128(1), 57–71 (2012) doi:10.1093/toxsci/kfs149 Advance Access publication April 26, 2012 toxicological sciences Mode of Action Associated With Development of Hemangiosarcoma in Mice Given Pregabalin and Assessment of Human Relevance Kay A. Criswell,*,1 Jon C. Cook,* Zbigniew Wojcinski,† David Pegg,‡ James Herman,§ David Wesche,¶ John Giddings,|| Joseph T. Brady,* and Timothy Anderson* *Pfizer Worldwide Research & Development, Drug Safety Research & Development, Groton, Connecticut 06340; †Drug Development Preclinical Services, LLC, Ann Arbor, Michigan 48103; ‡Michigan Technology and Research Institute, Ann Arbor, Michigan 48104; §Integrated Nonclinical Development Solutions, Ann Arbor, Michigan 48103; ¶Ann Arbor, Michigan 48105; and ||University of Wales College of Medicine, Heath Park Cardiff, CF14 4XN, United Kingdom 1 To whom correspondence should be addressed at Pfizer Worldwide Research & Development, 2400 Eastern Point Road, Groton, CT 06340. Fax: (860) 441-7049. E-mail: [email protected]. Received November 8, 2011; accepted April 3, 2012 Pregabalin increased the incidence of hemangiosarcomas in carcinogenicity studies of 2-year mice but was not tumorigenic in rats. Serum bicarbonate increased within 24 h of pregabalin administration in mice and rats. Rats compensated appropriately, but mice developed metabolic alkalosis and increased blood pH. Local tissue hypoxia and increased endothelial cell proliferation were also confirmed in mice alone. The combination of hypoxia and sustained increases in endothelial cell proliferation, angiogenic growth factors, dysregulated erythropoiesis, and macrophage activation is proposed as the key event in the mode of action (MOA) for hemangiosarcoma formation. Hemangiosarcomas occur spontaneously in untreated control mice but occur only rarely in humans. The International Programme on Chemical Safety and International Life Sciences Institute developed a Human Relevance Framework (HRF) analysis whereby presence or absence of key events can be used to assess human relevance. The HRF combines the MOA with an assessment of biologic plausibility in humans to assess human relevance. This manuscript compares the proposed MOA with Hill criteria, a component of the HRF, for strength, consistency, specificity, temporality, and dose response, with an assessment of key biomarkers in humans, species differences in response to disease conditions, and spontaneous incidence of hemangiosarcoma to evaluate human relevance. Lack of key biomarker events in the MOA in rats, monkeys, and humans supports a species-specific process and demonstrates that the tumor findings in mice are not relevant to humans at the clinical dose of pregabalin. Based on this collective dataset, clinical use of pregabalin would not pose an increased risk for hemangiosarcoma to humans. Key Words: hemangiosarcoma; mice; pregabalin; α2δ subunit; mode of action; human relevance; clinical trials. Pregabalin is effective for the treatment of neuropathic pain (associated with diabetic peripheral neuropathy, postherpetic Disclaimer: The authors certify that all research involving human subjects was done under full compliance with all government policies and the Helsinki Declaration. neuralgia, and following spinal cord injury), as an adjunctive therapy in the treatment of partial seizures, and in the treatment of generalized anxiety and fibromyalgia. An increased incidence of a single tumor type, hemangiosarcomas, was seen in male and female mice when fed with the diet for approximately 2 years (Pegg et al., unpublished data). These tumors were located predominantly in liver, spleen, and bone marrow, which are hematopoietic tissues in mice. In contrast, there was no increased incidence of hemangiosarcomas, or any other tumor type, in rats fed with dosages that achieved equivalent concentrations of pregabalin in the feed for 2 years. In a battery of tests, pregabalin was found to be nongenotoxic (Pegg et al., unpublished data). Hemangiosarcomas are endothelial cell–derived tumors that comprise poorly differentiated, proliferating endothelial cells (Mendenhall et al., 2006). These tumors form spontaneously and in response to many different compounds in mice but are rare in humans. To our knowledge, there are only two examples of hemangiosarcoma induction by a chemical stimulus that occur in both humans and rodents (i.e., mouse and rat). Both examples are genotoxic carcinogens (vinyl halides and Thorotrast), and both produce primarily liver hemangiosarcoma (Boivin-Angele et al., 2000; Lipshutz et al., 2002). In contrast, numerous commercial pharmaceutical products and chemicals that produce hemangiosarcomas solely in rodents act by nongenotoxic, proliferative mechanisms (Cohen et al., 2009). Previous manuscripts in this series have provided the proposed mode of action (MOA) for the species-specific, nongenotoxic formation of hemangiosarcomas in mice (Criswell et al., unpublished data), whereas this manuscript provides an evaluation of human relevance including assessment of several biomarkers of the early events in humans. The Hill Criteria (Hill, 1965) have long been utilized by epidemiologists to evaluate data and identify causality. The International Programme © The Author 2012. Published by Oxford University Press on behalf of the Society of Toxicology. All rights reserved. For permissions, please email: [email protected] 58 CRISWELL ET AL. on Chemical Safety (IPCS) has recommended this rigorous process and the International Life Sciences-Risk Sciences Institute (ILSI-RSI) outlined a methodology referred to as the Human Relevance Framework (HRF) to evaluate human risk from animal hazard assessment studies. The Hill criteria form a key component of the HRF process. An excellent example and model for using this evaluation approach was provided by Pastoor et al. (2005), which described thiamethoxam-related mouse tumors and their relevance to human health. This manuscript follows the ILSI-RSI HRF approach outlined by Meek and coworkers (2003) where the MOA in rodents is described and then three fundamental questions are answered to make a HRF assessment: (1) Is the weight of evidence sufficient to establish the MOA in animals? (2) Are the key events in the animal MOA plausible in humans? and (3) Taking into account kinetic and dynamic factors, is the animal MOA plausible in humans? The Hill criteria are embedded in Question 1. SUMMARY OF PROPOSED MOA IN RODENTS Figure 1 summarizes the key events in the pregabalin MOA and contrasts the findings between those seen in mice versus rats. Mice react inadequately to metabolic alkalosis following pregabalin administration, thus creating a cascade of events starting with an increase in serum bicarbonate and leading to sustained depression of respiratory rate and minute volume (Criswell et al., unpublished data). The