Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs...

36
Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of Long-acting Beta-agonist Bronchodilators Salmeterol Sally M. Seymour, M.D. Medical Officer Division of Pulmonary and Allergy Drug Products

Transcript of Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs...

Page 1: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Pulmonary-Allergy Drugs Advisory Committee Meeting

July 13, 2005

Safety of Long-acting Beta-agonist Bronchodilators

Salmeterol

Sally M. Seymour, M.D.

Medical Officer

Division of Pulmonary and Allergy Drug Products

Page 2: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

2

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Salmeterol Regulatory History Post-marketing Studies

Serevent Nationwide Surveillance Study (SNS)Salmeterol Multicenter Asthma Research Trial

(SMART) Post-marketing Spontaneous Reports Product Label Summary

Page 3: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

3

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Salmeterol Regulatory History Post-marketing Studies

Serevent Nationwide Surveillance Study (SNS)Salmeterol Multicenter Asthma Research Trial

(SMART) Post-marketing Spontaneous Reports Product Label Summary

Page 4: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

4

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Regulatory History Serevent Inhalation Aerosol

Approved February 1994 for asthma Maintenance treatment of asthma & prevention of

bronchospasm in patients with reversible obstructive airways disease

Discontinued by Sponsor as part of CFC phase out Serevent Diskus

Approved September 1997 Advair Diskus

Fluticasone propionate & salmeterol xinafoate Approved August 2000

Page 5: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

5

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Regulatory History Salmeterol Inhalation Aerosol NDA

Two Phase 3 twelve-week clinical trials (n=556) Improvement in FEV1 Improvement in AM PEFR Improvement in mean % days and mean % nights with

no asthma symptoms Less rescue medication use

SNS results consideredAdvisory committee February 1993Approved February 1994 for asthma

Page 6: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

6

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Regulatory History

Reports of life-threatening respiratory events and fatalities within first 6 months after approval

Label revised January 1995 – new WARNINGS Serious acute respiratory events, including fatalities

have been reported with salmeterol Salmeterol not for acute symptoms Salmeterol not a substitute for inhaled corticosteroids Salmeterol should not be initiated in worsening or

acutely deteriorating asthma Patients should have a short acting beta agonist for

acute symptoms

Page 7: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

7

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Regulatory History

Physician and patient education program Sponsor committed to safety study

Salmeterol Multicenter Asthma Research Trial (SMART)

Safety study in 30K patients with asthma SMART initiated July 1996

Amended June 1999 to increase population from 30K to 60K

Page 8: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

8

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Regulatory History SMART

Planned Interim analysis in 2002 26K enrolled

DSMB analysis Point estimates suggested excess risk with salmeterol

in total population African Americans may be at particular risk

DSMB recommendations Optimal to continue study if timely recruitment feasible If timely recruitment not feasible, terminate study and

disseminate findings within 3-6 months

Page 9: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

9

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Regulatory History Sponsor terminated SMART in January 2003 Dear Healthcare Professional Letter January 2003 Label revised August 2003 based upon preliminary

SMART data Boxed Warning Information regarding SMART in Clinical Trials Section

Full SMART data submitted August 2003 NDI search performed and adjudication pending

SMART study report submitted February 2004 Included adjudicated NDI data

Label revised September 2004

Page 10: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

10

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Salmeterol Regulatory History Post-marketing Studies

Serevent Nationwide Surveillance Study (SNS)

Salmeterol Multicenter Asthma Research Trial (SMART)

Post-marketing Spontaneous Reports Product Label Summary

Page 11: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

11

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Serevent Nationwide Surveillance Study (SNS)

Randomized, double-blind, active-controlled (salbutamol), parallel group, 16-week trial in UK

N=25,180 (2:1 randomization) Salmeterol 50mcg BID vs. salbutamol 200mcg

QID Clinic visits after 4, 8, and 16 weeks Outcome measures

Serious adverse events Reasons for withdrawals

BMJ 1993; 306:1034-7

Page 12: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

12

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Serevent Nationwide Surveillance Study (SNS) - Results

BMJ 1993; 306:1034-7

Page 13: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

13

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Salmeterol Regulatory History Post-marketing Studies

Serevent Nationwide Surveillance Study (SNS)

Salmeterol Multicenter Asthma Research Trial (SMART)

Post-marketing Spontaneous Reports Product Label Summary

Page 14: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

14

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Salmeterol Multicenter Asthma Research Trial(SMART) Protocol

Multi-center, randomized, double-blind, placebo-controlled, parallel group study

Treatment period: 28 weeks Sample Size: 30,000 (increased to 60,000 in 1999)

Age 12 yrs Clinical diagnosis of asthma Currently taking asthma medications, but no LABA

Treatment groups: Salmeterol MDI 50mcg BID Placebo BID

One clinic visit then phone calls Q 4wks

Page 15: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

15

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART Protocol Primary Endpoint: Combined respiratory-related

deaths and respiratory-related life-threatening experiences (intubation & mechanical ventilation)

Key Secondary Endpoints: Asthma-related death Asthma-related deaths and life-threatening experiences All-cause SAEs All-cause death

