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[전문가기고_조제영] Review of FDA CDER Approved Drugs in 2019(4)

  • 2020.06.29
  • 818

Review of FDA CDER Approved Drugs in 2019

 

유니테스CRO 조제영

 

(본 내용은 FDA 에서 발간한 New Drug Therapy Approvals in CDER, 2019 의 내용 및 FDA 허가 검토자료를 바탕으로 작성되었다.)

 

본 리뷰에서는 2019 FDA CDER Approved Drugs 중 First-In-Class 로 허가 받은 약물 Adakveo, Balversa, Cablivi, Evenity, Givlaari, Ibsrela, Nourianz, Oxybryta, Padcev, Polivy, Pretomanid, Reblozyl, Reyvow, Scenesse, Turalia, Vyleesi, Vyndaqel, Vakix, Xpovio, 와 Zulresso 중 지난 호에 이어 Polivy 와 Pretomanid 두개의 약물에 대하여 치료 적응증, 분자 기전, 임상시험에 대한 요약 및 benefit/risk 에 준한 허가 내용에 대하여 요약하겠으며, 번역에 따른 제품의 그릇된 이해 방지를 위하여 영문 그대로 발췌, 요약하였다.

 

Drug

Name

Indication(s)

Pharmacologic Class/Unmet Medical Needs

Polivy (polatuzumab vedotin-piiq)

Poligy is indicated in combination with bendamustine and a rituximab product for the treatment of adult patients with relapsed or refractory diffuse large B-cell lymphoma (DLBCL), not otherwise specified, after at least two prior therapies

Polivy is a CD79b-directed monoclonal antibody-drug conjugate consisting of three components:

1) the humanized immunoglobulin G1 (IgG1) monoclonal antibody specific for human

CD79b; 2) the small molecule anti-mitotic agent (MMAE); and 3) a protease-cleavable linker that

covalently attaches the MMAE portion of the compound to the polatuzumab antibody.

 

Current standard therapy and medical unmet needs:

The current standard of care for the treatment of DLBCL is chemotherapy consisting of rituximab,

cyclophosphamide, doxorubicin, vincristine, and prednisone (R-CHOP). Approximately 60% of patients are cured with this treatment regimen, however, one-third of patients may develop relapsed/refractory (r/r) disease, leading to morbidity and mortality in patients who have exhausted primary treatment therapies.

3 Salvage therapies may include stem cell transplant if the patient meets certain criteria, followed by high-dose chemotherapy. Less than 40% of patients receiving second line therapies are cured, and median overall survival rates are approximately 6 months. There remains an unmet need for patients with r/r DLBCL.

 

Benefit Assessment:

The efficacy of Polivy was evaluated in Study GO29365 (NCT02257567). This was a randomized, openlabel, multicenter study that included 80 patients with r/r DLBCL that received at least one prior regimen for treatment of their disease.1 Patients were randomized 1:1 to receive the study regimen which included Polivy with bendamustine and a rituximab product (BR) or BR alone for six 21 day cycles. Efficacy was based on complete response (CR) rate at the end of treatment and duration of response (DOR) as determined by an independent review committee (IRC). Another efficacy measure included IRC-assessed best overall response. In the Polivy plus BR arm (n=40), patients received a median of five cycles, with 48% receiving 6 cycles. In the BR arm (n=40), patients received a median of three cycles, with 23% receiving 6 cycles.1 Results: Twenty-five patients in the Polivy plus BR arm achieved a partial or complete response. Sixteen of these patients (64%) had a DOR of at least 6 months, and 12 (48%) had a DOR of at least 12 months. Ten patients in the BR achieved a partial or complete response, and three of these patients had a DOR lasting at least 6 months, and 2 had a DOR lasting at least 12 months. Benefit outweigh its risks

Regulatory Pathway: Accelerated approval

Pretomanid

Pretomanid is antimycobacterial drug indicated, as part of a combination regimen with bedaquiline and linezolid, for the treatment of adults with pulmonary extensively drug resistant (XDR), or treatment-intolerant or nonresponsive multidrug-resistant (MDR) tuberculosis (TB). Pretomanid is indicated for use in a limited and specific population of patients.