sustained increase in blood pH hampers oxygen release from hemoglobin due to the Bohr effect, creating conditions conducive to hypoxia. Persistent perturbation of acid-base balance in mice is consistent with the identification of chronic tissue hypoxia in this species (Fig. 1, Criswell et al., unpublished data). One method of compensating for hypoxia is an increased production of erythrocytes to provide greater oxygen-carrying capacity. An appropriate circulating erythrocytosis is seen in rats but is lacking in mice, highlighting an additional key species-specific event that contributes to tissue hypoxia in mice alone (Criswell et al., unpublished data). The inability of the mouse to increase erythrocytes is due to dysregulated erythropoiesis that is apparent in bone marrows. Spontaneous hemangiosarcomas in mice occur primarily in hematopoietic tissues (liver, spleen, bone marrow) (Cohen et al., 2009), and pregabalin increased the incidence of hemangiosarcomas in these tissues as well (Pegg et al., unpublished data). In mice, pregabalin treatment increased platelet and megakaryocyte counts, decreased myeloid to erythroid ratio (M:E) up to 49%, increased the number of bone marrow macrophages/erythrophages, and was associated with the congestion of bone marrow and spleen and with extramedullary splenic hematopoiesis (Criswell et al., unpublished data). Bone marrow changes occurred early, within 1–3 months of the drug in diet, so were not the result of tumor formation (Criswell et al., unpublished data) and were consistent with a temporal association. These findings demonstrate that dysregulated erythropoiesis is occurring in mouse bone marrow where enhanced red blood cell (RBC) production is occurring, but there is a failure of release. This failure of release explains the decreased RBC response of the mouse when compared with the rat and results in macrophage activation and increased hemosiderin production that increases oxidative stress (Fig. 1, Criswell et al., unpublished data). In contrast to mice, pregabalin administration decreased overall bone marrow cellularity in rats, including megakaryocytes (up to 24% decrease, Criswell et al., unpublished data). Decreases in megakaryocytes in rats correspond with decreased peripheral platelet counts, which are in contrast to elevations in platelet counts and highly proliferative bone marrow in mice. There was no evidence of macrophage or erythrophage accumulation in rats, and M:E ratios were similar to those in the controls (Criswell et al., unpublished data). The effects seen in mice and absent in rats and monkeys suggest an association between hematopoietic stimulus and selective endothelial tumor induction in mice. In addition, they provide potential sentinel biomarkers for assessing the potential risk to humans. Hematopoiesis and angiogenesis are closely linked. Endothelial cells, the cell type of origin for hemangiosarcomas, are believed to be derived from a common hematopoietic precursor, the hemangioblast (Keller, 2001). Two hypotheses have been described for the cellular ontogeny of spontaneous hemangiosarcomas: either a series of mutations occur in fully differentiated vascular endothelial cells, giving them malignant potential or the malignant endothelial cells arise from bone marrow/hematopoietic-derived stem cells near the time of endothelial cell commitment (LameratoKozicki et al., 2006). Therefore, a highly proliferative, reactive bone marrow is relevant to hemangiosarcoma formation because bone marrow endothelial cells may migrate and repopulate other tissues such as the liver and spleen where pregabalin increased the incidence of hemangiosarcoma. An inflammatory component is also considered important in the MOA (Cohen et al., 2009) and is evidenced by a dose- and time-dependent increase in macrophages in the bone marrow, spleen, and liver of pregabalin-treated mice (Criswell et al., unpublished data). Macrophages can release reactive oxygen species that can damage endothelial cells as well as release angiogenic cytokines such as interleukin-6 to stimulate endothelial cell proliferation. Using immunohistochemistry, pregabalin was shown to increase tissue angiogenic growth factors (vascular endothelial growth factor [VEGF] and basic fibroblast growth factor [bFGF]) (Criswell et al., unpublished data) and increase endothelial cell proliferation as early as 2 weeks and sustained out to 12 months (Criswell et al., unpublished data). Therefore, mice treated with pregabalin demonstrate all of the components proposed by the unified MOA for nongenotoxic hemangiosarcoma formation (Cohen et al., 2009). Angiogenesis is an important physiologic process. It occurs monthly in the uterus of menstruating women, during pregnancy with the formation of the placenta, and in HUMAN RELEVANCE OF PREGABALIN-INDUCED HEMANGIOSARCOMA 59 FIG. 1. Mode of action of hemangiosarcoma formation in pregabalin-treated mice. wound healing. Because angiogenesis is so important, it is tightly regulated with over 20 angiogenic growth factors and more than 300 angiogenic inhibitors (http://www.angio.org/ understanding/fact.php). Although angiogenesis is a complex process, under regulated conditions the concentration of angiogenic inducers approximately equals the concentration of inhibitors (Fig. 2). During physiologic angiogenesis, hypoxia stimulates paracrine release of angiogenic growth factors. These growth factors bind to their specific receptors on endothelial cells, initiating a cascade of events including endothelial cell activation and endothelial cell proliferation, which ultimately leads to new blood vessel formation (Fig. 2). Once oxygenation is reestablished, the angiogenic process returns to a balanced state. Hence, these sequence of events characterize regulated angiogenesis. In contrast, the production of hemangiosarcomas in pregabalin-treated mice is believed to occur due to pathologic angiogenesis that is characterized by dysregulated angiogenesis (Fig. 3). Dysregulated angiogenesis refers to the condition where normal blood vessel formation does not occur in response to a hypoxia signal. Hence, there is a continued hypoxia signal leading to angiogenic growth factors exceeding inhibitors coupled with macrophage activation and release of reactive oxygen species that damage endothelial cells, all of which promote increased endothelial cell activation, proliferation, and damage of endothelial cell DNA (Fig. 3). Figure 4 illustrates a hemangiosarcoma in mouse liver where there is a pooling of blood from the blind vessels surrounded by the hemangiosarcoma. Hypoxia has been demonstrated in the liver of mice treated with pregabalin as well as time-related increases in multiple angiogenic growth factors (Criswell et al., unpublished data). Additionally, the discontinuous endothelium found in liver, spleen, and