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Position Paper on NDA 21-356 for Gilead
Sciences' Viread™ brand Tenofovir disoproxil fumarate by Yvette Delph,
M.D. for the Treatment Action Group 3 October
2001 |
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- INTRODUCTION
In May 2001, Gilead
Sciences submitted New Drug Application (NDA) 21-356 to the FDA
for its VireadTM brand of tenofovir disoproxil fumarate (TDF).
Gilead is seeking accelerated approval for TDF to be indicated, in
combination with other antiretroviral agents, for the treatment of
HIV infected adults. TDF is a nucleotide reverse transcriptase
inhibitor.
- OVERVIEW OF ISSUES
In Gilead
studies 902 and 907, when TDF was added to the failing
antiretroviral regimens of individuals who had had about 5 year's
experience with anti-retroviral agents, it produced a mean decline
in viral load of 0.6 log10
copies/ml. The sponsor, Gilead, is to be highly commended for
conducting pivotal registrational trials of TDF in such highly
treatment experienced individuals. TDF has a highly favorable
resistance profile, both in vitro and in vivo and
has demonstrated its efficacy against multi nucleoside-resistant
HIV. Subjects with lamivudine (3TC)-, zidovudine (AZT)-, NNRTI- or
PI resistance experienced mean declines in viral load of between
0.52 and 0.65 log10 copies/ml. The
only resistance mutation that TDF seems to select for is K65R
mutation in reverse transcriptase (RT), which results in 3 to
4-fold decline in sensitivity to TDF. However, the emergence of
this mutation does not seem to be associated with virologic
rebound. Information correlating IC50 with plasma levels of TFV is not
available
- Administered as one tablet once per day, TDF makes a
substantial contribution to the simplification of antiretroviral
regimens. Since TFV inhibits HIV-1 reverse transcriptase at
concentrations approximately 3000-fold lower than that needed to
inhibit DNA polymerases beta and gamma, it has very low potential
for mitochondrial toxicity and, to date, there has been no
evidence of mitochondrial toxicity due to TDF.
- TDF has a favorable side effect profile and in both Studies
902 and 907, the occurrence of clinical adverse events and
laboratory abnormalities in the TDF 300 mg daily arm was similar
to that in the placebo arm. The only adverse event that occurred
in >5% of the study population was depression, which occurred
after 48 weeks of Study 902 in 6% of subjects in the TDF 300 mg
daily arm. This compared with 0% in the first 24 weeks in the
placebo arm. In Study 907, during the first 24 weeks, no adverse
event occurred in >2% of the population in either arm.
- There is no hepatic metabolism of TFV and it is excreted
unchanged by the kidneys. Thus, there is potential for interaction
with other drugs that are renally excreted and there is likely to
be a need for dosage adjustment in individuals with renal
impairment. TFV is not a substrate, inhibitor or inducer of the
cytochrome P450 family of liver enzymes. It therefore has a low
potential for drug-drug interactions involving this family of
liver enzymes.
- TDF has been studied in very few persons with viral loads
>50,000 copies/ml. Therefore, there are not enough data
to assess the efficacy of TDF in this population. Because of
earlier concerns about possible bone toxicity, TDF has not been
studied in children.
- SUMMARY OF TAG POSITION
TAG is
in favor of accelerated approval of TDF for use, in combination
with other antiretrovirals, in the treatment of adults with HIV
infection.
- The FDA should require the sponsor to complete the following
studies in the post-marketing period:
- A safety and efficacy study in individuals with viral loads
>50, 000 copies/ml
- A safety and efficacy study in treatment-naive individuals —
such a study (903) was fully enrolled in January 2001
- Safety, efficacy and pharmacokinetic studies in children
- Safety and pharmacokinetic studies in individuals with renal
or hepatic impairment
- Studies to identify long-term toxicities of TDF
- Drug-drug interaction studies with drugs that inhibit renal
tubular secretion such as trimethoprim (or cotrimoxazole) and
probenecid; drugs that are excreted by the kidneys and are
likely to be used concomitantly by some HIV-infected
individuals, such as stavudine (d4T), certain antibiotics
(including aminoglycosides, cephalosporins, and penicillins)
narcotic analgesics (such as demerol and morphine) lithium and
digoxin; and the studies which the sponsor has indicated that it
plans to conduct with ddI EC, methadone, oral contraceptives and
adefovir
- Correlation of the IC50 or
IC90 with plasma levels of TFV
There are several additional issues that TAG wishes to
raise:
- Gilead is the first sponsor to respond to the calls from the
community to study investigational agents in highly
treatment-experienced individuals and should be congratulated,
not penalized, for this.