Mode of Actions

Pretomanid kills actively replicating M. tuberculosis, by inhibiting mycolic acid biosynthesis thereby blocking cell wall production. In addition, under anaerobic conditions, bioreduction of pretomanid generates reactive nitrogen species and results in respiratory poisoning of M. tuberculosis complex

 

Benefit Assessment;

Approval of this indication is based on limited clinical safety and efficacy data. The primary endpoint was a favorable outcome (absence of bacteriologic failure, relapse, or clinical failure) through 6 months following end of treatment (EOT). The trial is ongoing and at the interim data cutoff of June 29, 2019, the rate of favorable outcomes 6 months following EOT was 89% (95/107), 95% CI [81%-96%] in the Intent to Treat (ITT) population. As of the January 18, 2019 interim efficacy data cutoff, 32/38 (84%) patients had favorable outcomes at 24 months following EOT. The lower confidence limit for success greatly exceeded the prespecified historical control rate of 50%. In addition, a comparison was made to the outcomes to a matched historical control cohort and to the outcomes for XDR-TB reported in the literature. For the matched historical control, favorable outcome was 9/84 (11%) compared to Nix-TB 39/44 (89%), Relative Risk 64.5, 95% CI [9 to 472], p <0.0001. Successful outcomes based on review of the literature for treatment of XDR-TB was 28%, 95% CI [21% to 34%] with regimens that did not contain bedaquiline or linezolid. The contribution of pretomanid, bedaquiline and linezolid to the BPaL regimen was based on studies in the murine model of pulmonary TB. In three studies, the BPaL regimen achieved significantly greater reduction in bacterial lung burden (bactericidal activity) than the 2-drug regimens (BPa, BL or PaL) at the 8-week treatment time points. In addition, fewer mice treated with the 3-drug combination relapsed (sterilizing activity) compared to the BPa and BL regimens. Supportive information was provided from other studies in murine models that showed the contribution of the 2-drug combinations that contained pretomanid.
Regulatory Approval Pathway;
As the NDA is being approved under the LPAD pathway, labeling includes appropriate information to reflect approval in a limited population (Ref. Limited Population Pathway for Antibacterial and Antifungal Drugs, Guidance for Industry).

 

허가 약물의 허가 자료의 리뷰는 개발 및 임상 담당자, RA 담당자에게 직접 경험하지 못한 간접적경험에 기반한 많은 참고할 만한 정보를 제공한다. Polivy의 경우는 ADC drug으로 본 리뷰에서는 다루지 않았지만 허가 자료의 chemistry review를 통하여 제조에 따른 기시 항목에 대한 참고자료로 활용될 수 있으며, 또한 소개된 두 약물 모두 unmet medical needs 가 있는 환자를 대상으로 combination drug으로 허가를 득하는 방법에 대한 참고자료로 활용될 수 있다.   

 

Pretomanid의 경우는 약물에 효과가 있는 limited and specific population을 대상으로 preliminary safety and efficacy 결과로 LPAD pathway를 통하여 허가를 득한 약물로 현재 본 제품에 대한 임상은 진행중에 있다.

이렇듯 First-In-Class 약물은 약물의 효능을 long term 임상을 통하여 fully 규명하지 않아도 어떻게Regulatory Pathway를 활용하는가에 따라 조기 허가가 가능함으로 First-In-Class의 약물을 개발하거나 Life Threatening 한 약물을 개발하고 있는 개발사의 경우 Regular NDA 가 아닌 규제기관과의 협의를 통하여 조기 판매 허가를 득할 수 있는 Regulatory Strategy의 중요성을 한 번 더 강조 하고자 한다.

 

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