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Sub Heading Date Hazard Assessment Of Potentially Mutagenic Impurities ICH M7 Indian Roadshows 2020 February 28, 2020 March 02, 2020 Muzaffar Khan, Ph.D [email protected]

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Page 1: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Sub Heading

Date

Hazard Assessment Of

Potentially Mutagenic Impurities

ICH M7 Indian Roadshows 2020

February 28, 2020

March 02, 2020

Muzaffar Khan, Ph.D

[email protected]

Page 2: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Introduction

2

• Hazard assessment of 8 example compounds at Laurus Labs

with varying expert rule-based and statistical-based results

• Derek Nexus and Sarah Nexus results will be presented

• A conclusion will be drawn for each compound based on

expert call

• You will be asked to assess each example and vote

accordingly

• Laurus/Lhasa will then present an expert call*

• Follow-up hazard assessment on the alerting compounds will

be discussed

*All expert calls on the examples are solely the decisions taken at Laurus Labs

and corroborated by Lhasa Limited.

Page 3: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Hazard Assessment - ICH M7

3

Page 4: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

What kind of arguments can be used?

4

• Adequate Ames data available

• Ames test does not assess the hazard caused by the

compound class adequately

• Toxicophore identified by one system has not been

adequately assessed by the other

• Toxicophore identified is not causative of activity

• Nearest neighbours are not adequately similar to support

prediction

• Data available for nearest neighbours is not of sufficient

quality to support prediction

Page 5: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

5

Page 6: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Example-1

6

Page 7: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review high level predictions

7

Page 8: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

8

• No alerts fired

• Contains unclassified features

Page 9: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

9

• The test compound contains an unclassified feature (Imidoyl chloride)

which does not match with any structural alerts or examples for Ames

positive compounds in Derek.

• Predicted to be inactive in Ames mutagenicity test.

• Imidoyl chlorides are electrophilic in nature with a good leaving group

and therefore potentially mutagenic.

• Imidoyl chlorides are analogous of acyl chlorides and highly reactive.

• Imidoyl chlorides react spontaneously with water to yield the amides.

Page 10: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

10

• Outside domain

• Training set does not include any example covering this functionality

Page 11: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Expert review

11

Inactive *

Outside domain

• Inactive prediction but contains unclassified features

• Potential alkylating agent (short lived as hydrolysis is highly likely)

• Out of domain

• Sarah Nexus training set does not contain examples covering

“imidoyl chloride”

Page 12: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Please make your selection

12

1. Class 3 –Alerting structure

2. Class 5 –No alerts or alerting with sufficient data to

demonstrate lack of mutagenicity

3. Unsure

Page 13: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 1

13

• Derek Nexus

• Inactive prediction, contains unclassified features

• Potential alkylating agent; highly reactive

• Sarah Nexus

• Outside domain with no similar examples in the training set

Page 14: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 1

14

Class 3 Alerting structure

Hazard Assessment & Control Strategy:

Impurity introduced too early in synthesis (n-6 step) and unlikely to carryover to

the drug substance. Proposed ICH M7 Option 4 control strategy based on

commercial batch data and spike-purge studies.

Mirabilis is useful to justify Option 4 control strategy

Page 15: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Example-2

15

CAS No. 173676-59-0

Page 16: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review high level predictions

16

Page 17: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

17

• No alerts fired

• A certain aromatic amine and potentially mutagenic

• A more detailed review is necessary

Page 18: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

18

• Positive hypothesis for aromatic amine• The most relevant parent (2-Acetylaniline) is non-mutagenic.

• The 4-chloroaniline containing compounds (2,3,4&5) are not relevant.

• A Vitic search indicates that 4-Chloroaniline has displayed activity in TA98 (albeit

not very consistently). Listed in ICH M7 R1 Addendum too.

Page 19: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Expert Review

19

• Inactive prediction with no misclassified or unclassified features

• Compound contains an aromatic amine

• Expert review of pAA is a subjective process and the in silico

results should be handled with care.

• The stability and physicochemical properties of a subset of

aromatic amines affords them capricious mutagenic properties

in the Ames test.

• Positive hypothesis for aromatic amine

• 2-Acetylaniline is non-mutagenic, no relevant examples in

training set for 4-Chloroaniline

• 4-Chloroaniline has displayed mutagenic activity in TA98.