- TAG is concerned that a 48-week dose-finding study was
conducted in individuals, virtually all of whom had HIV
resistant to at least one class to antiretroviral agents and
many who had resistance to more than one class. The FDA should
require sponsors to determine the appropriate adult dose for
antiretroviral agents before proceeding to large Phase III
studies — especially in individuals with limited treatment
options.
- There is not yet enough evidence that TDF should be used
only with nucleoside RT inhibitors. Until there is more
evidence, TDF should be used in conjunction with at least one
protease inhibitor or a non-nucleoside reverse transcriptase
inhibitor and at least one NRTI.
- Some have questioned whether broad approval for TDF should
be granted when the data submitted to date focus on experienced
individuals. Here are several reasons TAG would urge the FDA to
grant accelerated approval for use of TDF, in combination with
other antiretrovirals, in the treatment of adults with HIV
infection.
- Precedent. Since the 1995
approvals of 3TC and saquinavir (SQV), the FDA has used this
language for approving new antiretroviral agents even though
pivotal studies were not done in certain important
HIV-infected populations. Although some thought these broad
indications would let industry off the hook for post-marketing
studies, both Glaxo and Roche continued developing 3TC and
SQV, respectively (unlike what Roche had done with ddC after
1992). With the advent of HAART these indications proved
useful.
- Timing. Gilead did not have
24-week pivotal data on naive patients in May 2001 when it
submitted the NDA. However, its pivotal study in
treatment-naive individuals fully accrued in January and so 24
week data is likely to be available within few months. Gilead
could not, therefore, avoid doing the necessary study in naive
individuals.
- Logic suggests that if the drug
reduces HIV RNA by ˜0.6 log10
in treatment-experienced individuals it will reduce RNA by
even more in naive individuals.
- Safety data are available in
both populations in real time; to date there has been no
serious safety problem in either population. In fact, TDF has
a very favorable safety profile in the treatment-experienced —
the population for which safety data have been analyzed.
- Weight of Evidence.
Cumulatively, the drug has good potency, a favorable
resistance and safety profile, is easy to take and generally
well tolerated.
- Consistency. For years, the
community has been asking industry to study new drugs in
experienced patients AS WELL AS in naive patients. Unlike
Abbott, a giant pharmaceutical company with lots of resources,
which could therefore submit a NDA for lopinavir/ritonavir
containing pivotal data on naive and experienced patients,
Gilead is a relatively small company with fewer resources. We
might wish Gilead had studied both populations in parallel,
but they had just had a setback with adefovir and had been
required to get 48-week safety data in TDF for renal and bone
toxicity. We should not penalize them for going sequentially.
- OVERVIEW OF THE DATA
- Safety
- The two pivotal studies of the safety and efficacy of TDF,
Studies 902 and 907, were conducted in individuals with 4.6 and
5.4 years, respectively, of prior antiretroviral therapy. Study
902 enrolled 189 HIV-infected subjects with viral loads of
400-100,000 copies/ml on stable antiretroviral therapy
consisting of <4 drugs for >8 weeks. They
were randomized 2:2:2:1 to receive one of three daily doses of
TDF(75mg, 150 mg or 300 mg) or placebo in addition to their
existing antiretroviral treatment regimen for 48 weeks. At week
24, all subjects receiving placebo were switched the TDF 300mg
daily arm. After the end of the 48-week blinded study, 135
subjects rolled over into an open label extension phase and
received 300 mg of TDF daily.
- Study 907 enrolled 552 subjects with viral loads of
400-10,000 copies/mL on stable antiretroviral therapy for at
least eight weeks prior to entering the study. Subjects were
randomized (2:1) to receive TDF 300mg once daily, or placebo, in
addition to their existing antiretroviral therapy. After 24
weeks, all subjects had the option of receiving TDF for the
remainder of the 48-week study period; 170 subjects who received
placebo rolled over to receive treatment with TDF.
- For the first 24 weeks of Study 907, rates of drug
discontinuation, of serious adverse events (SAEs), and of Grade
3 or 4 laboratory abnormalities in the 368 subjects who received
TDF 300 mg daily were all comparable to those for placebo. Two
SAEs in Study 902 were considered by the investigator to be
possibly related to TDF: liver failure in one subject in the TDF
75 mg group and acute pancreatitis in a subject in the TDF 300
mg group. During this study, there was also one suicide, which
was judged by the investigator not to be related to TDF. As of
September 28, 2001, over 4 900 patients worldwide have enrolled
in the TDF Expanded Access Program (EAP) which opened to accrual
in March 2001. Globally, SAEs have been reported in 122 (2%)
patients and all individual events were reported in < 1%
patients.