bone marrow is supported by numerous macrophages (Kupffer cells in the liver), an additional source of angiogenic growth factors. Angiogenesis is controlled by two different components, paracrine and autocrine. The paracrine component is driven by nonendothelial expression of angiogenic growth factors such as VEGF and bFGF. In the autocrine component, the endothelial cells themselves are induced to express VEGF (Fong, 2009). In pregabalin-treated mice, paracrine VEGF and bFGF were demonstrable in bone marrow and spleen and were particularly noteworthy in macrophages, megakaryocytes, and early erythroid cells (Criswell et al., 60 CRISWELL ET AL. FIG. 2. Regulated angiogenesis. Regulated angiogenesis leads to new blood vessel formation with reoxygenation of tissues. unpublished data). In the liver of these animals, vascular endothelial growth factor receptor 2 expression was increased. This suggests that both paracrine and autocrine increases in angiogenic growth factors are involved in pregabalin-treated mice, which drive an increase in the proliferation rate of endothelial cells (Fig. 1) (Criswell et al., unpublished data). The increase in endothelial cell proliferation can lead to an enhanced potential to fix spontaneous mutations because more cells are undergoing mitosis, resulting in growth dysregulation, clonal expansion of altered cells, and ultimately hemangiosarcoma formation (Cohen et al., 2009). Based on the above, the MOA for pregabalin has been established in mice and is consistent with the proposed unified MOA for hemangiosarcoma by other nongenotoxic compounds (Cohen et al., 2009). On the basis of the above MOA described for pregabalin in mice, we address the three fundamental questions to make a HRF assessment: (1) Is the weight of evidence sufficient to establish the MOA in animals? (2) Are the key events in the animal MOA plausible in humans? and (3) Taking into account kinetic and dynamic factors, is the animal MOA plausible in humans? Question 1: Is the Weight of Evidence Sufficient to Establish the MOA in Animals? The Hill criteria are a list of nine characteristics that help distinguish association from causation. These criteria include (1) analogy (considerations of alternate explanations), (2) strength of association, (3) consistency of association, (4) specificity (a single putative cause produces a specific effect), (5) temporality (exposure precedes outcomes), (6) dose-response relationships, (7) biologic plausibility, (8) coherence (association is compatible with existing theory), and (9) experiment (the condition can be prevented or ameliorated by an appropriate experimental regimen). Numerous studies ranging in length from 24 h to 2 years have amassed the data necessary to develop the proposed MOA and evaluate these criteria in mice, rats, monkeys, and humans administered with pregabalin. Analogy (Consideration of Alternate Explanations). Rodent nongenotoxic carcinogens generally act by modifying the normal physiology of specific tissues, resulting in increased cell proliferation. Increased cell proliferation can result from increased cell replication due to cytotoxicity/regenerative hy- HUMAN RELEVANCE OF PREGABALIN-INDUCED HEMANGIOSARCOMA 61 FIG. 3. Dysregulated angiogenesis. Dysregulation of angiogenesis may lead to enhanced endothelial cell proliferation with enhanced potential to fix spontaneous mutations (because more cells are undergoing mitosis), resulting in growth dysregulation, clonal expansion of altered cells, and ultimately hemangiosarcoma formation. perplasia, direct or indirect (e.g., hormonally induced) mitogenesis, decreased apoptosis, or combinations of these effects. Cell proliferation is required for fixation of spontaneous mutations secondary to replicative DNA synthesis and/or may facilitate selective clonal growth of spontaneously initiated cells. Neoplasms ultimately develop from these spontaneously initiated or preneoplastic cells. Data indicate that pregabalin increases endothelial cell proliferation in mice treated for at least 2 weeks and up to 1 year at a dose that resulted in an increased incidence in hemangiosarcomas, a key feature in nongenotoxic carcinogenesis (Criswell et al., unpublished data). There was no histopathologic evidence of cytotoxicity in endothelial cells of mice in repeat-dose toxicity studies with pregabalin (Pegg et al., unpublished data); thus, regenerative hyperplasia is unlikely to be responsible for increased endothelial cell proliferation. In vivo, pregabalin did not affect apoptosis of hepatic endothelial cells (unpublished data), and it did not induce proliferation in vitro of splenic endothelial cells isolated from B6C3F1 mice, indicating that pregabalin is not a direct endothelial cell mitogen (unpublished data). Therefore, these alternate explanations are not operational, and the most likely explanation is dysregulated angiogenesis. Strength of Association and Dose-Response Relationships. Endothelial cell proliferation is essential for the initiation of angiogenesis. It has been demonstrated in multiple models that the complex process of angiogenesis begins when cells respond to hypoxia, allowing accumulation of hypoxia-inducible factors and secondarily increasing paracrine and autocrine angiogenic growth factors. Hypoxia is a commonly accepted trigger for endothelial cell proliferation and angiogenesis (Fong, 2008, 2009; Pugh and Ratcliffe, 2003; Schäfer et al., 2003; Semenza, 2001). Tissue-specific hypoxia was demonstrable in mice treated with 62 CRISWELL ET AL. FIG. 4. This slide illustrates a hemangiosarcoma in a B6C3F1 mouse liver. The red region is the pooling of blood that occurs when the endothelial cells do not form the normal tube-like blood vessel structure. pregabalin but not in rats (Criswell et al., unpublished data). This correlates with a mouse-specific increase in endothelial cell proliferation and increased incidence of h emangiosarcomas. Pregabalin treatment at exposures comparable to those achieved in the mouse carcinogenicity studies did not induce hemangiosarcoma or tumors of any type in rats (Pegg et al., unpublished data), a species also known to develop hemangiosarcoma spontaneously but at a much lower frequency than mice (Poteracki and Walsh, 1998; Walsh and Poteracki, 1994). Although dose-response relationships were not evaluated for all endpoints of experiments conducted over a 2-year period, a dose-response relationship was evident in endothelial cell proliferation, bone marrow changes, increases in macrophage numbers, and platelet counts and function in mice (Criswell et al., unpublished data). Additionally, B6C3F1 mice exposed to pregabalin demonstrated higher levels of respiratory depression than CD-1 mice with equivalent exposures (Criswell et al., unpublished data). Strain sensitivity of response to respiratory depression