Question Number: 265
PDR Number: SQ22-000636
Date Submitted: 21/11/2022
Department or Body: Department of Health
140 The primary route of metabolism identified for ALC-0159 involves amide bond hydrolysis yielding N,N-ditetradecylamine. This metabolite was only identified in vitro in isolated mouse, rat, monkey and human preparations. The metabolite was not detected in vivo in rats after an IV dose of ALC-0159. The human exposure to ALC-0159 as part of the Pfizer vaccine is 50 ?g, which is below the threshold of toxicological concern (TTC) of 120 ?g/day for substances with a dosing period of less than one month over a lifetime (ICH guideline M7: www.ema.europa.eu/en/documents/scientific-guideline/ich-guidelinem7r1-assessment-control-dna-reactive-mutagenic-impurities-pharmaceuticals-limit_en.pdf). Even if N,N-ditetradecylamine is formed from ALC-0159 in vivo, the amount of the metabolite would be much lower than the amount of ALC-0159 in the vaccine dose. Therefore, neither ALC-0159 nor N,N-ditetradecylamine from COVID-19 vaccination is considered to pose a carcinogenic risk. As per the ICH guidelines, which are used by regulators in all major developed countries, guidelines no further risk assessment was required. 141 N,N-ditetradecylamine was not detected in rats in vivo after an IV dose of ALC-0159. This means there is no accumulation of N,N-ditetradecylamine. See also the response to Question 140.