Inactive

Positive

Page 20: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Please make your selection

20

1. Class 3 – Alerting structure

2. Class 5 – No alerts or alerting with sufficient data to

demonstrate lack of mutagenicity

3. Unsure

Page 21: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 2

21

• Derek Nexus

• Inactive prediction with no misclassified or unclassified features.

• The 2-substituent (electron withdrawing group) deactivates the aromatic

amine, there is no suitable electron donating group at another position

• Disubstituted aniline bearing only halogen and/or trifluoromethyl

substituents on aromatic ring are generally Ames negative

• Sarah Nexus

• Positive prediction for aromatic amine

• The most relevant example is Ames negative.

Page 22: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 2

22

Experimental results confirmed the compound was Ames negative

(Class 5)

Class 5 No alerts or alerting with sufficient data to demonstrate

lack of mutagenicity

Page 23: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Example-3

23

CAS No. 27607-77-8

Page 24: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review high level predictions

24

Page 25: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

25

• No alerts fired

• Compound contains unclassified features

Page 26: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

26

• Outside domain

• Nothing to report

Page 27: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

27

• Triflic acid predicted to be non-mutagenic

• No misclassified or unclassified features

Page 28: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

28

• TMS-OH predicted to be non-mutagenic

• No misclassified or unclassified features

Page 29: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

29

• Negative prediction for triflic acid

Page 30: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

30

• TMS-OH is Ames negative

Page 31: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Expert Review

31

• Inactive prediction

• Compound contains unclassified features

• Outside domain

• Nothing to report

Inactive *

Outside domain

Page 32: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Please make your selection

32

1. Class 3 –Alerting structure

2. Class 5 –No alerts or alerting with sufficient data to

demonstrate lack of mutagenicity

3. Unsure

Page 33: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 3

33

• Derek Nexus

• Inactive prediction but contains unclassified features.

• No alerts fired for the potential hydrolysis products, triflic acid and TMS-OH

• Sarah Nexus

• Out of domain

• The hydrolysis product triflic acid is predicted negative

• TMS-OH is Ames negative

Page 34: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 3

34

Class 5 No alerts or alerting with sufficient data to demonstrate

lack of mutagenicity

Page 35: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Example- 4

35

CAS NO:17933-03-8

Page 36: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review high level predictions

36

Page 37: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

37

• Plausible mutagen

• Alert – 746: Arylboronic acid or derivative

Page 38: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

38

Exact match -Positive Ames Call reported from Vitic Nexus

• 4 most relevant nearest neighbours are all positive

• Negative nearest neighbours are dissimilar.

Page 39: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

Page 40: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Expert Review

40

• Plausible mutagen

• Alert – 746: Arylboronic acid or derivative

• No reason to over-rule Derek prediction

• Predicted positive -100% confidence (exact match)

• 4 most relevant nearest neighbours are all positive

• Ames data is reliable

Positive

Plausible

Page 41: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Please make your selection

41

1. Class 3 –Alerting structure

2. Class 5 –No alerts or alerting with sufficient data to

demonstrate lack of mutagenicity

3. Unsure

Page 42: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 4

42

• Derek Nexus

• Plausible mutagen

• Alert – 746: Arylboronic acid or derivative

• Sarah Nexus

• Predicted positive -100% confidence (exact match)

• 4 most relevant nearest neighbours are all positive

• Negative nearest neighbours are not very relevant

Page 43: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 4

43

Class 2 Mutagenic

Hazard Assessment & Control Strategy

Introduced in n-2 synthetic step; proposed Option-3 control strategy in

the starting material

Page 44: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Example- 5

44

CAS No. 25487-66-5

Page 45: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review high level predictions

45

Page 46: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

46

• Predicted to be inactive

• Arylboronic acid or derivative?

Page 47: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

47

Aryl boronic acids - A mutagenic response is seen both with and

without metabolic activation, most commonly with Salmonella

typhimurium TA100 and TA1537 and Escherichia coli WP2 uvrA

strains. The mechanism by which these compounds exert their

mutagenic effect remains unclear.

Electron donating and sterically hindering groups are thought to

modulate reactivity of the boron centre, which may relate to mutagenic

activity. Strong correlation with 11B NMR shifts.

Following deactivating substituents on phenylboronic acids excluded.

- Carboxylic acid or tetrazole

- 2,6-Disubstitution

- Bulky alkyl para-substitution

- 3,4-Carbocyclic aliphatic fused ring substitution

Page 48: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

48

• Equivocal

• Positive for Aryl boronic acid, however;

• Both the examples in training set are not very relevant as they do not

contain carboxylic acid moiety.

