Hylaform P030032 Herbert Lerner, M.D. General and Plastic Surgery Devices Panel November 21, 2003.
-
Upload
nigel-bishop -
Category
Documents
-
view
214 -
download
0
Transcript of Hylaform P030032 Herbert Lerner, M.D. General and Plastic Surgery Devices Panel November 21, 2003.
Hylaform P030032
Herbert Lerner, M.D.
General and Plastic Surgery Devices PanelNovember 21, 2003
REVIEWERS FOR FDA
Herbert Lerner, MD- Lead and Clinical David Krause, PhD- Pre-clinical Phyllis Silverman, MS- Statistics
David Kaplan- Pre-Clinical Peggy Mayo- OC/GMP Linda Godfrey- OC/BIMO Jack McCracken & Mary Lou Pijar-
Labeling
Hylaform Pre-Clinical Review
David Krause, Ph.D.
General and Plastic Surgery Devices PanelNovember 21, 2003
Pre-Clinical Biocompatibility Testing Hylaform has successfully passed
testing for: Irritation:
Intracutaneous Toxicity Subcutaneous Implantation
Sensitization and Immunogenicity Immunization Subchronic Toxicity Guinea Pig Dermal Sensitization Delayed Contact Sensitization
Pre-Clinical Biocompatibility Testing (Cont.)
Cytotoxicity Acute Systemic Toxicity Hemocompatibility Implantation
Muscle Implantation (7-days) Muscle Implantation (30-days)
Pre-Clinical Biocompatibility Testing (Cont.)
Mutagenicity: Ames Mutagenicity Test Test for Induction of HGPRT Gene Mutation Chromosome Aberrations Test for Morphological Cell Transformation
Subchronic Toxicity Subchronic Intraperitoneal Toxicity (2-
weeks) Immunization and Subchronic Toxicity
Pre-Clinical Biocompatibility Testing (Cont.)
Chronic Toxicity and Carcinogenicity: One-year Subcutaneous Toxicity Study
Reproductive Effects Study: Pharmacokinetics:
Intradermal Injection of Radiolabeled Hylan B Distribution of Radiolabeled Hylan B
Pharmacodynamics: Intradermal & Subcutaneous Injection (6-Mo.)
Pre-Clinical Testing Formaldehyde Question:
Hylaform contains less than 2.3 ppm (ug/g) of formaldehyde in a 1 cc injection.
Would multiple injections of Hylaform lead to locally elevated levels of formaldehyde?
Normal tissue levels of formaldehyde are between 3 and 12 ug/g.
Multiple injections over a number of months would not lead to elevated levels of formaldehyde.
Objectives- Clinical
To provide a summary of Genzyme’s Hylaform Clinical Study
To highlight issues pertaining to the safety and effectiveness of the study device
Hylaform Study Purpose
To evaluate the safety and effectiveness of Hylaform viscoelastic gel when used for cosmetic correction of contour deformities of the dermis of the face
Design
Prospective, multi-center, randomized, double-blinded, parallel-group study comparing Hylaform and Zyplast in the nasolabial fold during the initial 12 week treatment, and Hylaform and Hylaform Plus during the extended treatment period.
Design
The sponsor has not included any efficiency data for the extended treatment phase of the study, and only 4 week safety data for possible immunological responses were presented in the PMA. The sponsor does not seek approval for Hylaform Plus at this time.
