The Cardiovascular Safety of COX-2 Inhibitors
A Joint Meeting of the FDA Arthritis Advisory Committee and the Drug Safety
and Risk Management Advisory Committee was held on February 16 through 18,
2005. The committees discussed the overall benefit to risk
considerations (including cardiovascular and gastrointestinal safety concerns)
for COX-2 selective nonsteroidal anti-inflammatory drugs and related agents (see
FDA Notice of COX-2 Meeting).
"Interested persons may present data, information, or views, orally or in
writing, on issues pending before the committee. Written submissions may be made
to the Division of Dockets Management....... FDA welcomes the attendance of the
public at its advisory committee meetings...... Electronic comments should be
submitted to
http://www.fda.gov/dockets/ecomments."
TMT has downloaded the
relevant Advisory Committee documents available on the FDA website (FDA
Website - CDER Meeting Documents) as Word documents where available, and as
PDF files if not, and has posted these on the TMT website to serve as a
secondary download source (TMT Website - CDER
Meeting Documents).
Because of its interest in the evaluation and management of chronic pain,
Taylor MicroTechnology, Inc. (TMT) has been carefully following the public
discussions on COX-2 safety since Vioxx was withdrawn from the market on
September 30, 2004. There are very diverse views in the medical community
regarding the cardiovascular safety of COX-2 inhibitors. It is TMT's considered
opinion that Celebrex (celecoxib) is the most extensively studied among marketed
COX-2 inhibitors and should continue to be available as one of the therapeutic
options for patients with chronic pain
(see TMT
Review of Cardiovascular Safety of Celebrex).
- As with most chronic-use drugs, most chronic pain
drugs have not been subjected to the type of study (long-term, controlled
evaluation of cardiovascular endpoints) necessary for adequate assessment of
cardiovascular safety.
- An exception is aspirin which has been conclusively
shown to reduce cardiovascular events. However, aspirin also increases the
risk of GI hemorrhage, so that for many patients aspirin therapy is not
suitable for the treatment of chronic pain.
- Since the introduction of selective COX-2 inhibitors,
long-term controlled studies evaluating cardiovascular safety have been
performed and there is now evidence that some COX-2 inhibitors, and possibly
the conventional NSAID naproxen, may increase cardiovascular risk
(particularly heart attack, stroke and other thrombogenic events).
Insufficient cardiovascular safety data are available for most NSAIDs.
Note added 2/20/05: The above comment on naproxen was based on a
December 2004 press release from the NIH on the ADAPT trial in Alzheimer's
Disease which
"indicated an apparent increase in cardiovascular and cerebrovascular
events" among naproxen patients versus patients receiving a placebo. At the
COX-2 Advisory Committee meeting in February 2005, this assertion was
withdrawn and it was stated that the trial was discontinued because of the
"practicalities" of continuing the trial and that "some post-hoc data
composites barely reached [statistical] significance" for naproxen.
- It is not yet clear whether increased cardiovascular
risk is a class effect of COX-2 inhibitors, a class effect of non-aspirin
drugs for chronic pain, or a drug-specific effect confined to certain drugs
in the COX-2 or non-COX-2 NSAID drug classes.
- A unifying hypothesis based on the thromboxane/prostacyclin
pathways has been proposed as a basis for a class effect of COX-2
inhibitors. However, this hypothesis has not been fully supported by the
actual data.
- Significant differences in molecular structure and
effects on blood pressure have been shown between different COX-2 inhibitors
and there is some evidence that COX-2 inhibitors that increase blood
pressure may be associated with greater cardiovascular risk.
- The limited evidence suggests that increasing doses of
some COX-2 inhibitors are associated with progressive increase in
cardiovascular risk.
TMT Recommendation
The following course of action seems prudent at this time:
- Drugs for chronic pain should continue to be made
available to patients with chronic arthritis or other causes of chronic
pain.
- Aspirin and acetaminophen may be excellent choices for
many patients.
- Dosage and duration of therapy of any drug for chronic
pain should be limited to that necessary for adequate pain relief.
- Particular caution in drug selection is necessary when
treating patients who also have increased cardiovascular risk or an
increased risk of a GI bleed.
- Of the currently marketed COX-2 inhibitors in the
United States, celecoxib (Celebrex) appears to have the most extensive
safety evaluation and the most favorable safety profile. No evidence of
increased cardiovascular risk has been shown at dosage of 200 mg/day or
less.
