Sunday, May 13, 2007

FDA failure to approve Provenge indicative of agency paralysis?

On March 29, an FDA advisory committee overwhelmingly determined that Provenge, Dendreon's immunotherapy directed against prostate cells following prostatectomy in advanced metastatic prostate cancer, is safe and has shown substantial evidence of efficacy, the two criteria Congress authorized the FDA to consider in approving drugs. It was therefore a surprise when the FDA announced on May 9 that it would require further proof of efficacy before approval, which may require waiting for clinical trial results that are 3 years away.

This is the first time in memory that the FDA has ever gone against a committee recommendation to approve a drug for a terminal condition. But most importantly, by forcing a delay of 3 more years to confirm something that already has a 99% chance of certainty, this decision will condemn tens of thousands of men to die earlier and unnecessary deaths. If it still insisted on further proof of efficacy, the FDA had the authority to allow marketing immediately with a postmarking commitment to complete the ongoing trial and revoke authorization if necessary, but the FDA did not pursue this possibility. This delay is therefore neither justified nor necessary.

To make the situation even more difficult to understand, there are plenty of cancer drugs in our armatarium that have never demonstrated a survival benefit, or even been tested in randomized controlled trials, prior to approval. Congress could not have possibly meant in establishing guidelines for the FDA that a drug that triples survival after 3 years, that has shown evidence of efficacy in 4 other trials, that has no side effects, and that is superior in all ways to existing drugs, should not be approved!

This (tragic, in my opinion) decision by the FDA may stem from problems in its organization or leadership. The FDA Commissioner, Dr. Andrew Von Eschenbach, said the FDA would be a bridge rather than a barrier to new therapies, and would attempt to get cancer drugs to patients as quickly as possible. In light of the decision to delay Provenge, Dr. Von Eschenback’s statements lack credibility. In addition, two doctors who had been on the advisory committee, despite having financial interests in companies developing more toxic competing therapies, waged an unusual campaign of disinformation against Provenge approval. That a few people can go outside of their predesignated roles at the FDA, hijack the Provenge approval process, and harm thousands of seriously ill patients would be a true travesty.

FDA fails to think, applies wrong lessons to Provenge

Found this excellent comment at http://www1.investorvillage.com/smbd.asp?mb=971&pt=msg&mid=2125129

The FDA willingly, openly exposed themselves with this decision by employing a less than logical risk/reward model for terminally ill patients. When safety is a near given, the risk becomes almost non-existent. Hence, the reward becomes more practical in terms of application. And in this case for an even better reason - the therapy works and the patients are afflicted with late-stage disease.

The end-point criteria that has been at the crux of the argument would make much more sense for otc products, or safety insufficient therapies, etc. - Marginalizing the condition of advanced prostate cancer, by minimizing the condition with this given peer set, is where the disconnect of logic by the FDA exposes itself and shouts to the rooftops - "we aren't about what we say, we are about what we do, and that is providing chemo agents to this patient class, and chemo agents only." Remember what the response from Hussein was in regard to the patient advocate who asked for a novel alternative for pc patients? "You can have Taxotere."

Let's reverse the scenario of applying the same standards to chemotherapy as are exhibited by Provenge. That association, of course, would really undermine the objective of the chemo-cartel. First of all we know chemo is not "Safe." Secondly the end-point they are so in love with has a major downside as well. Poisoning the patient guarantees that a given tumor will also be forced to deal with poison. Yes, you are almost awarded an automatic outcome of delay in disease progression with the poison, but at the same time you unfortunately have compromised the patient's system/body in other serious regards. Where are the risk/reward leveraged from in that analysis of feasibility?

The cartel has rendered any therapy believed to be "Safe" as also ineffective, simply because the existing standard dictates you must inflict damage to the overall patient to have success with the disease. Any other concept will be regarded as substandard if the given therapy does not retain this denominator, thus no other approach is ever going to provide a parallel outcome, and there is no flexibility / means to incorporate deviation.

The outcome for chemotherapy is championed because a simple observation says "see the tumor is smaller. We know the patient is less healthy, but so is the tumor." We can understand that as an application, but suggesting not poisoning the patient doesn't make sense (with their logic). If the patient can't be poisoned then how can the mechanism be effective on tumor growth?" This is the small circle the cartel stayed well within until they were recently forced to expose their agenda for basic economical survival.