Inclusion Criteria
Wrinkle Severity Score of 3 or 4 on the six point grading scale
Negative skin test to Collagen Test Implant
Two fixed facial sites, fully visible nasolabial folds, which were both candidates for correction
Exclusion Criteria
Known, prior or present positive skin test to Collagen Test Implant
Received prior therapy (dermabrasion, facelift) during previous six months
Previous tissue augmentation or other wrinkle/fold therapies within the past six months
Treatment Protocol
Initial Phase Screening Collagen skin test x2 Randomization Treatment
Can have “touch-up” at 2 weeks
Treatment Procedures
Initial Phase Both nasolabial folds treated Photographs taken at all treatment
sessions Investigator Wrinkle Assessments “Touch-up” at 2 weeks Follow-up for 12 weeks
Treatment Protocol
Repeat Phase- offered to Hylaform patients only Must have finished initial phase Randomization Treatment
Hylaform or Hylaform Plus
Treatment Procedures
Repeat Phase Hylaform and Hylaform Plus Investigator Assessment Photographs at each follow-up visit Patient global assessment at each
visit
Follow-up Protocol
Initial Phase- after skin testing and randomization Day 0, Day 3, Week 2,4,8, and 12 If “touch-up” start above from date
of procedure
Wrinkle Assessment Scale
A validated 6 point reference scale, with reference photographs, that classifies deep facial wrinkles (nasolabial folds)
Zero represents no lines/folds 5 represents severe lines/folds
Clinical Endpoints
Primary Phase
Evaluate the Efficacy (non-inferiority) of Hylaform for the correction of nasolabial folds as compared to Zyplast®. This was done using serial photograpic documentation and blinded IPR scores at week 12
Evaluate the Safety of Hylaform as compared to Zyplast- determined by rates of adverse events associated with the use of each product
Clinical Endpoints Repeat Phase
Evaluate the safety of repeat treatment with hylan B gel products
In particular, the sponsor added this phase to assess the safety of the device after repeat maintenance doses by determining the presence or absence of an immunologic response by measuring serum hylan B (IgG) antibodies
Evaluate the efficacy (non-inferiority) of Hylaform Plus vs. Hylaform for the correction of nasolabial fold contour defects
Demographics Both groups were comparable with respect
to Age Male: Female Ethnicity Smoking History Sun Exposure Height/Weight
Approx. 80% of the enrolled patients were Caucasian females, with only 3 African-Americans and 16 Hispanics in the Hylaform group.
Patient Accounting- 12 weeks
Hylaform ZyplastPt. Enrolled, Randomized 133 128
Pt. lost to follow-up 10 11
Pt. discontinued due to AE 0 2
Pt. Evaluated 123/133 117/128Actual Follow-up 92.4% 91.4%
Baseline Wrinkle Severity
Investigator’s Live Assessment- Day 0 Hylaform Zyplast
N (nasolabial folds)
266 256
Mean 3.5 3.6
Median 3.5 3.5
SD 0.46 0.46
Min/Max (3, 5) (3, 5)
Baseline Wrinkle Severity Independent Panel Review- Day
0Hylaform
Zyplast
N (nasolabial folds) 256 252
Mean 2.2 2.3
Median 2.0 2.5
SD 1.02 1.04
Min/Max (0, 5) (0, 5)
Endpoint Wrinkle Severity Investigators Live Assessment- Week
12
Hylaform Zyplast
N (nasolabial folds) 260 250
Mean 2.4 2.3
Median 2.5 2.0
SD 0.86 0.93
Min/Max (0, 5) (0, 4)
Endpoint Wrinkle Severity Independent Panel Review- Week 12
Hylaform
Zyplast
N (nasolabial folds) 246 234
Mean 2.3 2.2
Median 2.0 2.0
SD 1.11 1.12
Min/Max (0, 5) (0, 5)
Adverse Events Initial Phase
Adverse Event Hylaform N=133 Zyplast N=128 n % Events n % Events
At least 1 AE 117 88 342 112 88 322Procedure related 111 84 281 109 85 259Not procedure-related 39 29 61 43 34 63Deaths 0 0 0 0 0 0Discontinued-AE’s 0 0 0 2 2 2Serious Adverse Events 1 1 1 0 0 0Severe Adverse Event 3 2 3 7 6 7
Adverse Events Initial Phase- procedure related
Primary System Organ Class/Preffered Term
n (%) Events
n (%) EventsAt least 1 adverse event 111 84 281 109 85 259
General disorders 111 84 274 109 85 258Injection site erythema 84 63 92 86 67 94