correlates with higher levels of hemangiosarcoma formation in B6C3F1 mice compared with CD-1 mice (Pegg et al., unpublished data). Consistency of Data. Pregabalin produces hemangiosarcoma in two strains of mice (B6C3F1 and CD-1) but not in two bioassays conducted with Wistar rats. Effects on bicarbonate, bone marrow, respiration, metabolic changes, and endothelial cell proliferation were reproducible at several time points and in repetitive studies. Consistent with the criteria that hypoxia is an accepted trigger for endothelial cell proliferation, evidence of hypoxia in the mouse is accompanied by endothelial cell proliferation, whereas rats do not demonstrate tissue hypoxia and do not increase endothelial cell proliferation (Criswell et al., unpublished data). Specificity (Single Putative Cause Produces Specific Effect). To our knowledge, there is no specific disease model that produces the exact effects observed with pregabalin administration in mice. However, loss of von Hippel-Lindau (VHL) tumor suppressor protein represents an extreme condition that mimics a sustained hypoxic state in which hypoxia inducible factor (HIF) is constitutively stabilized, leading to the inappropriate activation of genes associated with endothelial cell proliferation, increased VEGF, and erythropoietin. Mutation in VHL tumor suppressor gene in mice produces life-long elevation of HIF with associated elevations in VEGF and other angiogenic growth factors and predisposes VHL+/– heterozygote mice to hemangiosarcoma formation (Kleymenova et al., 2004). This demonstrates the relationship between chronic life-long hypoxia and hemangiosarcoma formation in mice. In humans, VHL disease is an autosomal dominant disorder that is associated predominantly with clear cell renal carcinomas and benign retinal hemangioblastomas, but there is no evidence that transformation to malignant hemangiosarcomas occurs in people (Gordeuk et al., 2004; Kleymenova et al., 2004; Nordstrom-O’Brien, 2010), suggesting a species-specific sensitivity for this tumor type. Although the susceptibility is undoubtedly different between species, it should not be oversimplified because benign angiomatous proliferative lesions can also be identified in VHL knockout mice. Interestingly, however, the Kleymenova (2004) VHL mutation model failed to produce any effects on renal cancer in mice, further demonstrating species differences. Additionally, even in VHL patients, there is a strong genotype-phenotype correlation in VHL disease. The location of the mutation determines the type of tumor that arises (Kaelin, 2002) or if a predisposition to tumor formation exists at all. Individuals with a 598C→T mutation in exon 3 of VHL are not predisposed to tumor formation of any type; instead, these individuals have a disease known as Chuvash polycythemia (Hickey et al., 2007). Importantly, individuals with Chuvash polycythemia also demonstrate life-long elevations of HIF, with increased levels of VEGF and erythropoietin without evidence of increased risk of tumor formation, further suggesting a decreased sensitivity in people compared with mice for this tumor type. Multiple other compounds that produce hemolysis also produce hemangiosarcomas in mice (2-butoxyethanol [BE], phenylhydrazine, aniline). Hemolysis produces tissue hypoxia through active destruction of erythrocytes and results in decreased availability of red blood cells to carry adequate oxygen to tissues. Hemolysis is also classically associated with upregulation of bone marrow erythroid production and splenic increases in erythrocytes in rodents. Additionally, an inflammatory component accompanies hemolytic processes due to the release of cytotoxic products of hemoglobin degradation when it occurs within the vascular system. Therefore, these hemolytic compounds, as per the data from VHL gene mutations and pregabalin, support the specificity of hypoxia to induce hemangiosarcoma in mice. HUMAN RELEVANCE OF PREGABALIN-INDUCED HEMANGIOSARCOMA 63 Temporality (Exposure Precedes Outcome). Pregabalin produces increases in bicarbonate on day 1, and local tissue hypoxia and macrophage increases and bone marrow changes are seen as early as 2 weeks (Criswell et al., unpublished data). Bone marrow changes are progressive with time. All of these changes occur well before the first occurrence of hemangiosarcoma. Endothelial cell proliferation was increased as early as 2 weeks in the liver and 12 weeks in the bone marrow (Criswell et al., unpublished data). Hemangiosarcomas were not evident until after 12 months, and most occurred after 18 months or longer of pregabalin treatment. (Cunningham, 2002; Siesky et al., 2002). A vitamin E intervention study blocked hepatic pregabalin-induced endothelial cell proliferation in mice (Criswell et al., unpublished data). These data are consistent with the proposed MOA and also with the species specificity as vitamin E levels equivalent to those found in rats were sufficient to block endothelial cell proliferation in mice. Humans have even higher vitamin E levels than rats or mice, and so they have greater antioxidant protective reserve and presumably would be at lower risk for induction of hemangiosarcoma. Plausibility and Coherence (Association Should Be Compatible With Existing Theory). Hemangiosarcomas are vascular tumors. Physiologic angiogenesis is well characterized, and the hypothesis that dysregulated angiogenesis is responsible for induction of hemangiosarcoma is a logical extension based on disruption of a normal physiologic process. Pregabalin acts through a nongenotoxic mechanism to produce hemangiosarcomas in mice. Increased proliferation of the target cell type or hyperplasia is an accepted hallmark of nongenotoxic tumorigenesis. It should be anticipated that increases in endothelial cell tumors would be driven by biological drivers that increase proliferation rate of endothelial cells. Disruption of normal physiologic processes is well accepted for rodent thyroid tumors and Leydig cell tumors, which are driven by the growth factors specific for these cell types. For example, elevated thyroid stimulating hormone induces hyperplasia and thyroid tumors in rats, and increased luteinizing hormone concentrations result in stimulation of Leydig cells, which also produce an increased incidence of hyperplasia and adenomas in rats. In both cases, rodents have been characterized as containing endocrine tissue that is “highly sensitive” and not characteristic of the response in humans (Capen, 2000). Hypoxia is a commonly accepted driver for angiogenesis and endothelial cell proliferation. Hypoxia is known to stimulate angiogenesis, and sustained life-long hypoxia is known to induce hemangiosarcoma in mice as evidenced by mice with the VHL mutation (Kleymenova et al., 2004). Furthermore, tissue hypoxia has been proposed as the