This approach, although a simple and convenient mindset, has allowed the cartel to avoid / forgo the concept that attacking the disease could actually originate in a different form, with a different mechanism and outcome AND methodology for assessing progress, for either patient or disease. The phenomenon of a different class of agent so close to threatening their ideals is what has forced the chemo-cartel into exposing themselves as they have the past month. They deployed their last line of defense even at the risk of exposing their protectionist agenda. I believe they felt that threatened by Provenge and subsequent related therapy. Their offering was simply... Immunotherapy does not work simply because those agents do not work like chemotherapeutic agents.

Saturday, May 5, 2007

Big Pharma vs. personalized medicine: Big is not necessarily better

I was at a local biotech conference today and there was a panel discussion on personalized medicine. The speakers, biotech execs and doctors, noted that while there was much interest and even current business from doctors, there has been very little interest in partnerships or acquisitions from Big Pharma. One of the speakers noted that Lipitor has some of the best evidence for clinical efficacy of drugs widely used in medicine, and yet its benefit of reducing risk of cardiovascular events from 3% to 2% still meant that 97% of patients experienced no actual benefit. Personalized medicine in its various forms aims to be more efficient than that. And surprise surprise, big pharma is not interested.

That got me thinking about trial sizes. I think in recent years there has been some expectation inflation, or expectation confusion, when it comes to trial sizes. We have gotten used to trial sizes of 1000-10000 patients run by big pharma companies testing drugs like Lipitor that are meant to be given to lots of people to provide benefits in low-frequency outcomes. When the effect is real, the p value can be very small. When there are few or no side effects in this large population, then everybody is happy, including the biostatisticians, and the drug gets approved. However, a large trial is not an inherent good in and of itself. In fact large trials should be seen as necessary evils, if they end up taking up more time and money than a smaller one. If you were throwing a Japanese-themed dinner party, for example, would you spend the time and money to make twice the amount of sushi you think you need to be 95% sure nobody is left out, or would you make 10 times the amount, just in case the Japanese national sumo team happens to show up?

Much has been made of the fact that trials for Provenge and other immunotherapies have been small. However, not one of the critics who have raised this issue in public (e.g. oncologist Howard Scher and biostatistician Thomas Fleming), seem to have thought about if the benefit of more trials outweigh their harms. They seem to be misapplying anachronistic guidelines suitable for non-customized drugs with small therapeutic windows, e.g. chemotherapy, to a different new situation of personalized medicine. But large trials and biostatistical purity are not requirements for FDA approval. Demonstration of substantial evidence of efficacy is the requirement, and there are no written rules about how that is defined. Lately, large trials have been accepted as useful tools for most small molecule chemicals to arrive at that demonstration. However, if the indication is urgent and your drug is so good that you can see effects in a smaller number of patients, then that satisfies all the clinical and regulatory requirements for approval. That happened with rituximab, which was approved in 1997 on the basis of a 166-patient noncontrolled unblinded Phase II trial. It is happening now with Provenge, where the 3-year survival rate is tripled over placebo. Now larger trials may have gotten smaller p-values, and that's nice, but one has to ask if the intellectual satisfaction of being 99.9% certain vs. being 99% certain is worth delaying drug availability and putting more patients on placebos, which are real and irreversible harms inflicted to patients. Also, one can make the case that continued testing may reveal unexpected side effects, and this is a valid point for non-life-threatening conditions, but again you could take this argument to infinite extremes, and it's perhaps unnecessary to ask for multi-year safety data in a disease with a 1-year life expectancy.

Wednesday, April 18, 2007

Getting a grasp on GVAX

A study of immune responses from patients in a Phase II study of GVAX for prostate cancer by Cell Genesys was presented at AACR yesterday (abstract 4139). The analytical methodology used was quite nice: an expression library of cDNAs from the two allogeneic (meaning coming from other people) prostate cancer cells used as immunizing agents was constructed, and screened for immunoreactivity with sera from patients receiving immunotherapy, and counterscreened with pretreatment sera. The researchers eventually settled on 20 proteins that were frequently targetted in the immune responses to profile immune responses, and found patients receiving GVAX raised antibodies to different subsets of these proteins. Proteins included HLA-A24, filamin B, and NSFL1C.