- Since osteomalacia (softening of the bones due to
demineralization) was observed in rats and dogs dosed at doses
equivalent to 6- to 10-fold greater than human exposure and in
juvenile monkeys at 12 to 50-fold greater than human exposure,
close monitoring for bone toxicity in humans was done in Studies
902 and 907. There was no evidence of bone abnormalities. All
fractures seen were due to high impact trauma and the rate of
fractures for TDF 300mg daily was 1.9 per 100 patient-years
compared with 3.0 per 100 patient-years for placebo.
- Because of the nephrotoxicity of adefovir, another
nucleotide RTI, and because there was evidence of nephrotoxicity
in newborn and juvenile monkeys dosed with TFV equivalent to 12-
to 50-fold greater than human therapeutic doses, individuals
with renal impairment were excluded from Studies 902 and 907. In
addition, subjects were closely monitored for evidence of renal
toxicity. No nephrotoxicity was seen and changes in serum
creatinine and phosphate were similar to those seen in the
placebo arm.
- Efficacy
The primary efficacy
endpoint for both studies was DAVG24, a measurement of the average
change in viral load between 0 and 24 weeks.
DAVG24 by intent-to-treat (ITT)
analysis among the 54 subjects treated with TDF 300 mg in Study
902 was -0.58 log10 copies/ml while for placebo it was +0.02 log10
(p<0.001). For Study 907, it was -0.59 log10 copies/ml for the
TDF arm and -0.01 log10 in the placebo group (p<0.0001). In
Study 907, 45% (155/346) of subjects treated with TDF achieved
viral load reductions to <400 copies/ml at 24 weeks, compared
with 13% (23/172) in the placebo group (p<0.0001). Reduction in
viral load to <50 copies/ml was achieved by 22% (76/346) of
subjects in the TDF group compared to 1% (2/172) in the placebo
group (p<0.0001). DAVG24 for
both non-Caucasians (35% study population) and women (15%) was
-0.6 log10 by ITT analysis of 907.
DAVG48 for subjects who received
TDF 300 mg in Study 902 was -0.62 log10 copies/ml.
TDF has demonstrated good efficacy against drug resistant HIV.
Subjects in Study 902 with virus resistant to AZT, NNRTIs, or PIs
experienced DAVG24 of -0.52 to
-0.61 log10 copies/ml. Individuals
with HIV exhibiting >10-fold change in susceptibility to AZT
had DAVG of -0.58 log10 copies/ml.
DAVG24 was -0.65 and -0.48
log10 cells/ml, respectively, for
subjects in 907 with and without the M184V mutation on TDF 300 mg
and -0.20 and +0.28 log10,
respectively, for those on placebo.
In the TDF arm of Study 907, the DAVG24 for CD4 cells was an
increase of 12.6 cells/ml compared with a decrease of 10.6
cells/ml in the placebo arm (p=0.0008).
- Pharmacokinetics and Drug-Drug
Interactions
TFV is only about 6% bioavailable when
administered orally. It is therefore administered as TDF which is
rapidly converted to TFV by esterases in the intestinal lumen and
plasma. TDF is 20-40% orally bioavailable. Food enhances the
absorption of TDF and oral bioavailability with a high fat meal is
40%. The time to maximum serum concentration (Tmax) in the fasted
state is 1 hour. After a high fat meal (50% calories from fat),
the Tmax is 2 hours and the area under the curve (AUC) is
increased by 40%. Gilead recommends that TDF be taken with food.
Following single oral doses of TDF 300 mg with food in
HIV-infected subjects, mean peak TFV plasma levels were 362 ng/mL,
respectively. After dosing fasted subjects with TDF 300mg once
daily until steady state, the Cmax was 350-380ng/ml, the Cmin was
50-70 ng/ml and the AUC0-24 was 2 500-3 000 ng.h/ml. When dosed
with food, the Cmax was 300ng/ml and the AUC was 3300 ng.hr/ml.
The volume of distribution was 600-800 ml/kg. and the serum
half-life (T½) 12-18 hours. The intracellular (IC)
T½ of PMPApp was 15-50 hours in resting cells and 10
hours in dividing cells. The PK in uninfected volunteers is
similar to that in HIV-infected subjects.
