a 355 b 497 c No treatment Dose-dependent effects on hematopoietic, GI, renal, and male reproductive systems. LD 50 : lethal to male and female mice. LD 10 : delayed toxicity to the testes (decreased mean relative testicular weight). 1/2LD 10 : can be considered safe in the mouse.

a=1/2LD10 b=LD10 c=LD50

Table 16

ACUTE TOXICITY STUDIES - RAT AND DOG

Study Type/ Route of Administration Animal Information No. of Animals Dosage mg/kg/day Results
Single Dose Rat 24 800 Dose-dependent signs of toxicity were hypoactivity, rough fur,
Toxicity (Sprague Dawley) (15 Males, 1,400 squinted eyes, hypothermia, gross findings in lymph nodes, thymus,
Age: 8-11 weeks 9 Females) 2,000 heart, lungs, and stomach and death. Estimated LD 50 values were 910
Intravenous Injection Wt. : 200-269 g mg/kg (males) and 1,050 mg/kg (females).
Study # TBT03-008
Single Dose Dog 20 13.1 a Dose-dependent signs of toxicity included changes in clinical status
Toxicity (Beagle) (I0 Males, 131.2 b and adverse effects on the hematopoietic, gastrointestinal, renal and
Intravenous Injection Age: 8-10 months Wt. : 7.0-11.6 kg 10 Females) 262.4 c 393.6 d hepatic systems. In addition, male dogs receiving 4 x MELD 10 had pancreatic and reproductive toxicity, and were sacrificed moribund.
524.8 e The 1/10 MELD 10 and MELD l0 doses were considered safe, as effects
Study # SIB 6101.5 seen were minimal and readily reversible.
Five Daily Dose Dog 24 0 Dose-dependent signs of toxicity included alterations in clinical status
Toxicity (Beagle) (12 Males, 5.59 a and adverse effects on the hematopoietic, renal, gastrointestinal, and
Age: 8-9 months 12 Females) 55.85 b hepatic systems resulting in moribund sacrifice or death by day 8 for
Intravenous Injection Study # SIB 6106.6 and Wt. : 6.5-11.7 kg 111.76 c 167.7 d 223.52 e all 4 x MELD 10 animals, as well as one female at the 3 x MELD 10 dose level. The 1/10 MELD 1 0 and MELD 10 dose levels were considered safe, as effects seen were minimal and readily reversible.
6101.6c

MELD = Mouse Equivalent Lethal Dose

a=1/10 MELD10 b=MELD10

c=2 x MELD10 d=3 x MELD10 e=4 x MELD10

Table 17 SUBCHRONIC STUDIES

INTRAVENOUS 13-WEEK TOXICITY STUDIES IN RATS AND DOGS

Study Type/ Route of Administration Animal Information No. of Animals Dosage mg/kg/day Results
13 Week Subchronic Toxicity Intravenous Study # TBT03-003 Rat (Sprague Dawley) Age: 8-14 weeks Wt. : 215-312 g 160 (80 Males, 80 Females) 0, 1, 10, 50 There were 9 mortalities across all dose groups throughout the 13 weeks. None were attributable to test article. At 50 mg/kg/day, toxicity was expressed as increased physical activity during dosing, increased incidence of piloerection, effects on body weights, food consumption, water consumption, and clinical chemistry parameters, and decreases in red blood cell parameters. Organ weight changes included decreased absolute testes weights (males) and increased (relative to body weight) adrenal, kidney, liver, and spleen weights in both sexes at this dose. There were correlated gross pathologic and histologic abnormalities in most of these organs. Fludarabine phosphate given intravenously to rats for 91 consecutive days at doses of 1 and 10 mg/kg/day was well tolerated.
13 Week Subchronic Toxicity Intravenous Study # TBT03-002 Dog (Beagle) Age: 12-16 months Wt. : 7.1-17.9 kg 16 (8 Males, 8 Females) 0, 1, 10, 50 One male dog in the 50 mg/kg/day group died on day 42. Signs of toxicity noted in the 50 mg/kg/day group included weight loss, decreases in some red and white blood cell parameters, possible decrease in testicular weight, lymphoid depletion of the thymus and chronic inflammation of the stomach. For the male that died during the study, additional findings included hemorrhage in numerous tissues. The only test article-related change in the 10 mg/kg/day group was mild lymphoid depletion of the thymus in one male, although testicular weights may have been slightly decreased. The "no toxic effect" dose level was 10 mg/kg/day in female dogs and 1 mg/kg/day in male dogs.

