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Disclosures Employee:
• Pfizer
Shareholder:
• GlaxoSmithKline
• Spero Therapeutics
Consultant:
• Prokaryotics
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The opinions expressed in this presentation are my own and are not necessarily
shared by my employer or industry colleagues © ESCMID eL
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Industry Experience with Drug Development of Anti-Infectives
John F. Tomayko, MD
ESCMID/ASM Conference on Drug Development to Meet the Challenges of
Antibiotic Resistance
September 4-7, 2018 Lisbon, Portugal
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Agenda
• Pearls • Phase 1 FTIH
• A chance to save time and cost
• Phase 2 • To do or not to do?
• Phase 3 • Going to the battlefield
• Public Private Partnerships • Push-incentives and trial networks
• What’s beyond--- Yikes!!
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PHASE 1
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PHASE 1-First Time in Human Studies
• FTIH studies are largely prescriptive, dose ascending studies, single ascending (SAD), followed by a multiple ascending dose (MAD) • Choose safe starting dose, based on the NOAEL of most sensitive species in
toxicology studies • Convert to Human Equivalent Dose (HED) based on body surface area • Apply safety factor, usually 10 to 20 fold lower= starting dose for single ascending dose*
• Cohort sizes vary, typically 6-8 active, 2 placebo • Staggering dosing among subjects has become standard • Sentinel patient dosing before full cohort is becoming more common • Dose escalation schemes vary
• Many now consider including multiple ascending dose in FTIH study, so that both escalations are done under one protocol • MAD start is typically midway through SAD
*Non-linear PK, irreversible toxicity, steep dose response curve, variable bioavailability requires greater safety margin
5 Tomayko JF ASM/ESCMID Lisbon 2018
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Opportunities to Streamline FTIH Study Conduct
• Several countries have streamlined the clinical trial approval process and excel in the conduct of FTIH studies • Example 1: MHRA can approve the CTA for FTIH typically <14d
• They allow fusion of SAD and MAD and even other elements such as food effect into one study
• Several excellent UK sites can help with all aspects of the trial from regulatory submission, protocol design and execution
• Example 2: Australia uses a CTN process which is more of a notification and approved by the HREC (AUS ethics committee), this is a simple application and for straightforward programs can be approved in 5-10 days • However, if there are complexities in the program, a more detailed CTX is required and pulls
in the regulatory authorities (TGA) • Must be submitted by an AUS entity, many CROs available and similarly capable research sites • Exchange rate currently favors US$ over AUS$ further reducing costs
• Other countries (Netherlands, Germany, etc) have similar capabilities
https://www.tga.gov.au/book-page/ctn-and-ctx-schemes
http://www.richmondpharmacology.com/downloads/Publications/Richmond%20Pharmacology%20Ltd%20(2)%20(2).pdf
6 Tomayko JF ASM/ESCMID Lisbon 2018
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PHASE 2
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Phase 2: Go or Skip? • There is controversy about the value of PH2 with properly dosed antibiotics
• Whereas ~70% of PH2 PoC trials in other TAs are unsuccessful, this doesn’t apply to antibiotic trials* • For abx, a successful PoC combines solid preclinical work, demonstrating thorough understanding
of PK/PD + Ph1 data, showing that target exposures for key pathogens can be reliably and safely achieved (good safety margin)
• Small PH2 trials often don’t reveal safety risks
• PH2 trials could be useful: • The more that you don’t know about dose, the more valuable PH2 becomes • Concerns about tolerability issues in target population, e.g. nausea, vomiting in post op pts • Dose ranging when there is room to dose higher than current MICs demand • Novelty (novel target, endpoints, delivery, etc.) • Ambiguous results regarding frequency of resistance
• PH2 trials can help discharge risk earlier, but so can adaptive PH2-3 trials when properly executed
*http://www.appliedclinicaltrialsonline.com/phase-iii-trial-failures-costly-preventable 8
Tomayko JF ASM/ESCMID Lisbon 2018
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EXAMPLE:
Development Program Discontinued due to the Emergence of Resistance in PH2
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AN3365 (formerly GSK2251052) Works by Inhibiting Bacterial Leucyl tRNA Synthetase
GSK'052-A76 Adduct In Editing Site
tRNALeu
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• Mechanism of action
• LeuRS is an essential
enzyme for protein
synthesis
• GSK’052 forms an
adduct with the tRNA
in the editing site
locking LeuRS in an
unproductive state
• Mutants are editing
deficient When the 3′ end of tRNALeu binds to the editing active site, the boron crosslinks to the cis diols of its terminal ribose
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Will resistance emerge on therapy?
