Title: Clinical Pharmacology Subcommittee (CPSC) Report ACPS Presentation, May 3, 2005 J
1Clinical Pharmacology Subcommittee (CPSC)
ReportACPS Presentation, May 3, 2005Jürgen
Venitz, MD, Ph.D.Goals of the Advisory
SubcommitteeTo provide expertise and feedback
to ACPS, specifically in the areas
ofExposure-Response Modeling
(Pharmacometrics)Pediatric Clinical
PharmacologyPharmacogenetics
2CPSC Meeting, November 3-4, 2004Outline
- Meeting Topics
- CPSC Update
- Pharmacogenetic (PG) Testing of Irinotecan
- Drug-Drug Interaction (DDI) Potential Assessment
- Tribute to Lewis Sheiner, MD
- Biomarkers and Surrogate Markers
3CPSC Meeting, November 3-4, 2004CPCS Update (L.
Lesko, Ph.D., OCPB)
- 1. Identification of Populations at Risk
- Exposure-Response (E/R)
- Modeling and Simulations (M/S)
- Internal use continues to impact drug product
labeling recommendations - 2. Utility Functions in Risk Assessment
- No consensus on utility factors/weights
- On hold
4CPSC Meeting, November 3-4, 2004CPCS Update (L.
Lesko, Ph.D., OCPB)
- 3. Pediatric Decision Tree
- Pediatric Database within FDA
- Internal Research Project Ongoing
5CPSC Meeting, November 3-4, 2004CPCS Update (L.
Lesko, Ph.D., OCPB)
- 4. PG Testing for TMPT
- Pediatric Oncology Subcommittee recommended
labeling language (2003) - Negotiation with sponsors (6-MP, Azathioprin)
Ongoing - 5. DDI Assessment of NMEs
- Including CYP2C8 and CYP2B6
- Guidance Near Completion
6CPSC Meeting, November 3-4, 2004CPCS Update (L.
Lesko, Ph.D., OCPB)
- 6. End-of-Phase 2a Meetings (EOP2a)
- Initiative - Ongoing
- Guidance Under Development
- 7. Assessment of QT-liability
- Internal discussions regarding clinical study
designs and analyses - Ongoing
7CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- Presentations by
- 1. N.A. Rahman, Ph.D. OCPB
- 2. L. Parodi, MD, Pfizer
- 3. M. Ratain, MD, U of Chicago (Consultant)
8CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- Irinotecan (CPT-11, Camptosar) is an oncological
agent approved for first- and second-line
treatment of colorectal cancer - Major clinical toxicities, limiting its use, are
neutropenia (infections) and diarrhea - Complex PK
- CPT-11 forms the active metabolite, SN-38
- SN-38 is further metabolized by UGT1A1 to an
inactive glucuronide
9CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- UGT1A1 has various alleles
- for 28, the 7/7 allele (10 prevalence in
Caucasians) results in reduced glucuronidation - Other enzymes (CYP3A4, CE) and drug transporters
(P-gp) are involved in Irinotecan PK as well
(their significance is unknown)
10CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- Systemic SN-38 exposure is associated with 28
genotype (7/7 has higher exposures) - Systemic SN-38 exposure is positively correlated
with neutropenia - Relative risk of grade 4 neutropenia 9.3 for 7/7
genotype - Diarrhea is less clearly associated with 28
genotype
11CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- Known Risk Factors for Neutropenia (Label)
- Age
- Prior abdominal/pelvic radiation
- Low performance status
- increased bilirubin (UGT1A1 substrate)
- Proposed Risk Factor
- UGT1A1 Genotype (28, 7/7)
12CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- Current Information across 4 clinical trials
- (Odds Ratio of 7/7 versus 6/6 and 6/7)
- Neutropenia 2.5-16.7
- Diarrhea 0.4-8.4
- Note Studies were not designed to assess the
strength of association
13CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- Expected UGT1A1 28 PG Test Performance for
Neutropenia (Pfizer) - Sensitivity 22 PPV 50
- Specificity 95 NPV 83
- (overall incidence of neutropenia of 20)
14CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- Expected UGT1A1 28 PG Testing Performance for
Neutropenia (M. Ratain) - Without PG testing, 100 patients are treated,
and 10 develop grade 4 neutropenia - With PG testing, 90 of patient are treated, and
only 5 develop grade 4 neutropenia - Test 20 patients to protect 1
15CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- Concerns about PG Testing
- Current clinical studies are limited in assessing
the strength of association between neutropenia
and UGT1A128 genotype - Ongoing clinical trials may identify other PG
factors of significance - No validated dosing algorithm after PG testing
has been established - Possible loss of efficacy with reduced irinotecan
doses
16CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- Committee Votes (Yes-No-Abstain)
- 7/7 genotype is associated with a higher risk of
neutropenia 12-0-0 - 7/7 genotype is associated with a higher risk for
acute/delayed diarrhea 0-11-1 - 28 PG testing has adequate sensitivity and
specificity 9-0-3
17CPSC Meeting, November 3-4, 2004PG Testing of
Irinotecan
- Committee Comments
- Lack of optimal dosing regimen even without PG
testing - Lower doses may keep patient on regimen
- Additional clinical trial may be need to
establish a modified dosing regimen - Serum bilirubin (UGT1A1 substrate) may be safety
marker
18CPSC Meeting, November 3-4, 2004DDI Potential
Assessment
- Presentations by
- 1. S.-M. Huang , Ph.D., OCPB
- 2. K. Gottesdiener, MD, Merck
- 3. E. LaCluyse, CellzDirect (Consultant)
- 4. K. Reynolds, Pharm.D., OCPB
19CPSC Meeting, November 3-4, 2004DDI Potential
Assessment
- Issues
- FDA is updating DDI guidance for NMEs
- How to integrate in-vitro transporter studies?