key event in the formation of mouse-specific hemangiosarcomas with a diversity of agents including peroxisome proliferator activated receptor (PPARγ), 2-BE (a hemolytic industrial solvent), and pregabalin (Cohen et al., 2009), demonstrating a common mechanism among diverse compounds. Therefore, dysregulated angiogenesis as a response to a sustained hypoxia signal is biologically plausible for hemangiosarcoma formation in mice. Question 2: Are the Key Events in the Mouse MOA Plausible in Humans? The basic premise is that nongenotoxic compounds induce hemangiosarcoma by dysregulated angiogenesis, which is to say, dysregulation of physiologic angiogenesis. Although physiologic angiogenesis is similar across species and therefore plausible in humans, there are several reasons why this is unlikely to occur in humans. Treatment of mice for 2 years with pregabalin induces an increased incidence of hemangiosarcoma, but the latency and tissue distribution of the tumor are not altered from those that arise spontaneously (Pegg et al., unpublished data). Thus, in mice, pregabalin appears to exacerbate extant processes associated with the spontaneous occurrence of hemangiosarcoma. Increases in serum bicarbonate and tissue hypoxia are events that could occur in any species. Therefore, a simple assumption might be that the proposed MOA may be operational in other species. However, there is strong evidence that this is not the case. The most convincing evidence is that although rats also demonstrate the same increase in bicarbonate as mice, pregabalin does not induce hemangiosarcomas in rats (Pegg et al., unpublished data). Although there are many biological processes that can result in tissue hypoxia, there are an equally diverse set of compensatory processes that typically prevent the development of long-term hypoxia. The ability of pregabalin to sustain respiratory depression over the lifetime of the mouse (assessed up to 22 months) with an associated metabolic alkalosis without adequate compensatory mechanisms is highly unique and has been identified only in the mouse (Criswell et al., unpublished data). In contrast, rats exposed to pregabalin demonstrate appropriate compensatory processes. Evaluation of species-specific responses helps to frame the relevance of any toxicological finding to human health. Similar duration studies were conducted in the mouse and rat to compare the toxicologic response in a species sensitive to hemangiosarcoma formation with long-term pregabalin administration and in a species where there is no evidence of this tumor (Criswell et al., unpublished data). Table 1 summarizes the species-specific changes in key elements of the MOA, including studies conducted in monkeys for up to 1 year. The key difference between mice and rats is that mice respond inadequately to an acid-base imbalance with subsequent development of chronic Experiment (Condition Can Be Prevented or Ameliorated by an Appropriate Experimental Regimen). Vitamin E is a fat-soluble antioxidant that has been shown to inhibit angiogenic growth factors (Woodson et al., 2002) and inflammatory cytokines (Huey et al., 2008). Additionally, it has been shown with 2-BE that the level of oxidative injury and associated cell proliferation in liver is inversely related to vitamin E levels 64 CRISWELL ET AL. TABLE 1 Species Specificity of Pregabalin-Induced Changes in Parameters Associated With Hemangiosarcoma in Mice Parameter Increased bicarbonate Decreased respiration Acid-base imbalance Bone marrow congestion Macrophage/erythrophage proliferation Extramedullary hematopoiesis Increased platelets and/or megakaryocytes Increased platelet activation Altered platelet morphology Altered platelet aggregation Increased circulating PDGF Increased VEGF (bone marrow and spleen) Increased bFGF (bone marrow and spleen) Increased VEGFR2 (liver) Chronic tissue hypoxia Increased endothelial cell proliferation Increased incidence of hemangiosarcoma B6C3F1 mice Wistar rat Monkey Human + + + + + + + – – – – – – – – – – N.T. N.T. N.T. + + – – – – N.T. – + + + + + – – – – – – – – N.T. N.T. – – – N.T. N.T. + – N.T. N.T. + + + – – – N.T. N.T. N.T. N.T. N.T. –a + – – – Note. + = effect; – = no effect. N.T., not tested; PDGF, platelet-derived growth factor; VEGFR2, vascular endothelial growth factor receptor 2. a As assessed by negative effects on thrombomodulin. tissue hypoxia. These differences can be summarized as follows: (1) Rats respond appropriately to acute metabolic alkalosis. They effectively decrease respiration rate. In contrast to mice, rats normalize minute volumes; (2) Rats also show the anticipated compensatory response to increased serum bicarbonate, which returns the HCO3:pCO2 ratios to control levels. This results in the expected acid balance and no impact on blood pH; (3) Rats respond to acute changes with a peripheral erythrocytosis such that circulating erythrocyte counts are nearly 20% higher than those in untreated control rats by the end of the 2-year bioassay. The presence of increased erythrocytes provides another appropriate and expected compensatory response to provide additional oxygenation to tissues; (4) Rats did not demonstrate the key components of the proposed MOA (i.e., hypoxia, increased endothelial cell proliferation, dysregulated erythropoiesis). There was no evidence of tissue hypoxia in liver when assessed with an immunohistochemistry stain for hypoxia (Hypoxyprobe, NPI, Burlington, MA) or a transcriptomic/pathway analysis. There was no evidence of increases in macrophages, angiogenic growth factors, the production of a reactive, proliferative bone marrow, and most importantly, no evidence of endothelial cell proliferation; and (5) Rats have higher levels of vitamin E than mice, which may provide an additional protective mechanism against hemangiosarcoma formation likely via multiple protective effects on angiogenesis. Importantly, several of these endpoints provide potential biomarkers that can be used to assess risk in humans. Scientific contributions to the literature surrounding hemangiosarcomas in mice have also added to the ability to evaluate human relevance. For the first time, tissue hypoxia and, perhaps more importantly, how mice uniquely respond to that metabolic alkalosis leading to hypoxia, have been proposed as the key event in the formation of mouse-specific hemangiosarcomas with a diversity of agents including PPARγ agonists, 2-BE (a hemolytic industrial solvent), and pregabalin (Cohen et al., 2009). A recent systems biology study of 2-BE demonstrates that hypoxia is a contributing factor for hemangiosarcoma formation in mice by this industrial solvent (Laifenfeld et al., 2010). Hypoxia is a well-accepted signal for increased endothelial cell proliferation and normal angiogenesis. Further suggestive evidence of the lack of relevance of hypoxia