Drug interactions between TFV and agents from all three
licensed classes of antiretrovirals have been conducted. Among the
NRTIs, interactions with 3TC and ddI, which are both excreted
primarily by the kidneys, were studied. The NNRTI, EFV, and the
PIs, IDV and LPV/rtv, were also studied. All studies were
randomized, multiple-dose, open-label, 3-way cross over Phase I
studies.
There was no clinically relevant effect of 3TC 150 mg BID on
the PK of TDF 300 mg QD. 3TC absorption was delayed increasing
Tmax by 0.9 hr and decreasing
Cmax 24%. There was no significant
change in 3TC exposure as measured by AUC(o-t). There was no clinically relevant
effect of ddI (Videx™) 400 mg (250 mg if weight <60 mg) QD
taken 1 hour prior to TDF on the PK of TDF 300 mg QD. The Cmax of ddI was increased by 28% and the
AUC(o-t) was increased by 44%.
The PK parameters for TDF 300 mg QD were not affected by
administration with IDV 800 mg Q8H. The IDV Cmax was slightly reduced when IDV was
administered with TDF, but the AUC(o-t) was unchanged. TDF AUC(o-t) and Cmax were approximately 30% higher when
TDF 300 mg QD was given with LPV/r 400/100 mg BID.
Co-administration with TDF resulted in 15% lower LPV AUC(o-t) and Cmax and 11% lower Cmin. The
decrease in Cmin was not statistically significant.
The PK of TDF 300 mg QD was not affected by administration with
EFV 600 mg QD. Neither was the PK of EFV affected by
administration with TDF.
- Further Studies Planned or in
Progress
- Study 903: To evaluate the potential role of tenofovir DF in
treatment-naïve subjects, Gilead initiated a randomized,
double-blind, multi-center, Phase III clinical trial in June
2000. This trial is designed to compare the safety and
tolerability of two treatment regimens, TDF, efavirenz and
lamivudine (3TC) versus stavudine (d4T), efavirenz and
lamivudine. It was fully enrolled in January 2001 with 601
treatment-naíve subjects.
- Study 910: Open-label rollover of
Studies 902 and 907. N=575.
- Expanded Access Program: In
January 2001, after protracted discussions with the community,
Gilead initiated an expanded access program (EAP) for
individuals >18 years of age who required TDF to
construct a viable treatment regimen and had failed treatment
with at least two PIs or one PI and one NNRTI. Individuals were
required to have a viral load of >10,000 copies/ml (by
PCR) and CD4 count <100 cells/ml. Additionally,
individuals with CD4 count between 100 and 200 cells/ml, and
documented evidence of an AIDS-defining opportunistic infection
within the past 90 days were eligible. Individuals were also
eligible for the EAP if they had completed a clinical trial
including TDF and desired continued access to the medication.
Individuals receive TDF 300 mg once daily. In April 2001, after
some start up difficulties, Gilead announced that the company
had broadened the entry criteria for its US EAP to provide TDF
to individuals who had failed prior antiretroviral therapy,
regardless of their CD4 cell count or viral load. To date,
nearly 5000 individuals have enrolled in TDF EAPs in the United
States, Canada, Europe the United Kingdom.
- Pediatric Studies: A pediatric
formulation of TDF is in development and Gilead has said that
they expect it to be ready early in 2002. The study of TDF in
infants and children was deferred pending the outcome of bone
toxicology studies in animals.
- Recommendations for Post-Marketing
Studies
Studies which should be conducted on TDF in the
post-marketing period include:
- A safety and efficacy study in individuals with viral loads
>50, 000 copies/ml
- A safety and efficacy study in treatment-naive individuals —
such a study (903) was fully enrolled in January 2001
- Safety, efficacy and pharmacokinetic studies in children
- Safety and pharmacokinetic studies in individuals with renal
or hepatic impairment
- Studies to identify long-term toxicities of TDF
- Drug-drug interaction studies with drugs that inhibit renal
tubular secretion such as trimethoprim (or cotrimoxazole) and
probenecid; drugs that are excreted by the kidneys and are
likely to be used concomitantly by some HIV-infected
individuals, such as stavudine (d4T), certain antibiotics
(including aminoglycosides, cephalosporins, and penicillins)
narcotic analgesics (such as demerol and morphine) lithium and
digoxin; and the studies which the sponsor has indicated that it
plans to conduct with ddI EC, methadone, oral contraceptives and
adefovir
- Correlation of the IC50 or
IC90 with plasma levels of TFV
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