Page 49: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Expert Review

49

Arylboronic acid genotoxicity: Summary of data and knowledge

NMR shifts of arylboronic acids

Dr. Richard Williams, Lhasa Limitedhttps://www.lhasalimited.org/Public/Library/2015/Arylboronic%20acid%20genotoxicity%20-%20summary%20of%20data%20and%20knowledge.pdf

Page 50: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

3-Carboxyphenylboronic acid was non-mutagenic in AMES assay

Stannard, L., Giddings, A., Lad, A., Munoz-Muriedas, J., Harvey, J., and Kenny, J. (2012)

Can lowest unoccupied molecular orbital (LUMO) energies predict the mutagenicity of

boronic acids? Mutagenesis 27, 807−808.

Expert Review

Page 51: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Expert Review

51

• Inactive prediction with no misclassified or unclassified features

• Compounds containing carboxylic acid substitution are

excluded from the alerts list

• Equivocal

• Positive hypothesis for the aryl boronic acid

• Nearest neighbours with positive results are not very relevant

• Training set does not contain phenylboronic acids with

carboxylic acid substitution

Inactive

Equivocal

Page 52: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Please make your selection

52

1. Class 3 –Alerting structure

2. Class 5 –No alerts or alerting with sufficient data to

demonstrate lack of mutagenicity

3. Unsure

Page 53: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 5

53

• Derek Nexus

• Inactive prediction with no misclassified or unclassified features.

• No reason to over-rule Derek Nexus prediction

• Sarah Nexus

• Equivocal

• Positive examples not very relevant

• Compound is Ames negative (data available elsewhere)

Page 54: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 5

54

Class 5 No alerts or alerting with sufficient data to demonstrate

lack of mutagenicity

Page 55: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Example- 6

55

Page 56: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review high level predictions

56

Page 57: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

57

• Predicted to be inactive

• Contains unclassified features

Page 58: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

58

• Positive hypothesis for Thiophene driven by presence of unrelated

toxicophores

Page 59: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Expert Review

59

• Inactive prediction, contains unclassified features

• Thiophene itself is not an alerting structure for mutagenicity

• Thiophene was non-mutagenic in Ames test*. *AESCHBACHER,HU, et.al CONTRIBUTION OF COFFEE AROMA CONSTITUENTS TO THE MUTAGENICITY OF COFFEE; FOOD CHEM. TOXICOL. 27(4):227-232, 1989.*ZEIGER,E, ANDERSON,B et.al. SALMONELLA MUTAGENICITY TESTS: III. RESULTS FROM THE TESTING OF 255 CHEMICALS; ENVIRON. MOL. MUTAGEN. 9(SUPPL.9):1-110, 1987.

• Aryl fused thiophene not necessarily Ames negative.

• Equivocal prediction

• All positive examples were confounded• All the Ames positive compounds in training set containing thiopene

fragment contained other known mutagenic functionalities (e.g.

aromatic nitro compounds).

Derek: Inactive *

Sarah: Equivocal

Page 60: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Please make your selection

60

1. Class 3 –Alerting structure

2. Class 5 –No alerts or alerting with sufficient data to

demonstrate lack of mutagenicity

3. Unsure

Page 61: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 6

61

• Derek Nexus

• Inactive prediction with unclassified features.

• Sarah Nexus

• Equivocal

• Equivocal prediction driven by examples from training set containing

different toxicophores.

Page 62: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 6

62

Class 5 No alerts or alerting with sufficient data to demonstrate

lack of mutagenicity

Page 63: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Example- 7

63

Page 64: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review high level predictions

64

Page 65: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

65

• Positive prediction by Derek (Alert – 028: Mono- or di-alkylhydrazine)

• Hydrazines often produce weak and inconsistent responses in the Ames test

(due to their high toxicity and tendency to oxidise, which confounds testing)

and hence the compound is fired as an Equivocal alert in Derek.