as a sole inducing effect of hemangiosarcoma in humans is that there is no epidemiological evidence that people living at high altitudes have a greater incidence of hemangiosarcoma, whereas Mori-Chavez et al. (1970) report that exposure of mice to high altitude does increase the incidence of spontaneous ovarian angiomas. Many of the compounds reported to produce hemangiosarcomas in mice by nongenotoxic mechanisms are hemolytic in nature (Cohen et al., 2009). Chronic hemolysis would drive hematopoietic compensatory mechanisms increasing proliferative activity of bone marrow and spleen and accumulating iron—attributes that have also been identified with pregabalin administration even though pregabalin does not produce hemolysis. Recent advances in the understanding of tumor angiogenesis highlight the important role of circulating, bone marrow– derived progenitor cells, including both endothelial and monocyte/macrophage lineage cells, in pathological angiogenesis (Ding et al., 2008; Lamerato-Kozicki et al., 2006). These findings suggest that hemangiosarcomas may arise not only from transformation of tissue-resident endothelial cell populations but also from circulating progenitors or adult stem cells recruited from bone marrow or possibly also from extramedullary sites such as the spleen. The marked differences in bone marrow and spleen of pregabalin-treated mice compared with bone marrow of rats and monkeys further highlight the speciesspecific components of the proposed MOA. There are no reports of increased hemangiosarcomas in humans with chronic hemolytic disease or bone marrow proliferative disorders. Question 3: Taking into Account Kinetic and Dynamic Factors, Is the Animal MOA Plausible in Humans? This phase of the ILSI-RSI HRF decision-making process requires a quantitative and kinetic analysis to determine whether the MOA observed in animals could plausibly occur in humans. Species-specific susceptibility to spontaneous occurrence of hemangiosarcoma constitutes a major element in determining human relevance. Hemangiosarcoma is a relatively common tumor in mice, with a spontaneous incidence as high HUMAN RELEVANCE OF PREGABALIN-INDUCED HEMANGIOSARCOMA as 10–12% in some cases (Chandra and Frith, 1992a,b; Eiben, 2001; Giknis and Clifford, 2005; Haseman et al., 1988, 1999; Tamano et al., 1988; Ward et al., 1979). It follows that mice are highly susceptible to endogenous factors perturbing normal homeostatic mechanisms and inducing target endothelial cell proliferation. In contrast, the spontaneous incidence of hemangiosarcoma in humans has recently been estimated at 0.00021%, indicating that humans are substantially less susceptible to spontaneous hemangiosarcoma development than mice (U.S. National Cancer Institute SEER Database). Recent publications provide further evidence that the mouse is more susceptible to the induction of hemangiosarcoma than humans: • Spontaneous cell proliferation rates (labeling index) of hepatic endothelial cells in mice (0.84–1.14), rats (0.28–0.36), and humans (0.20–0.25) correlate with the spontaneous incidence of hemangiosarcoma (Ohnishi et al., 2007). • Troglitazone, a compound that produces hemangiosarcomas in mice but not in rats, has been shown to stimulate endothelial cell proliferation in mouse, but not human microvascular endothelial cells (Kakiuchi-Kiyota et al., 2009). • Mice have lower antioxidant levels (e.g., vitamin E) than rats (2.5-fold higher than mice) and humans (100-fold higher), which may contribute to enhanced susceptibility to developing hemangiosarcoma in mice but not in rats treated with 2-BE (Siesky et al.,2002). By supplementing the diet of mice with vitamin E to levels typically found in rats, pregabalin-induced increases in endothelial cell proliferation were inhibited. • Humans who have mutations in the VHL do not develop hemangiosarcoma, yet mice do develop tumors (Gordeuk et al., 2004; Kleymenova et al., 2004). • There are no reports of increased hemangiosarcomas in humans with chronic hemolytic disease or bone marrow proliferative disorders. • Further suggestive evidence of the lack of relevance of hypoxia as a sole inducing effect of hemangiosarcoma in humans is that there is no epidemiological evidence that people living at high altitudes have a greater incidence of hemangiosarcoma, whereas Mori-Chavez et al. (1970) report that exposure of mice to high altitude does increase the incidence of spontaneous ovarian angiomas. Based on the above evidence, humans do appear to be less susceptible to hemangiosarcoma induction than mice. Beyond species-specific differences in the spontaneous rate of hemangiosarcomas, carcinogenicity studies in rats and mice achieved similar exposure levels, yet hemangiosarcomas were found only in mice. The negative finding in rats was confirmed by a second negative 2-year carcinogenicity study in Wistar rats. Although most of the mechanistic experiments in rodents were conducted at doses resulting in exposures greater than those achieved in humans, effects on platelet number, platelet function, platelet morphology, and bone marrow were seen in mice at 200 mg/kg 65 with exposures equivalent to a human dose of 600 mg. Therefore, exposures comparable to those in mice at which platelet and bone marrow effects were elicited have been achieved in humans but without similar effects on platelets, which further supports lack of human evidence for the mechanism. To test the human relevance, several key biomarkers identified in the mouse MOA experiments were assessed in humans. Use of these biomarkers allows the assessment of the question remaining, namely, whether results in humans are more similar to results in mice or rats. This evaluation was conducted through quantitative evaluation of key components of the MOA in humans in clinical trials measuring several biomarkers. Assessment of Key Elements of the MOA in Humans Compared With the Effects Seen in Mice. Potential effects of pregabalin on key elements of the MOA established in mice were investigated in a human clinical trial. The clinical trial study design is described in the Supplemental Section. It was not ethically possible to duplicate endothelial cell proliferation and hypoxia assays in humans as current methods would have required obtaining liver sections. Therefore, selective biomarkers were evaluated in a clinical trial to assess whether pregabalin treatment at the maximum therapeutic dose altered key elements of the MOA established in mice. Bicarbonate was measured because this is hypothesized to be the initial event in the mouse for the induction of hemangiosarcoma. White blood cell (WBC) counts, platelet numbers, and platelet function were measured as biomarkers of dysregulated erythropoiesis. The data supporting platelets as a biomarker have been previously described (Criswell et al., unpublished