Factors
Do at least 90% of strains tested have a low/moderate Frequency of Resistance? Low: ≤9 x 10-9 Moderate: 1 x 10-8 to 4 x 10-8 High = ≥5 x 10-8
Is it likely the exposure in patients can “cover” the MIC of the mutants?
Is there a fitness cost in the mutants?
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Discharge this risk before progressing to Phase 3 studies © ESCMID eL
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AN3365/(‘052) : Pre-Clinical Knowledge Regarding Resistance
• FOR was considered moderate-to-high, ranging 10-7-10-8
• Laboratory generated mutants resistant to AN3365/(‘052) contain mutations in leuS and were determined to be incapable of editing
• AN3365/(‘052) MICs of resistant mutants range from 32->512 mcg/mL
Given a novel target and the extremely broad GN spectrum of AN3365 (‘052), and a false sense that the mutants would be unfit, PH2 studies in cUTI and cIAI were started
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Both studies were suspended when the rapid emergence of resistance was detected in four subjects in the cUTI study, emerging after the 1st day of therapy
cUTI: (20 patients recruited) cIAI: (15 patients recruited)
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PHASE 3
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Phase 3 Trial Development
• Phase 3 studies are typically randomized, controlled, double-blinded, non-inferiority, multicenter trials of large patient numbers intended to support a regulatory submission
• Comparison of the test drug to a drug considered to be the “gold standard” for treatment of the disease under study
• Make sure you have the capabilities in place before you embark on a Phase 3 trial
• You must have a clear protocol that can be feasibly executed • Consider obtaining input from high recruiting site investigators or study coordinators
• Build in protocol flexibility where possible to avoid amendments
Tomayko JF ASM/ESCMID Lisbon 2018
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Non-inferiority vs. Superiority* • Why are new antibiotics mainly developed using non-
inferiority (NI) trials vs. existing SoC agents • New antibiotic trials must (usually) be designed to avoid superiority
• MDR/XDR are rare (we hope) & require customized comparators (BAT)
• Must NOT enroll if resistance is known/likely to TEST or comparator.
• Highly unlikely to see superiority over a fully dosed modern comparator when pathogen is susceptible to same
• Very hard to win on toxicity
• Superiority is a high-stakes gamble for a novel agent • If your primary aim is to show superiority and you fail on this, you cannot
retreat to a claim of non-inferiority
• But if you see superiority in a NI study, you can claim that result
• Once you show superiority you have a new SoC therapy, harder for next agent to demonstrate superiority
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*Modern Non-inferiority Trial Designs Enable Antibiotic Development in Advance of Epidemic Bacterial Resistance Link: https://doi.org/10.1093/cid/cix246
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Phase 3 Antibiotic Pivotal Trials
• Should have selected the proper dose for body site infection under study • Very important for lung infection
• If you have chosen the proper dose, biggest remaining risk is safety risk • Remember the “Rule of 3”– 1/100 risk will be detected in 300 pt. exposures…
• Select qualified, experienced sites • Make sure they are collaborative, and help them define a referral network • Site engagement throughout study is crucial
• Sponsor’s designated medical monitor should follow up with PI on all SAEs • A robust narrative, following the work-up and course of each SAE is essential
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Challenges of Pivotal Trials of Antibiotics
• Patients are urgently started on empiric therapy to reduce mortality and morbidity which may obscure the effect of an abx under study • Imprecise diagnosis of infection under study can weaken the conclusion of a
NI analysis
• Uncertainty of bacterial pathogen can lead to additional abx coverage with overlapping spectrum with abx under study
• The severity of the acute illness can make obtaining informed consent and completing enrollment procedures challenging
• Hospital policies often encourage early discharge increasing the operational challenges of studying IV only antibiotics
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Challenges (cont.)
• Start-up timelines can be delayed, particularly for inpatient studies, if site-specific issues are not understood • Contracting with sites is time consuming, sometimes need multiple contracts
(e.g. PI, hospital, pharmacy)
• Often several review committees, that may not meet every week
• Sites may require sponsors to provide ancillary supplies for infusions, and sometimes ancillary equipment, IV pumps, refrigerators, etc. Its important to learn early
• Understand patient flow, communications or alert systems in hospitals so that patients can be enrolled quickly
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Microbiologically Evaluable Population (ME cohort)
Challenges • Obtaining quality specimen
• Transport
• Central Lab vs. Local
• Protocol adherence
• Microbiological technique and identification
• Consistent results reporting
• Storage of isolates
• Real time review of culture results
• AST (frozen; dried; MIC; disk; eTESTS; CLSI; EUCAST???)
Solutions • Clear Protocols
• Involve Clinical Microbiologists; not just the Investigator
• Training for investigator site staff
• Training for laboratorians/specimen collectors
• Follow-up during study
• If CRO involved; ensure high quality clinical microbiology support
• Invest in expertise for real time review of culture results.