Injection site bruising 54 41 59 39 31 39
Injection site swelling 47 35 50 53 41 54
Injection site pain 42 32 44 29 23 32
Injection site pruritus 10 8 12 11 9 11
Hylaform
N = 133
Zyplast
N = 128
Adverse Events Repeat treatment Phase
Adverse Event Hylaform N=96 Hylaform Plus N=96 n % Events n % Events
At least 1 AE 87 91 269 92 96 286Procedure related 87 91 267 92 96 283Not procedure-related 2 2 2 3 3 3Deaths 0 0 0 0 0 0Discontinued-AE’s 0 0 0 0 0 0Serious Adverse Events 1 1 1 1 1 1Severe Adverse Event 0 0 0 1 1 2
Adverse Events Repeat Treatment Phase – Procedure
Related
N (%) E N (%) E
At least 1 adverse event 87 91 269 92 96 286
General disorders 87 91 265 92 96 282
Injection site erythema 72 75 73 70 73 72
Injection site swelling 50 52 50 50 52 50
Injection site pain 49 51 49 54 56 55
Injection site bruising 34 35 34 41 43 41
Injection site nodule 22 23 22 25 26 25
Injection site pruritus 11 12 11 10 10 11
Hylaform Plus Side
N = 96Primary System Organ Class/Preferred Term
Hylaform Side
N = 96
Immunologic Response
Serum IgG levels during Repeat Phase to demonstrate a response to repeat treatments of Hylaform
No immunologic response demonstrated (no patients had a 4-fold increase in IgG levels during repeat treatment)
Duration of Effect
Percent returning to IPR baseline- At 2 weeks- 38.2% (control 21.9%) At 4 weeks- 56.1% (control 26.3%) At 8 weeks- 68.9% (control 46.7%) At 12 weeks- 73.3% (control 65.1%)
Patient Assessment of Treatment Group Assignment
Patient Assessment HylaformN= 133
ZyplastN=128
Hylaform 36 (27.1) 25 (19.5)
Zyplast 18 (13.5) 31 (24.2)
I do not know 76 (57.1) 69 (53.9)
Conclusions Adverse events were similar in
both groups The improvement of wrinkle
severity at 12 weeks was comparable.
Panel Question-1 21 CFR 860.7(d)(1) states that there is a
reasonable assurance that the device is safe when it can be determined that the probable benefits to health from use of the device for its intended uses, when accompanied by adequate instructions for use and warnings against unsafe use, outweigh any probable risks. Considering the data in the PMA, please comment on whether there is a reasonable assurance that the device is safe.
Panel Question-2 21 CFR 860.7(e)(1) states that there is a
reasonable assurance that a device is effective when it can be determined, based on valid scientific evidence, that in a significant portion of the target population, the use of the device for its intended uses and conditions of use, when accompanied by adequate directions for use and warnings against unsafe use, will produce clinically significant results. Considering the data in the PMA, is there reasonable assurance that the device is effective?
Panel Question-3 Only three African-American patients were
enrolled in the Hylaform clinical study. There were 16 Hispanic, 5 Asian and 5 “Others”. If the device is approved, should the sponsor be required to conduct a post-approval study to collect safety data on specific minorities? Is specific labeling needed to address potential use in minorities that may be at a higher risk for adverse clinical outcome, e.g., African Americans?
Panel Question-4 The sponsor proposes the following
indications for use: “Hylaform is intended for the correction of soft tissue contour deficiencies, such as wrinkles and acne scars.” Please discuss the adequacy of these indications based on the fact that only nasolabial folds were treated in the PMA.
Panel Question- 5 As shown by Genzyme, the duration of effect
of this device is short, and multiple maintenance doses will be needed to maintain the desired cosmetic effects. To assess safety of these repeated doses the sponsor has provided serum hylan B IgG levels for the repeat study population. Clinically, no significant changes in adverse events were noted in this group. Does this data support the safety of the device for repeated use, or do you believe that a post-approval study is needed to address this issue?