data). Because increased endothelial cell proliferation is paramount in the production of hemangiosarcomas by nongenotoxic mechanisms and direct assessment of endothelial cell proliferation in humans was not possible, thrombomodulin and the generation of Annexin Vlabeled circulating endothelial microparticles, markers of endothelial cell activation or injury, were evaluated as alternate biomarkers of endothelial cell proliferation. Because endothelial cell activation is a prerequisite step for endothelial cell proliferation to occur in normal angiogenesis, it was considered a relevant biomarker for endothelial cell proliferation. Bicarbonate. Serum bicarbonate values were assessed in humans receiving 600 mg/day pregabalin in the 1-month study at 24 h, 15 days, and 29 days. There was no change in bicarbonate in pregabalin-treated subjects compared with controls (Table 2; Fig. 5). This demonstrates that at maximum recommended dose, pregabalin does not increase bicarbonate as it does in mice and rats. Respiratory depression in humans of a magnitude comparable to that in mice would most certainly have been evident clinically in volunteers. Additionally, although blood pH was not measured in the clinical study of platelet function, there was no evidence that venous bicarbonate levels were affected by pregabalin treatment in humans. Therefore, humans are either not susceptible to the elevations of bicarbonate at a daily 66 CRISWELL ET AL. TABLE 2 Bicarbonate Concentrations in Plasma in Healthy Volunteers Receiving Placebo or Pregabalin Bicarbonate concentration (mmol/L ± S.D.) Dose group Placebo Screening Day 1 – Day 15 Day 29 Predose 28.1 ± 1.91 24.8 ± 2.05 25.4 ± 2.37 24.3 ± 1.97 Pregabalin 27.5 ± 1.92 24.9 ± 2.11 25.5 ± 1.85 25.2 ± 1.55 (300 mg/ BID) Close-out 27.8 ± 1.74 27.8 ± 2.33 Note. n = 18–22 subjects per time point. maximum dose of 600 mg or, in contrast to mice, are able to compensate adequately. This demonstrates that the first identifiable event in the mouse MOA, elevation in serum bicarbonate levels, with a resulting metabolic alkalosis does not occur in humans. WBC and Platelets. There were no effects on WBC or platelet count at day 15 or 29 in this clinical trial (results not shown). In mice, pregabalin treatment is associated with increased WBC (approximately twofold), platelet count (approximately 20–30%), changes in morphology (giant platelets, agranular platelets, aggregates), and increase in platelet activation based on P-selectin expression (Criswell et al., unpublished data). Although direct examination of bone marrow has not been done in humans, lack of peripheral changes in humans and lack of bone marrow changes in rats (up to 2 years) and monkeys (up to 69 weeks) supports a species-specific difference in a key FIG. 5. HCO3 concentrations assessed on pretest, day 15, and day 29 in subjects receiving placebo (blue circles) or 600 mg/kg pregabalin/day (red triangles). There was no difference in HCO3 between placebo and pregabalintreated subjects. Closed symbols represent arithmetic means. component of the proposed MOA. Therefore, the absence of effects on WBC and platelet count, morphology, and function demonstrates that dysregulated erythropoiesis is not occurring in humans treated for 1 month with pregabalin. Platelet Function Assays. There were no statistically significant (p < 0.05) differences between placebo and pregabalintreated groups on days 15 or 29 for the primary (nonparametric) analysis of P-selectin (a marker for platelet activation; Fig. 6). Pregabalin had no effect on platelet or erythrocyte morphology as visualized by light microscopy. Furthermore, in patients given pregabalin at up to 600 mg/day for up to 3 years, there were no clinically significant changes in platelet morphology, considered a surrogate marker of platelet activation (data not shown). For comparison, platelet activation was increased 46% within 1 month at the tumorigenic dose of 1000 mg/kg in mice, and platelet counts were increased from 32 to 58% above the control range after 2 years of treatment in the carcinogenicity studies with mice. Pregabalin had no effect on maximum platelet aggregation (Fig. 7a) and no effect on ADP threshold aggregation (Fig. 7b). Similarly, pregabalin had no clinically relevant effect on platelet function analyzer (PFA)-100 closure time stimulated by either ADP or epinephrine (Figs. 8a and b). The results in humans differ markedly from what was observed in mice, where there was a 28–46% decrease in maximum aggregation in pregabalin-treated animals, consistent with activation and depletion of dense granules. Thus, in contrast to the marked effects displayed in mice, platelet changes are not observed in humans administered with the maximum recommended clinical dose of pregabalin. Thrombomodulin and Annexin V Microparticles. Activation of endothelial cells is a prerequisite step that precedes endothelial cell proliferation in normal angiogenesis (Fig. 2). If there is no evidence of endothelial activation, FIG. 6. Mean platelet activation assessed by flow cytometric evaluation of platelet P-selectin on pretest, day 15, and day 29 in subjects receiving placebo (blue circle) or 600 mg/kg pregabalin/day (red triangle). There was no evidence of platelet activation in subjects receiving pregabalin. The dotted line at 2% represents the investigator-defined limit for subject inclusion in the study. HUMAN RELEVANCE OF PREGABALIN-INDUCED HEMANGIOSARCOMA 67 FIG. 7. Platelet aggregation assessed with a platelet aggregometer in human subjects. (a) Mean maximum percentage platelet aggregation in response to 300 µM ADP and (b) mean threshold concentration required to produce 75% aggregation of platelets was unchanged at days 15 and 29 in subjects receiving 600 mg/kg pregabalin (red triangles) compared with placebo (blue circles). Data offset for clarity. Dotted lines represent laboratory normal ranges. p rogression to endothelial cell proliferation would be unlikely. Therefore, because endothelial cell proliferation could not feasibly be assessed in humans, thrombomodulin and Annexin V-labeled microparticles were assessed as clinically relevant markers of direct endothelial cell damage and/or activation. Thrombomodulin is an endothelial cell transmembrane glycoprotein that plays an important role as an anticoagulant and is predominantly expressed on vascular endothelial cells of arteries, veins, and capillaries (Maruyama et al., 1985). Small amounts of thrombomodulin may also be detected on platelets, monocytes, and neutrophils (Fink et al., 1993). Soluble thrombomodulin is found in serum or urine and is probably released during endothelial cell damage or activation. Soluble thrombomodulin is considered to be a specific marker of endothelial cell injury (Ishii et al., 1991), and it has been used widely as a marker of