Clinical Microbiologist = Indispensable role on the Clinical and Project team
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Public/Private Partnership to Overcome Challenges
• “Push incentives” have had a tremendously positive impact on our field
• COMBACTE projects generate clinical epidemiology and microbiology data from several observational studies • supporting greater disease understanding and informed clinical trial design and conduct
• BARDA SMEs and COMBACTE academic leads providing advice as integrated members of the pharma team – real time advice leading to clinically relevant protocols
• Clinical Trial Networks and Platform Trials could reduce costs and expedite recruitment (Wellcome Trust, BARDA)*
Clin Infect Dis. 2016 Aug 15; 63(Suppl 2): S57–S59 * 20
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Safety and Efficacy of ZTI-01 (IV Fosfomycin) vs Piperacillin/Tazobactam for Treatment cUTI/AP Infections (ZEUS)
Sponsor: Zavante Therapeutics Collaborator: Medpace, Inc.
Study Type : Interventional (Clinical Trial) Actual Enrollment : 465 participants
Allocation: Randomized Intervention Model: Parallel Assignment
Masking: Quadruple (Participant, Care Provider, Investigator, Outcomes Assessor)
Primary Purpose: Treatment Official Title: Randomized, Double-Blind, Comparative Study to
Evaluate the Safety and Efficacy of ZTI-01 vs Piperacillin/Tazobactam in the Treatment of cUTI/AP Infection in Hospitalized Adults
Actual Study Start Date : April 2016 Actual Primary Completion Date : January 12, 2017
Actual Study Completion Date : May 30, 2017
465 pts. recruited in <7 months
Recent Clinical Trial Highlights the Value of a Clinical Trial Network
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Aztreonam/Avibactam a Unique Collaboration
BARDA Ph3
• All non EU sites (LA/AP/US)
• Support for drug supply and microbiology
• Resistant pathogen study
• Clin Pharm studies
• Pediatric PK
COMBACTE-CARE Ph2
• ARO in place of CRO 1st time
• EU sites (Clin Net) in Spain/France/Germany • Spain recruited ~90% pts.
Ph3
• Academic partners provided pragmatic relevance to protocol improving feasibility
• Clin Net sites in EU
• Global clinical leadership
Pfizer Ph1
• SAD/MAD
Ph 2 and 3
• Overall management and governance
• Clinical Management
• Regulatory
• Safety
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What About Narrow-Spectrum Agents? • There is clear recognition that narrow or single spectrum agents vs. P.
aeruginosa, A. baumannii, etc. could be therapeutically useful
• Tier C development was outlined to develop narrow spectrum agents when a “Tier B” non-inferiority study not feasible
• Regulations must still be met
• Substantial evidence of effectiveness • Adequate safety data to support benefit/risk
FDA workshop on narrow spectrum agents: https://www.fda.gov/drugs/newsevents/ucm497650.htm FDA workshop: Animal models of serious infections https://www.fda.gov/Drugs/NewsEvents/ucm534031.htm AMDAC: “Developing Antibacterial Therapies Targeting a Single Bacterial Species“
https://www.fda.gov/downloads/AdvisoryCommittees/CommitteesMeetingMaterials/Drugs/Anti-InfectiveDrugsAdvisoryCommittee/UCM551632.pdf
*Duke Margolis: “Understanding the Development Challenges Associated with Emerging Non-Traditional Antibiotics”
https://healthpolicy.duke.edu/events/understanding-development-challenges-associated-emerging-non-traditional-antibiotics
*FDA workshop: Developing non-traditional therapies for bacterial infections https://www.fda.gov/Drugs/NewsEvents/ucm606052.htm
23 *Many of these “non-traditional therapies” would need to be studied as adjunctive to antibiotics
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Parting Comments…
• Following the regulatory guidance can yield an approvable file…
…obtaining ROI means you need a reimbursable file
• Make sure your investors understand the risks (not easy)
• Get expert help early in the process, experienced help is critical to success
• Don’t forget CMC!!
• Regulators want you to succeed, they are on your team! ENGAGE THEM
• Small Companies who intend to commercialize their newly approved products should build resource to support regulatory approvals in regional markets, and recognize the perpetual challenges of supporting a marketing license
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Acknowlegements
• Linda A. Miller, PhD (GSK retired, Independent Consultant)
• Nicole Scangarella-Oman (GSK)
• Joseph Chow, MD (Pfizer)
• Juliet McQuillan, MSc (Pfizer)
• Seamus O’Brien, PhD (GARDP)
• Brian Murphy, MD (Medpace)
[email protected] [email protected]
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