Page 66: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

66

• Predicted overall negative in Sarah Nexus

• Positive hypothesis for hydrazine

Page 67: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Expert Review

67

• Equivocal

• Alert – 028: Mono- or di-alkylhydrazine

• Alert as per ICH M7

• Negative prediction

• Positive hypothesis for alkyl hydrazine

• Compounds in the training set with same alerting functionality are

Ames positive

Equivocal

Negative

Page 68: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 7

68

Imp-1

Imp-2Atazanavir API

Page 69: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Hazard Assessment

69

Structure Derek

Prediction

Sarah

Prediction

QSAR

Prediction

Experimental

Data

Similarity

to API

ICH M7

Class

Comments

Imp-1

Carc: Unspecified Ames: Unspecified

All Alerts found in API

EQUIVOCAL: Alert028 -

Mono- or di-alkylhydrazine

Class 4

Imp-2

Carc: Unspecified Ames: Unspecified

All Alerts found in API EQUIVOCAL: Alert028 -

Mono- or di-alkylhydrazine

Class 4

Page 70: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Please make your selection

70

1. Class 3 –Alerting structure

2. Class 4 –Alerting structure, same alert in drug substance

or compounds related to the drug substance (e.g.,

process intermediates) which have been tested and are

non-mutagenic

3. Class 5 –No alerts or alerting with sufficient data to

demonstrate lack of mutagenicity

Imp-1

Page 71: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 7

71

• Derek Nexus

• Equivocal; Alert- 028: mono- or dialkyl - hydrazine

• Predicted as ICH M7 Class 4 but chemical environment of the alert

is essentially not same as that of the API

• Sarah Nexus

• Negative prediction

• Alkyl hydrazines in training set are Ames positive

Page 72: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 7

72

Class 3 Alerting structure unrelated to the structure of API

Imp-1

Page 73: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 7

73

Hazard Assessment & Control Strategy

Option-1: Control at TTC limit

Option-2: Perform Ames test to classify as Class 2 or 5

Imp-2: Ames positive (in Salmonella

tester strains TA1537 and TA98) !Imp-1 : Ames negative

Imp-2 was non-clastogenic in the follow-up in vivo micronucleus assay in rats.

Page 74: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Example- 8

74

Page 75: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review high level predictions

75

Page 76: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the expert prediction

76

• Predicted to be inactive

• No misclassified or unclassified features

• Potential aromatic amine, aryl N-oxide and acrylonitrile present

Page 77: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Review the statistical prediction

77

• Positive hypothesis for aryl-N-oxide

• >=1 fused aromatic ring or second toxicophore is required for activity

Page 78: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Expert Review

78

• Inactive prediction, no misclassified or unclassified features

• Mutagenicity from the amine between two aromatic rings is unlikely

• Aryl-N-Oxide and Acrylonitrile alerts have not been fired for valid

SAR reasons

• Positive prediction

• Aromatic N-oxide alert

• All positive examples were confounded containing > 1 fused

aromatic rings or other alerts e.g. aromatic nitro or amine

Inactive

Positive

Page 79: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Expert Review – Public data

79

Myatt et al. concluded based on SARs that the general class of aromatic N-Oxide is not an alert for predicting DNA-reactive mutagenicity (except quindioxins)Mutagenesis, Volume 34, Issue 1, January 2019, Pages 67–82, https://doi.org/10.1093/mutage/gey020

Page 80: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Please make your selection

80

1. Class 3 –Alerting structure

2. Class 5 –No alerts or alerting with sufficient data to

demonstrate lack of mutagenicity

3. Unsure

Page 81: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 8

81

• Derek Nexus

• Inactive prediction with no misclassified or unclassified features.

• No reason to over-rule Derek Nexus prediction

• Sarah Nexus

• Positive

• All positive examples are confounded, contain other alerts (e.g.

aromatic nitro or amine and > 1 aromatic rings) and not very

relevant

Page 82: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

M7 Classification – Example 8

82

Class 5 No alerts or alerting with sufficient data to demonstrate

lack of mutagenicity

Page 83: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

Conclusions

83

1. ICH M7 recommends using two complementary in-silico tools;

Expert rule-based (eg. Derek Nexus) and Statistical (eg. Sarah

Nexus).

2. Both expert and statistical tools are necessary!

3. Equivocal / out of domain results should be treated further with

expert opinion to arrive at meaningful conclusion.

4. Dependence only on literature based structural alerts (e.g.

Mueller’s alerts) for the expert review process, without

considering mitigating factors, could result in many more false

positives (Mayden A, Williams RV et al. (2017), Utility of published DNA

reactivity results, https://pubmed.ncbi.nlm.nih.gov/28549899.).

5. The use of Derek Nexus and Sarah Nexus significantly reduces

the number of false positives saving significant resources in the

hazard assessment process.

Page 84: HAZARD ASSESSMENT OF MUTAGENIC IMPURITIES

84

THANK YOU for your kind attention!

ACKNOWLEDGEMENTS

Dr. Richard Williams

LAURUS LABS LTD. and LHASA LIMITED