microvascular endothelial injury and/or activation in various clinical disease states, including disseminated intravascular coagulation (Endo et al., 1995), multiple sclerosis (Tsukada et al., 1995), rheumatic diseases (Ohdama, et al., 1994), systemic lupus erythematosus, lupus nephritis (Frijns et al., 2001), renal transplant (Keven et al., 2010), congestive heart failure (Chong et al., 2009), preeclampsia, and uteroplacental insufficiency associated with intrapartum hypoxia (Moussa, 2010; http://www. obgyn.net/pregnancy-birth/pregnancy-birth.asp?page=/pb/ articles/moussa-preeclampsia). Therefore, assessment of thrombomodulin in subjects receiving pregabalin was utilized to assess direct endothelial cell injury and/or activation. FIG. 8. PFA-100 closure times in human subjects. The mean time required for hemodynamic closure when stimulated with (a) ADP or (b) epinephrine was similar in subjects receiving 600 mg/kg pregabalin (red triangles) for 15 or 29 days compared with placebo (blue circles). Data offset for clarity. Dotted lines represent laboratory normal ranges. 68 CRISWELL ET AL. Microparticles are fragments of membrane that are shed during apoptosis or activation of several cell types including erythrocytes, platelets, and endothelial cells (Martinez et al., 2005; Tesse et al., 2006). Increased levels of circulating microparticles serve as a marker for endothelial activation, endothelial dysfunction, or platelet activation (Martin et al., 1995). Annexin V is commonly used in flow cytometry as an early marker of apoptosis. Annexin V has the ability to bind to phosphatidylserine, which is exposed on the cell surface early in the process of apoptosis or cellular activation (Martin et al., 1995; Reutelingsperger and van Heerde, 1997). Increased levels of circulating endothelial Annexin V positive microparticles have been used as a valid predictor of endothelial effects in a broad variety of vascular disease states including atherosclerosis, renal failure (Amabile, et al., 2005; Shehata, et al., 2010), pulmonary hypertension (Amabile et al., 2008), and metabolic syndrome (Agouni et al., 2008). As such they serve as another valid marker of possible drug-induced effects on endothelial cells and vascular function. Pregabalin had no effect on endothelial cell activation as measured by soluble thrombomodulin. There were no statistically significant differences in thrombomodulin levels in humans receiving pregabalin from placebo observed on either days 15 or 29 (Fig. 9). Additionally, there were no differences in Annexin V labeling (Fig. 10a) or the number of endothelial microparticles (Fig. 10b) on either day 15 or 29, providing further evidence that pregabalin did not activate or directly injure endothelial cells in humans. Increases in endothelial cell FIG. 9. Comparison of mean serum soluble thrombomodulin assessed on pretest, day 15, and day 29 in subjects receiving placebo (blue circles) or 600 mg/kg pregabalin/day (red triangles). Pregabalin had no effect on soluble thrombomodulin: least-squares means and 95% confidence intervals from the parametric analysis. Data are offset for clarity. Dotted lines represent mean standard deviation reported in healthy males aged 21–55 years. proliferation were observed in mice as early as 2 weeks in the liver (Criswell et al., unpublished data). In summary, there was no evidence that pregabalin-treated patients or volunteers had changes in bicarbonate (the first event in the mouse for hemangiosarcoma formation), dysregulated erythropoiesis (changes in WBC or platelet function), or FIG. 10. (a) Comparison of Annexin V binding assessed on pretest, day 15, and day 29 in subjects receiving placebo or 600 mg/kg pregabalin/day. Pregabalin treatment in humans had no effect on Annexin V binding. Least-squares means with 95% confidence intervals from the parametric analysis. Triangles represent pregabalin-treated subjects and circles represent placebo; data are offset for clarity. (b) Comparison of endothelial microparticle formation assessed on pretest, day 15, and day 29 in subjects receiving placebo or 600 mg/kg pregabalin/day. Pregabalin treatment in humans had no effect on microparticle formation. Least-squares means with 95% confidence intervals from the parametric analysis (lower panel). Triangles represent pregabalin-treated subjects and circles represent placebo; data are offset for clarity. HUMAN RELEVANCE OF PREGABALIN-INDUCED HEMANGIOSARCOMA activated endothelial cells (thrombomodulin, Annexin V, or microparticles), which are surrogates for endothelial cell proliferation. These data support the conclusion that humans do not exhibit the specific responses to pregabalin treatment that were observed in the mouse and hence do not appear to be at increased risk for hemangiosarcoma at the maximum daily dosage of pregabalin. CONCLUSION This paper assessed the human relevance of pregabalininduced hemangiosarcoma in mice using the IPCS/ILSI-Health and Environmental Sciences Institute HESI HRF. The first step of this process is developing a data-driven MOA in animals and assessing the weight of evidence for the MOA using the Hill criteria. The proposed MOA for pregabalin is consistent with four other compounds previously reported as a unified MOA frame work proposed for induction of hemangiosarcoma in mice by nongenotoxic compounds (Cohen et al., 2009). Those key elements include hypoxia, macrophage activation, increased angiogenic growth factors, dysregulated angiogenesis/ erythropoiesis, and increased endothelial cell proliferation. The second step in the IPCS/ILSI-HESI HRF is assessing whether the key events in the animal MOA are plausible in humans. Because hemangiosarcoma is due to disruption of a physiologic process (i.e., angiogenesis), which is shared across all species, this MOA is theoretically plausible for humans. Therefore, one must address the third question of the HRF. The third step in the IPCS/ILSI-HESI HRF, taking into account kinetic and dynamic factors, asks if the animal MOA is plausible in humans. This was assessed by comparing susceptibility across species, disease states, and measuring key biomarkers in a clinical trial with pregabalin. Several lines of evidence were presented that supported the conclusion that the mouse is more susceptible to the induction of hemangiosarcoma than humans. Additionally, key biomarkers identified from the mouse studies were assessed in patients treated with the maximum recommended human dose of pregabalin. There was no evidence that pregabalin-treated patients or volunteers had changes in bicarbonate (temporally the first change identified in mice treated with pregabalin and likely responsible for elevation in blood pH in mice) or biomarkers for dysregulated erythropoiesis or endothelial cell proliferation. 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