The companies interpretation in a press release from yesterday, annotated with what I think are remaining important questions:
"Evaluation of antibody responses in patients with advanced prostate cancer from these studies shows that the GVAX cell-based immunotherapy induces antibody responses to a broad array of prostate cancer- associated antigens, including some not previously known to be associated with prostate cancer [1]. In addition, the antibody responses to this non patient- specific product were predominantly patient-specific and unique from patient to patient, indicating the potential advantage of a cell-based multi-antigen product such as GVAX to generate the broadest and most relevant immune response [2]. Serological analysis of gene expression (SEREX) technology was also used to identify target antigens involved in response to the immunotherapy. More than 148 proteins to which antibody responses were induced were identified and many of these proteins had not been identified previously as prostate cancer-associated antigens [1]. These findings were presented today by Dr. Thomas Harding and colleagues from Cell Genesys at the annual meeting of the American Association for Clinical Research being held in Los Angeles, CA."

[1] As far as I can tell, it is still not known if the newly identified antigens are specifically associated with prostate cancer. Certainly HLA-A24, filamin B, and NSFL1C are broadly expressed, based on cDNA sources (www.ncbi.nlm.nih.gov/UniGene/clust.cgi?ORG=Hs&CID=181244, www.ncbi.nlm.nih.gov/UniGene/clust.cgi?ORG=Hs&CID=476448, www.ncbi.nlm.nih.gov/UniGene/clust.cgi?ORG=Hs&CID=12865). So how specific are these or other newly identified antigens for prostate cells or cancerous cells?
[2] It should be noted that at the moment the authors can only hypothesize that the multitargetted immune response is the "most relevant" or that it is the "broadest". (And I assume they mean broadest relevant, as opposed to the theoretical broadest, which would be every antigen in the immunogen, which is decidedly not desirable, so "broadest and most relevant immune response" is a bit of sloppy language. "The broadest relevant immune response" would be better.) How can the authors test the relevance of each component of the immune response to clinical benefit, and prove that the different mixtures of responses seen in different patients are on the whole better than consistent responses across all patients to a small set of targets?

Hopefully some answers will be forthcoming (especially to question 1, which should be straightforward), in either upcoming publications or future research. That said, it's not necessary to know the answers for patients to benefit and the drug to be a great thing. Indeed, GVAX patients are living longer than historical controls, with no severe autoimmune cases reported so far. The worst case scenario is that this has happened by chance or by an artifact of the patient selection process or open label treatment protocol in the past Phase II trials and that autoimmunity crops up later. The best case is that the effect is real, and the body's immune response somehow is able to target a set of antigens that mediates anti-tumor activity without overt autoimmune sequalae. Natural systems have a way of surprising us with their robustness and adaptability.

Two Phase III trials, one comparing GVAX to docetaxel and prednisone, and the other comparing GVAX plus docetaxel and prednisone to docetaxel and prednisone alone, are ongoing. These trials are randomized, but not blinded or placebo controlled. That already introduces the possibility of bias as everybody roots for the new drug to work and may subconsciously pay a little more attention to what they can do to help the experimental subjects along. Hopefully there will be a benefit in survival, and it will be large enough to be convincing.

Very nice discussion here: www.extendmed.com/capvaccine/p7info.html

Tuesday, April 17, 2007

The immune system - master snooper

Vaccines are not limited to recognizing antigens on the surface of cells. In all cells, intracellular proteins are processed into peptides and translocated to the surface in Class I MHC molecules which are then recognized by antigen-specific receptors on T cells. If provided with the right stimulation at the same time that they are recognizing an antigen in the Class I MHC complex, these cells can go on to become cytotoxic T lymphocytes (CTLs) that go around killing cells expressing the antigen. In this way the immune system is always checking up on the identity of your body's cells and taking lethal action when appropriate. Creepy, isn't it?