Page 16: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

16

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART Protocol Non-inferiority design - not designed to show

a difference between salmeterol and placebo Powered to rule out

40% increase in combined respiratory related deaths and life threatening experiences

3 times increase in asthma related deaths Planned interim analysis after ~half of

subjects enrolledStopping Criteria

RR of 1.4 for primary endpoint, alpha = .01 RR of 3 for asthma related deaths, alpha =.01

Page 17: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

17

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART – Interim Analysis

Interim analysis performed after 26K enrolled in 2002

DSMB reviewed data Potential treatment group difference African Americans may be at particular risk

DSMB recommended Continue study if recruitment feasible Terminate study if recruitment not feasible and

disseminate findings within 3-6 months SMART terminated January 2003

Page 18: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

18

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART Results Results from early termination of study

Did not meet pre-specified stopping criteriaDid not meet non-inferiority objectiveSuggested a difference in some endpoints

Based upon 28 week treatment period Inclusion of NDI search data Life table analyses

Page 19: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

19

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART Results - Disposition

Page 20: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

20

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART Results - Demographics

Page 21: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

21

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART Results – Primary EP

*Intubation and mechanical ventilation

Page 22: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

22

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART Results – Key Secondary EP

Page 23: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

23

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART Results Inhaled Corticosteroid (ICS) Use

ICS analyses all post hoc ICS use recorded at baseline ICS not randomly assigned 47% total population used ICS

50% Caucasians used ICS38% African Americans used ICS

Page 24: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

24

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART Results - ICS Use

Page 25: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

25

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART Results - ICS Use

Page 26: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

26

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART - Conclusions SMART stopped early

Interim analysis and difficulty with recruitment Total population

RR 1.4 for primary outcome events -respiratory related deaths or life threatening experiences

CI did not exclude oneRR 4.37 for asthma related deaths

CI excludes oneRR 2.16 for respiratory related deaths

CI excludes one

Page 27: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

27

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

SMART - Conclusions Caucasian Subpopulation

No treatment group difference for primary endpoint Numeric increase in asthma related deaths and

respiratory related deaths in salmeterol group African American Subpopulation

Numeric increase in salmeterol group for primary endpoint events

Numeric increase in salmeterol group for Asthma related deaths Respiratory related deaths Combined asthma related deaths or life threatening

experiences (CI excludes 1)

No definitive conclusions regarding ICS use

Page 28: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

28

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Salmeterol Regulatory History Post-marketing Studies

Serevent Nationwide Surveillance Study (SNS)Salmeterol Multicenter Asthma Research Trial

(SMART) Post-marketing Spontaneous Reports Product Label Summary

Page 29: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

29

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Post-Marketing Reports

Adverse Events Reporting SystemMay 1994-February 2005

Reviewed by Office of Drug Safety 201 deaths reported in US with salmeterol

91 asthma-related deaths 10 possible asthma-related deaths

Difficult to draw conclusions

Page 30: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

30

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Salmeterol Regulatory History Post-marketing Studies

Serevent Nationwide Surveillance Study (SNS)Salmeterol Multicenter Asthma Research Trial

(SMART) Post-marketing Spontaneous Reports Product Label Summary

Page 31: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

31

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Current Label

Clinical Trials: SMART Results for primary and key secondary endpoints

Page 32: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

32

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Salmeterol Regulatory History Post-marketing Studies

Serevent Nationwide Surveillance Study (SNS)Salmeterol Multicenter Asthma Research Trial

(SMART) Post-marketing Spontaneous Reports Product Label Summary

Page 33: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

33

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Summary Regulatory History SNS

Numerical increase in respiratory/asthma deaths in salmeterol group

Fewer withdrawals due to respiratory or asthma events

SMART Total population

Increase in asthma and respiratory related deaths African American Subpopulation

Increase primary events Increase combined asthma related deaths or life threatening

experiences Not designed to assess the effects ICS use on

outcomes Product label

Page 34: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

34

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Questions for Committee

1. The product labels of salmeterol containing products have been modified to include warnings related to the SMART study.

a. Based on currently available information, what further actions, if any, do you recommend that the Agency take to communicate or otherwise manage the risks of severe asthma exacerbations seen in the SMART study?

b. Based on the currently available information, do you agree that salmeterol should continue to be marketed in the United States?

Page 35: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

35

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Questions for Committee

3. What further investigation, if any, do you recommend to be performed by GSK that can improve the understanding of the nature and magnitude of the risk of salmeterol?

Page 36: Food and Drug Administration Division of Pulmonary and Allergy Drug Products Pulmonary-Allergy Drugs Advisory Committee Meeting July 13, 2005 Safety of.

July 13, 2005

PADAC Meeting

36

Food and Drug Administration

Division of Pulmonary and Allergy Drug Products

Division of Pulmonary and Allergy Drug Products

Parklawn Building, Room 10B-45

5600 Fishers Lane, HFD-570

Rockville, MD 20857

Phone: 301-827-1050

Fax: 301-827-1271