- How to integrate in-vitro enzyme induction
studies? - Should multiple inhibitor/impairment in-vivo
studies be required?
20CPSC Meeting, November 3-4, 2004DDI Potential
Assessment
- Committee Votes
- If in-vitro lack of inhibition (CYP1A2, 2C9,
2C19, 2D6, 3A), no need for in-vivo DDI
study 12-0-1 - If in-vitro P-gp inhibition, need for in-vivo DDI
study with P-gp substrate (e.g., digoxin) 8-2-3 - If in-vitro P-gp substrate and 3A4 substrate,
need for in-vivo DDI study (e.g.,
ritonavir) 7-4-2
21CPSC Meeting, November 3-4, 2004DDI Potential
Assessment
- Committee Votes (continued)
- If in-vitro P-gp substrate and not 3A4 substrate,
need for in-vivo DDI study (e.g.,
verapamil) 6-5-2 - Recommend in-vivo DDI studies for CYP2B6, CYP2B8,
UGT1A1? 11-0-2 - Recommend in-vivo DDI studies for OATP and MRP
transporters? - 3-7-3
22CPSC Meeting, November 3-4, 2004DDI Potential
Assessment
- Committee Votes (continued)
- If in-vitro induction gt40 of positive control,
need for in-vivo DDI study 3-8-2 - If in-vitro lack of CYP3A4 induction, no need for
in-vivo DDI studies for CYP3A4, 2C9, 2C19,
2B6 9-1-3 - Should multiple inhibitor/impairment (in-vivo)
studies be recommended? 0-12-1
23CPSC Meeting, November 3-4, 2004Tribute to Lewis
Sheiner, MD
- Tribute by T. Blaschke, MD, UCSF
- Lewis Sheiner, MD, UCSF passed away in 2004
- Inaugural member of CPSC (long-term FDA
consultant) - Seminal Researcher and Teacher in PK/PD
(Exposure-Response) and Pharmacometrics - Learn and Confirm Cycles in Drug Development
(Empiricism versus Mechanistic Approaches,
Frequentists versus Bayesians) - Sheiners Rules
-
24CPSC Meeting, November 3-4, 2004Biomarkers and
Surrogate Markers
- Presentations by
- 1. J. Woodcock, MD, CDER
- 2. J. Wagner, MD, Ph.D., Merck/PhRMA
- 3. T. Blaschke, MD, Ph.D., UCSF (Consultant)
25CPSC Meeting, November 3-4, 2004Biomarkers and
Surrogate Markers
- Dr Woodcocks comments
- Biomarkers (BM) indicate biological/pathological
processe(s) and/or pharmacological response(s) to
therapeutic intervention - Clinical endpoints (CE) measure how patients
feel, function or survive - Surrogate markers (SM) are intended to replace CE
for efficacy and/or toxicity
26CPSC Meeting, November 3-4, 2004Biomarkers and
Surrogate Markers
- Dr Woodcocks comments (continued)
- Rational use of BM can accelerate drug
development and decision making - BM can provide a mechanistic bridge between
mechanistic preclinical studies and empiric
clinical testing - Need business model for (commercial) BM
development in parallel with drug development
27CPSC Meeting, November 3-4, 2004Biomarkers and
Surrogate Markers
- Dr Woodcocks comments (continued)
- Prentice (statistical) criteria for SM are quite
strict - Future CE will not be univariate but rather
composite endpoints - Need responder rather than mean analysis from
pivotal clinical trials, perhaps using BMs - BMs may help individualize/personalize therapy
pre- and post-marketing
28CPSC Meeting, November 3-4, 2004Biomarkers and
Surrogate Markers
- Dr. Blaschkes comments
- Reviewed use of BM/SM in HIV/AIDS drug
development (i.e., CD4 count, HIV viral load) - SM validation required assays, interventional
clinical trials and mechanistic models about
disease progression - Useful BM need to be causal path BMs, i.e.,
mechanistic plausible/proximal to disease
endpoint to provide confirmatory evidence to
support efficacy
29CPSC Meeting, November 3-4, 2004Biomarkers and
Surrogate Markers
- Dr. Wagners comments (on behalf of PhRMA WG)
- Fit-for-Purpose Qualification of BM
- Exploration (BM as research tool)
- Demonstration (probable/emerging BM)
- Characterization (known/established BM)
- Surrogacy (BM substitutes for CE)
30CPSC Meeting, November 3-4, 2004Biomarkers and
Surrogate Markers
- Dr. Wagners comments (continued)
- Lack of uniform nomenclature
- Need for collaboration between Pharma, FDA, NIH
and academia for - decision what BMs to pursue
- decision on what evidence need to accept BM/SM
- Incentives, intellectual property rights, funding