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The Food and Drug Administration's (FDA) Psychopharmacological Drugs
Advisory Committee met on July 19, 2000 to review the safety and
effectiveness of Pfizer's atypical antipsychotic drug ziprasidone (ZELDOX).
The committee voted nine to one to recommend approval of the drug as a
first-line treatment for schizophrenia. The final decision to approve
ziprasidone, including labeling that could restrict its use to second-line
treatment and warnings about potentially fatal heart rhythm disturbances,
or to not approve the drug is the FDA's. The agency is expected to make
its final decision about the drug sometime this year.
Pfizer submitted a New Drug Application (NDA) to the FDA for
ziprasidone on March 18, 1998. Three months later on June 17, 1998 the
agency issued the company a not-approvable letter based on "the judgement
that ziprasidone prolongs the QTc and that this represents a risk of
potentially fatal ventricular arrhythmias [heart rhythm disturbances] that
is not outweighed by a demonstrated and sufficient advantage of
ziprasidone over already marketed antipsychotic drug products."
The QTc interval is the length of time it takes the large
chambers of the heart (ventricles) to electrically discharge and recharge.
A prolongation of the QTc interval can lead to heart rhythm
disturbances, or cardiac arrhythmias, such as torsade de pointes and other
life-threatening arrhythmias. The QTc interval is measured by an
electrocardiogram (EKG or ECG) in milliseconds (msec). The subscript "c"
indicates that the QT interval has been corrected for the patient's heart
rate. Torsade de pointes is a French phrase that means "twisted point"
that describes the appearance of this type of rhythm disturbance on the
EKG tracing.
The basis for this article are documents posted on the FDA's web site
the day before the July 2000 Psychopharmacological Drugs Advisory
Committee meeting. These are the same materials that were distributed to
the committee members prior to the meeting and consist of Pfizer's
briefing book and the FDA reviews of the data submitted in ziprasidone's
NDA by Pfizer. These documents are now available to the public as a direct
result of a lawsuit the Health Research Group filed against the FDA under
the Freedom of Information Act and the Federal Advisory Committee Act in
1999. We prevailed and since January 1, 2000, the materials distributed to
advisory committee members are now, for the first time, available to the
public on the Internet, usually the day before a meeting.
Drug companies exercise tremendous control over the information that is
reported in the news media and medical literature about their new drugs.
We believe that it is no longer possible to form an objective opinion
about the therapeutic value of a new drug using only the published medical
literature. Any evaluation of a new drug that does not include the FDA's
review is incomplete and can lead to an overestimation of the potential
therapeutic value of the drug.
The documents distributed to the ziprasidone advisory committee can be
found on the FDA's web site at:
http://www.fda.gov/OHRMS/DOCKETS/AC/00/backgrd/3619b1.htm
A major concern expressed by the FDA in its June 17, 1998 not-approval
letter to Pfizer was that the degree of QTc prolongation observed with
ziprasidone may have represented an underestimate given the fact that most
ECGs were likely obtained when the blood levels of the drug were the
lowest. The FDA recommended that Pfizer conduct another study to determine
the QTc effect of ziprasidone when the drug's blood levels were
the highest in comparison to other atypical antipsychotics and with
several other standard antipsychotic drugs.
Pfizer complied and conducted a direct comparison of ziprasidone at its
optimal dose to haloperidol (HALDOL), olanzapine (ZYPREXA), quetiapine (SEROQUEL),
risperidone (RISPERDAL), and thioridazine (MELLARIL) with ECGs obtained
when the blood levels of these drugs were at their highest. The Division
of Neuropharmacological Drug Products which has the responsibility for
reviewing new antipsychotic drugs asked the agency's Division of
Cardio-Renal Drug Products to review this study. This later Division has
experts in the effect of drugs on the heart.
The study involved 183 patients with normal ECGs and psychotic
disorders. Following a screening phase, the study consisted of five
different treatment periods: (1) patients who were eligible for the study
had their current drugs stopped over a period of several days as
out-patients; (2) the patients were admitted to a research facility to be
completely withdrawn from the current drugs; (3) the patients were then
randomly assigned to one of the six study drugs (ziprasidone, risperidone,
olanzapine, quetiapine, thioridazine or haloperidol) with doses increased
over 10 to 19 days; (4) after the maximum dose of the study drugs was
reached, a potentially interacting drug selected for each study drug was
given to the patients; and (5) after the blood levels of the study drugs
were stabilized with the combination of the study drug and interacting
drug, the patients were withdrawn from treatment. Baseline ECGs were
obtained. Additional ECGs were obtained on day 2 of the study, when the
blood levels of study drugs were stabilized, and with the potentially
interacting drugs. The ECGs were recorded at times estimated to correspond
with the maximum blood levels of the study drugs.