- The maximum Celebrex dosage should be restricted to
200 mg/day until additional safety data become available.
- Direct marketing of Celebrex to the consumer should
not be resumed, and should be discouraged for medications in general.
- Celebrex should continue to be one of the options
available for the treatment of chronic pain.
TMT has reviewed the
Pfizer Briefing Book made available on the FDA website and has the
following comments:
-
META-ANALYSIS:
-
Dosage and Duration
of Therapy:
-
The average duration of therapy in
those receiving >200 mg/day was only 2 months and
Celebrex dosage may not have exceeded 200 mg/day in most
patients.
-
Additional analyses should be
provided to clarify the dose-response and time-response
relationships for cardiovascular events.
-
As far as possible, the analysis
should avoid confounding of time and dose.
-
Definitions of
Cardiovascular Endpoints:
-
The primary cardiovascular
endpoint is a composite index based on a modification of the
APTC index. It includes 19 event types, some of which are
debatable in the COX-2 context (e.g., all five
peripheral vascular terms dealing with venous rather than
arterial thrombosis, and inclusion of "cerebrovascular disorder"
and "cerebral hemorrhage").
-
It is stated that "Stroke
comprised the individual adverse events cerebrovascular
accident, cerebrovascular disorder, and cerebral hemorrhage."
Including "cerebrovascular disorder" as a "stroke" is debatable,
particularly in patients with Alzheimer's disease. It would be
useful to have event rates separately for cerebrovascular
accident and cerebral hemorrhage, since the thromboxane/prostacyclin
hypothesis would suggest that thrombotic cerebrovascular events
might be increased with Celebrex whereas cerebral hemorrhage
could be reduced.
-
Assurance is required that
inclusion of many terms in the APTC and stroke definitions did
not dilute a true drug effect on events related purely to
arterial thrombosis.
-
Separate Kaplan-Meier plots for
myocardial infarction and/or stroke, myocardial infarction
alone, and stroke alone (based only on the term “cerebrovascular
accident”) would be useful.
-
It should be stated whether the
decision to use the modified APTC composite index and other
defined endpoints was made before or after the safety results
had been examined.
-
One-Sided or
Two-Sided Testing: It is not stated whether p
values in the meta-analysis were based on one-sided or two-sided
testing.
-
Inclusion of
Non-Pfizer-Sponsored Studies in Meta-Analysis or Comparable Tables:
To the extent possible from the data available to Pfizer,
tabulations of cardiovascular safety should include both
Pfizer-sponsored and non-Pfizer-sponsored studies.
-
Kaplan-Meier Plot
(Figure 1): This plot is visually misleading and
difficult to interpret (closed circles for Celebrex, and NSAIDs
plotted on top of Celebrex data). Additional analysis of the
6-month-to-1-year data would be useful.
-
Typographical-Type
Errors: There are some scattered minor errors in
the Pfizer Briefing Book (e.g., Page 25 says “3 of the 10 patients
in the celecoxib treatment group” whereas it should say “3 of the 10
patients in the placebo treatment group”).
-
ADDITIONAL
DATA ON THREE KEY INDIVIDUAL
TRIALS:
-
Three trials of particular importance
are the APC trial, the ADAPT trial and
Study IQ5-97-02-001.
-
The APC and ADAPT trials
were not Pfizer-sponsored, and only preliminary results are
available. However, in so far as these preliminary results can be
combined with the appropriate long-term studies in the Pfizer
database, an overall assessment of risk should be made.
-
Study IQ5-97-02-001 appears to be a
Pfizer-sponsored study and was completed several years ago. However,
the
Study Report for IQ5-97-02-001 posted on the Internet does not
reach Pfizer’s normal high standards. The statement is made that “A
statistically significant difference favoring placebo in adverse
events was observed for certain CV-related body system terms
(Cardiovascular Disorders, General; Heart Rate and Rhythm Disorders;
Myo, Endo, Pericardial & Valve Disorders). These differences were
primarily driven by the individual terms cardiac failure,
fibrillation atrial, and angina pectoris.” However, the raw
tabulations, statistical rationale, and detailed results underlying
this statement are not provided in the study report.
Posted on www.masterdocs.com on
February 5, 2005 and revised February 7, 2005.
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