Table 18 MUTAGENICITY STUDIES

Study Type System Used Concentration Range Results
Ames Mutagenesis Assay Study # TBT03-009 Salmonella typhimurium Strains TA 98 TA 100 TA 1,535 TA 1,537 Activated and Non-activated Assays: 0.0015; 0.005; 0.015; 0.05; 0.15; 0.5 mg/plate Non-activated Assay Fludarabine phosphate, at concentrations of 0.0015-0.15 mg/plate, did not increase the mean number of revertants per plate over the negative control value for each of the four strains of bacteria tested. The highest concentration tested, 0.5 mg/plate, was toxic to all strains of bacteria utilized. Activated Assay At concentrations of 0.0015 to 0.15 mg/plate, the mean number of revertants per plate was not increased over the control value for any of the four strains of bacteria tested. At 0.5 mg/plate, fludarabine phosphate was toxic to one strain of bacteria (TA 1537). Fludarabine phosphate was non-mutagenic to S. typhimurium strains tested, under both activated and non-activated conditions.
Sister Chromatid Chinese hamster Non-activated Assay : Non-activated Assay
Exchange Assay ovary cells 10; 15; 30; 50; 100; 150; 300; A significant increase in sister chromatid exchanges (SCEs) was seen in cells
(CHO) 500 ug/mL exposed to fludarabine phosphate at a concentration of 50 ug/mL with higher
Study # TBT03-010 concentrations precluded from analysis due to cellular toxicity. Concentrations of 15
and 30 ug/mL did not cause statistically significant increases in SCEs.
Activated Assay: Activated Assay
50; 125; 250; 500; 1,000; Concentrations of 500 and 1,000 ug/mL caused significant increases in SCEs per
1,500; 2,000; 2,500 ug/mL cell. Concentrations of 125 and 250 ug/mL did not increase SCEs per cell.
Concentrations higher than 1,000 ug/mL were toxic to cells and thus precluded from
analysis.
Fludarabine phosphate has been demonstrated to cause significant increases in SCEs
under both activated and non-activated assay conditions.

Table 18 (Continued) MUTAGENICITY STUDIES

Study Type System Used Concentration Range Results
CHO/HGPRT Chinese hamster Non-activated Assay : Non-activated Assay
Mammalian Cell ovary cells 0.3; 1; 3; 10; 30; 100; 300; At concentrations of 1 to 300 ug/mL, fludarabine phosphate was non-mutagenic as
Mutagenesis Assay (CHO) 500 ug/mL indicated by mean mutation frequencies not significantly different from the negative
(solvent) control values. A concentration of 500 ug/mL produced significant cellular
Study # TBT03-012 toxicity and could not be analyzed.
Activated Assay: Activated Assay
3; 10; 30; 100; 300; 1,000; Mean mutation frequencies were not significantly different from the solvent control
1,500; 2,000; 2,500 ug/mL value at fludarabine phosphate concentrations ranging from 3 to1,000 ug/mL. Higher
concentrations were not selected for analysis due to toxicity to cells.
It was concluded that fludarabine phosphate was non-mutagenic under both non-
activated and activated conditions in the CHO/HGPRT system.
Chromosome Chinese hamster Non-activated Assay: Non-activated Assay
Aberration Assay ovary cells 2.6, 4.5, 9, 13, 26.45, 90, The concentrations of fludarabine phosphate analyzed, 9, 26, and 90 ug/mL, did not
(CHO) 130,260 ug/mL increase the percentage of aberrant cells (both excluding and including gaps).
Study # TBT03-011 Concentrations of 130 and 260 ug/mL were toxic to cells.
Activated Assay: Activated Assay
30, 50, 100, 150, 300, 500, A significant increase in the percentage of cells with chromosomal aberrations (both
1000, 1500, 2000 ug/mL excluding and including gaps) were detected at concentrations of 1,500 and 2,000
ug/mL. No significant increases in aberrant cells were noted at the other two
concentrations analyzed, 150 and 500 ug/mL.
Fludarabine phosphate has been demonstrated to increase chromosome aberrations
under activated conditions but did not increase chromosome aberrations under non-
activated conditions in this assay.

Table 18 (Continued) MUTAGENICITY STUDIES

Study Type System Used Concentration Range Results
Mouse Micronucleus Test Study # PHRR AD76 Mouse, NMRI (SPF) 0; 100; 300; 1,000 mg/kg body weight cyclophosphamide (30 mg/kg) positive control One day after application at the toxic dose level of 1,000 mg/kg, 3/20 mice showed moderate apathy, while on day 2, 2/20 died. In the 1,000 mg/kg dose group, a significant increase in the micronucleated polychromatic erythrocytes (PCE) and normochromatic erythrocyte (NCE) counts was observed at both sampling times. Additionally, in the mid-dose group, a significant increase in micronucleated PCE counts was observed 24 hours after administration. Furthermore, bone marrow depression was observed in all treatment groups at 24 hours post-administration and in the high- and mid-dose groups at 48 hours post- administration. The positive control gave the expected increase in the micronucleated cell counts. A significant decrease in the PCE/NCE ratio was also observed.
Dominant Lethal Test Study# PHRR AV36 Mouse, NMRI, BR (SPF) 0; 100; 300; 800 mg/kg body weight cyclophosphamide (120 mg/kg) positive control Only the highest dose tested (800 mg/kg) was clearly toxic after single administration as demonstrated by a mortality rate of approximately 40%. Fludarabine phosphate showed no potential to induce germ cell mutations in male mice at any germ cell stage over complete spermatogenic maturation. No biologically relevant positive response for any of the parameters evaluated (number of total and those resulting in death per pregnant female, pre-implantation losses and fertility index) were observed at any mating interval at any dose-level. The positive control gave the expected mutagenic response demonstrating the sensitivity of the test system.