Table 1 below summarizes the average change in
QTc interval for the six study drugs and the range when the
blood levels for the drugs were stabilized and their concentrations were
estimated to be at their highest. Thioridazine clearly had the largest
effect in lengthening the QTc interval followed by ziprasidone.
| Table 1
Average Change and Range of QTc Intervals in Milliseconds
for the Six Study Drugs |
|
Drug |
Average Change From Baseline
in Milliseconds (msec) |
Range in Milliseconds (msec) |
| thioridazine |
35.8 msec |
22.3 msec to 49.3 msec |
| ziprasidone |
20.6 msec |
4.2 msec to 37.0 msec |
| quetiapine |
14.5 msec |
1.8 msec to 27.2 msec |
| risperidone |
10.0 msec |
-1.1 msec to 21.1 msec |
| olanzapine |
6.4 msec |
-7.2 msec to 20.0 msec |
| haloperidol |
4.7 msec |
-12.2 msec to 21.6 msec |
The number and percentage of patients grouped according to the extent
of QTc interval prolongation is seen in
Table 2 below. Again, thioridazine and ziprasidone rank one and two
with none of the patients taking the other drugs experiencing a
prolongation of 75 msec or greater.
| Table 2
Numbers and Percentage of Patients Who Experienced QTc
Prolongation of 30, 60, or 75 Milliseconds (msec) or Greater
|
|
Drug |
Increase of 30 Milliseconds (msec) or
Greater (percentage) |
Increase of 60 milliseconds (msec) or
Greater (percentage) |
Increase of 75 Milliseconds (msec) or
Greater (percentage) |
| thioridazine |
27 (90%) |
6 (20%) |
4 (13%) |
| ziprasidone |
21 (64%) |
7 (21%) |
1 (3%) |
| quetiapine |
14 (52%) |
3 (11%) |
0 |
| risperidone |
12 (46%) |
1 (4%) |
0 |
| haloperidol |
11 (41%) |
1 (4%) |
0 |
| olanzapine |
9 (35%) |
1 (4%) |
0 |
The experience with the antipsychotic drugs sertindole (SERLECT) and
thioridazine places ziprasidone's effect on QTc interval
prolongation in some perspective. Sertindole was recommended for approval
by an FDA advisory committee and approved by the FDA on October 2, 1996,
but the drug was never marketed in the U.S. Before its approval it was
known to increase QTc by about 21 milliseconds. Doctors and
pharmacists were notified on July 7, 2000 about the addition of extensive
new safety warnings, including a boxed warning, to the professional
product labeling, or "package insert," for the thioridazine regarding QTc
interval prolongation, cardiac arrhythmias, torsade de pointes and the
possibility of sudden death.
Ziprasidone increases the QTc on average about 10 to 20
milliseconds and thioridazine approximately 36 milliseconds. Sertindole
was marketed in the United Kingdom but was withdrawn on December 2, 1998
following reports of cardiac arrhythmias and sudden cardiac death
associated with its use. The European Commission reached a decision on
February 25, 2000 on a European wide suspension of the marketing
authorization of sertindole for one year. The magnitude of the increase of
the QTc and QT interval is considered to be important; it is
not predictive of the degree of risk of torsade de pointes or other
serious cardiac arrhythmias.
The FDA must balance the potential risks of a cardiac arrhythmia and
sudden death against the research documenting what is known about the
efficacy of ziprasidone.
Ziprasidone's Efficacy
The FDA was in general agreement with Pfizer regarding the
antipsychotic efficacy of ziprasidone based on short-term, fixed dose,
clinical trials using an inactive dummy drug or placebo for comparison.
The FDA was careful to point out that they were not "aware on any evidence
from these or any other studies of any superior antipsychotic efficacy for
ziprasidone compared to any other antipsychotic drugs, either in typical
schizophrenic patients or in those shown refractory to standard
antipsychotic therapy."
The FDA did not release their own detailed analyses of the clinical
trials that had previously been submitted by Pfizer in support of
ziprasidone's approval. We had to depend on Pfizer's interpretation these
trials. Pfizer presented the results of five clinical trials in their
briefing materials distributed to the advisory committee. Four of these
tested the effect of ziprasidone in the management of the acute symptoms
of schizophrenia. The studies lasted four to six weeks and involved 702
patients who received ziprasidone in doses ranging from 10 milligrams to
200 milligrams, 273 patients that received a placebo, and in one trial 85
patients who were given a fixed dose of haloperidol 15 milligrams. The
fifth trial assessed the effect of ziprasidone in preventing schizophrenia
relapse. This last trial ran for 52 weeks, 219 patients received
ziprasidone in doses from 40 milligrams to 160 milligrams, and 75 patients
received the inactive placebo.
Various rating scales were used to test the efficacy of ziprasidone. A
brief description of these scales can be found in the side-bar
accompanying this article. In general, the standard for showing that a
drug has a treatment effect (efficacy) is that the average scores on the
rating scales improve and that the difference between the averages for
those patients receiving ziprasidone, for example, are statistically
different from the group of patients receiving the inactive placebo.
Overall, Pfizer found that ziprasidone treatment was statistically
superior to no treatment at all.