This becomes important for efforts to develop vaccines to intracellular proteins such as p53. A study at AACR The particular study by Chikamatsu et al. claims that the presentation of wild-type (nonmutated) p53 peptides is enhanced in some tumors, providing a rationale for making vaccines against wild-type p53. The authors found several peptides from p53 that could elicit CTL activation in vitro when presented by dendritic cells, and these CTLs showed cytolytic activity toward squamous cell carcinoma of the head and neck cells in vitro. It remains to be seen how well this would work in the in vivo background of lots of cells expressing p53. Previous studies had proposed generating immune responses to particular mutant sequences of p53 commonly occurring in cancers.

Cancer vaccines - Different approaches

It has been asked what the risk of creating autoimmune disorders would be from a cancer vaccine. Good question and its certainly a theoretical concern if you are training the immune system to target antigens that are also expressed on normal cells. It's unlikely to be a concern with Provenge, because prostate cells are the only ones expressing PAP, and the patient would have had the prostate already removed. It's more a concern with approaches such as Cell Genesys' GVAX or Antigenics' Oncophage which use cell lysates, i.e. mixtures of all antigens in the cell, most of which will be universal, rather than just one.

That said, it may be possible to create an immune response against a widely expressed antigen and still have it result in a therapeutic index > 1 if the antigen is more highly expressed in cancerous tissue and if the immune response is not too strong. This is what already seems to be occuring in passive immunotherapy, e.g. administration of anti-HER2 antibodies for breast cancer aka Herceptin aka Genentech's hot-selling drug. HER2 is by no means confined to breast cancer cells; its just more highly expressed in them. Given these complexities, I think it's safer to use the single antigen approach like Dendreon is doing because it allows testing of the therapeutic ratio of immune responses to a single trigger, rather than the throw everything at the wall and see what sticks approach of Cell Genesys or Antigenics. The latter could still work, but it is less predictable, I think.

Where else could a single-antigen approach work? Spontaneous immune-mediated remissions has often been seen with melanomas, which seem to be naturally antigenic, likely because melanocytes express several antigens that are not found in any other tissue and because the skin is full of dendritic cells that are ready to sound the alarm to the immune system if they smell something fishy. Anybody who has undergone allergy testing or has allergic dermatitis or eczema can attest to this. The fact that one can live without melanocytes makes melanoma like prostate cancer a good target for immunotherapy, and in fact there are many cancer vaccines under development for melanoma.

AACR in the news

Cancer vaccines are getting some news from the ongoing AACR meeting in Los Angeles. Most of the news in the media is about the HPV vaccine to prevent cervical cancer. However, the cervical cancer vaccines are really only vaccines against the virus that causes cervical cancer, and so are more like other microbio vaccines, e.g. flu vaccines. To call them cancer vaccines is a bit of a misnomer, and also trivializes the much more difficult issue of making true cancer vaccines, i.e. vaccines that can effectively discriminate cancerous from noncancerous cells and can overcome self tolerance.

The most interesting developments in cancer vaccines are in Dendreon's Provenge for prostate cancer. This is a vaccine against prostatic acid phosphatase, and is basically designed for the immune system to mop up any residual prostate cells after prostatectomy. Provenge is awaiting final clearance from the FDA for marketing in advanced prostate cancer (hormone-refractory prostate cancer, HRPC); it got a very favorable advisory panel review in late March. Provenge is the most important cancer vaccine to discuss because it is the first to show efficacy in Phase III trials, will most likely be the first to be approved, and also is designed to target the most common cancer in men.

The way Provenge works is of general geeky interest and explains its relative effectiveness sans side effects versus other vaccine approaches. First, a patient's blood is drawn and the dendritic cells (the primary antigen-presenting cells of the immune system) are purified. These are then stimulated by a fusion protein of GM-CSF (a potent dendritic cell activator) and a prostatic acid phosphatase peptide. The cells are then reinfused back into the patient, where they will present the PAP epitope and costimulatory molecules to lymphocytes, inducing a specific immune response to PAP and overcoming the previously established tolerance to self antigens.

Provenge (aka Sipuleucel-T) is also being presented at AACR, with data showing the immune response to PAP can be boosted by repeated treatments in earlier stage prostate cancer (hormone-dependent prostate cancer, or HRPC). About 1 in 6 men will get some form of prostate cancer if they live to age 80. If it weren't for smoking, prostate cancer would be the number one cause of cancer deaths among men. (A similar situation exists for breast cancer in women.)