Table 19 REPRODUCTIVE STUDIES

INTRAVENOUS DEVELOPMENTAL TOXICITY STUDIES OF FLUDARABINE PHOSPHATE

Study Type/ Route of Administration Animal Information No. of Animals Dosage mg/kg/day Results
Range-Finding Rat 30 Females 0 Mortality was 100% at the 400 mg/kg/day dose level; all other
Developmental Toxicity (Sprague Dawley) 4 animals survived to scheduled sacrifice. Signs of toxicity in the 40,
Age: 12 weeks 10 100, and 400 mg/kg/day groups included lethargy, hypothermia,
Intravenous Injection Wt. : 227-266 g 40 changes in the feces, decreased body weight gain or body weight loss,
(gestation days 6-15) 100 and decreased food consumption. Post-implantation loss was 100%
400 and 30% at the 100 and 40 mg/kg/day dose levels respectively. Ten
Study # TBT03-004 fetuses in two litters in the 40 mg/kg/day group had fetal
malformations, which included omphalocele and various limb and tail
anomalies. The 4 and 10 mg/kg/day dose levels produced no signs of
maternal or developmental toxicity. The No Observable Adverse
Effect Level (NOAEL) was 10 mg/kg/day.
Developmental Toxicity Rat 100 Females 0 No treatment-related deaths occurred during the study, nor were there
(Sprague Dawley) 1 any clinical signs of toxicity. Mean maternal body weight gain was
Intravenous Injection Age: 12 months 10 slightly decreased early in the dosing phase, and mean fetal weight
(gestation days 6-15) Wt. : 208-299 g 30 was low, for the 30 mg/kg/day group. The small number of
malformations seen were considered not test article-related, due to a
Study # TBT03-006 lack of a dose response; however, the 10 and 30 mg/kg/day groups
showed dose-related increases in the incidence of several skeletal
variations (rib and vertebrae anomalies), indicating developmental
toxicity at both dose levels. A dose level of 1 mg/kg/day was
considered the No Observable Adverse Effect Level (NOAEL).

Table 19(Continued)

REPRODUCTIVE STUDIES

INTRAVENOUS DEVELOPMENTAL TOXICITY STUDIES OF FLUDARABINE PHOSPHATE

Study Type/ Route of Administration Animal Information No. of Animals Dosage mg/kg/day Results
Range-Finding Rabbit 30 Females 0 Mortality was 100% for the 50 and 25 mg/kg/day groups. Signs of
Developmental Toxicity (New Zealand White) 1 toxicity in the 10, 25, and 50 mg/kg/day groups included ataxia,
Age: 6 months 5 lethargy, labored respiration, changes in the feces, maternal body
Intravenous Injection Wt. : 3.0-3.9 kg 10 weight losses, and decreased food consumption. The 5 mg/kg/day
(gestation days 6-18) 25 group also had slightly decreased food consumption early in the
50 dosing phase. Post-implantation loss was slightly increased in the 10
Study # TBT03-005 mg/kg/day group. In addition, 30 of 35 fetuses in this group had
external malformations, consisting primarily of craniofacial and/or
limb and digit defects. The No Observable Adverse Effect Level
(NOAEL) was considered to be 1 mg/kg/day.
Developmental Toxicity Rabbit 80 Females 0 Maternal survival was not affected and no clinical signs of toxicity
Intravenous Injection (gestation days 6-18) (New Zealand White) Age: 6 months Wt. : 3.1-4.2 kg 1 5 8 were apparent in any group. The 5 and 8 mg/kg/day groups showed dose-related inhibition of maternal body weight gain and food consumption. Post-implantation loss was increased and mean fetal body weight was low, at the 8 mg/kg/day dose level. External and
Study # TBT03-007 skeletal malformations, generally specific to the head, limbs, digits
and tail, were increased in the 8 mg/kg/day group. In addition,
diaphragmatic hernia (a soft tissue malformation) was noted at a low
frequency but in a dose-related pattern (3, 1 and 1 fetuses in the 8, 5
and 1 mg/kg/day groups, respectively). The incidence of skeletal
variations was also increased in a dose-related manner in the 5 and 8
mg/kg/day groups. A dose level of 1 mg/kg/day was considered the
No Observable Adverse Effect Level (NOAEL) for maternal toxicity
but equivocal for fetal developmental toxicity, because of the
appearance of a single fetus with diaphragmatic hernia at this dose
level.

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