In the single trial in which ziprasidone was compared to an active
antipsychotic drug, ziprasidone, in several different dosages, was
compared to 15 milligrams of haloperidol. Pfizer estimated that the
treatment effect for haloperidol was greater on the four rating scales
used in the study compared to all dosages of ziprasidone tested. Pfizer
did not determine if the difference between haloperidol and ziprasidone
was statistically significant and the company did not provide sufficient
information for us to make this determination, nor did Pfizer discuss this
finding in the narrative describing the trial.
Pfizer found in the 52-week long study testing the effect of
ziprasidone compared to placebo in the prevention of schizophrenia relapse
that ziprasidone was statistically superior to the placebo. At the end of
the study, about 25 percent of the patients given the placebo were relapse
free and approximately 60 percent of the ziprasidone patients were also
relapse free.
The evidence presented and interpreted by Pfizer suggest that
ziprasidone is superior to an inactive placebo in the treatment and in the
prevention of schizophrenia symptom relapse. But, ziprasidone may actually
be inferior to haloperidol, based on four rating scales, in the treatment
of schizophrenia symptoms.
Ziprasidone and Weight Gain
Pfizer highlighted the weight gain seen with other antipsychotic drug
compared to ziprasidone in its briefing materials distributed to the
advisory committee. Table 3 below is based on
information presented in the company's briefing materials.
| Table 3
Weight Change from Baseline in Long-Term Trials of Ziprasidone vs
Reported Data for Other Antipsychotic Drugs |
| Drug |
Reported Weight Gain |
Source |
| ziprasidone |
0.5 pounds; over 6 months |
Pfizer |
| risperidone |
5.1 pounds; over 6 months |
Manufacturer Product Monograph |
| olanzapine |
11.9 pounds; median duration of treatment 238 days |
US Product Labeling |
| quetiapine |
12.4 pounds; over one year |
Manufacturer Product Monograph |
Pfizer promoted ziprasidone as "weight neutral" in a July 19, 2000
press release announcing the advisory committee's recommendation to
approve the drug. QTc interval prolongation was mentioned but
no explanation was provided as to its potential serious consequences.
Manufacturer's make it a point to minimize potential adverse effects. It
remains to be seen if this difference in weight gain claimed by Pfizer
will persist between ziprasidone and other antipsychotic drugs if the drug
is approved and prescribed to large numbers of patients outside of a
controlled experimental setting.
The law will not allow the FDA to require that a manufacturer show a
new drug is either safer or more effective than currently marketed drugs
as a condition of approval. In fact, new drugs may be less safe or
effective than drugs already on the market. When Congress decides to
"raise the bar" for approving new drugs, the American public will have
better drugs, not just more drugs.
Based on the FDA's review of Pfizer's study showing the extent of
ziprasidone's effect on QTc interval compared to other
antipsychotic drugs and the company's failure to demonstrate an advantage
over currently available drugs, the Psychopharmacological Drugs Advisory
Committee's recommendation to approve ziprasidone as a first-line
treatment was irresponsible. If approved, ziprasidone should be
recommended as a second line antipsychotic. If its relative lack of weight
gain is confirmed in longer-term studies, it may be useful for patients on
antipsychotics for whom weight gain is a major problem. However, the
cardiac effects of this drug are troublesome. Long-term follow up and
monitoring of patients taking it will be necessary to insure that the
risks of taking it do not outweigh any possible benefits.
| RATING SCALES USED TO ASSESS THE EFFICACY OF
ZIPRASIDONE |
| Positive and Negative Syndrome Scale (PANSS):
This scale consists of 30 items, with the total score consisting of
the sum of the seven positive items, seven negative items, and 16
general psychopathology items. The PANSS negative subscale score is
the sum of the 7 negative items. A decrease in PANSS score (total,
positive, or negative) reflects improvement in the evaluated items in
schizophrenic patients. |
| PANSS Depression Factor: This scale equals the
sum of 5 items derived from the PANNS (depression, anxiety, guilt,
somatic concern, and preoccupation). |
| Brief Psychiatric Rating Scale (BPRS or BPRSd):
This scale consists of 18 items with the total score representing the
sum of all 18 items while the core items score is the sum of 4 items
(conceptual disorganization, suspiciousness, hallucinatory behavior,
and unusual thought content). A decrease in BPRS score reflects an
improvement in the evaluated items in schizophrenic patients. The BPRS
may also be derived from the PANSS; it is then designated BPRSd. |
| Clinical Global Impression Severity (CGI-S) and
Improvement (CGI-I): evaluation is a single rating of how
mentally ill a skilled rater feels the subject is at the time of
evaluation. A decrease in CGI-S score reflects symptomatic improvement
in schizophrenic patients. The CGI-I evaluation is a single item
reflecting a subject's improvement at baseline compared with screening
and improvement at each visit compared with baseline. An increase in
CGI-I score reflects symptomatic improvement in schizophrenic
patients. |
| Global Assessment of Functioning Scale (GAF):
This instrument considers psychological, social, and occupational
functioning on a hypothetical continuum of mental health status. An
increase in GAF score reflects symptomatic improvement in
schizophrenic patients. |
| Montgomery-Asberg Depression Rating Scale (MADRS):
This scale consisted of 10 items assessing symptoms associated with
clinical depression. |
________
Posted 10/2000 |