Title: Abraxane
1Abraxanefor the adjuvant treatment of
node-positive breast cancer
- Oncologic Drugs Advisory Committee Meeting
- September 7, 2006
2Purpose of the Meeting
- To determine if, under the 505(b)(2) pathway, an
efficacy trial in the adjuvant treatment of
node-positive breast cancer is required to
approve Abraxane in this setting
3505(b)(2) Regulatory Pathway
- 505(b)(1) Typical way most new drugs are
approved all investigations from sponsor - 505(b)(2) Used for new formulations of existing
drugs applicant may rely on investigations to
which it does not own or have the right of
reference (e.g. information in the published
literature or in approved NDAs for the RLD) - 505(j) For generic drugs that are the same as
the established drug (the Reference Listed Drug
RLD)
4FDA Position Regarding 505(b)(2)
- FDAs longstanding interpretation of section
505(b)(2) the Agencys approach is to use the
505(b)(2) drug approval pathway to avoid
requiring drug sponsors to conduct and submit
studies that are not scientifically necessary. - The conduct and review of duplicative studies
would . slow the process for drug approval with
no corresponding benefit to the public health.
Source Woodcock 2003 Response to Citizens
Petition regarding 505(b)(2)
5505(b)(2) Avoids Significant Delays inDrug
Approval
- FDA has approved more than 80 section 505(b)(2)
applications for drugs for indications ranging
from cancer pain to attention deficit disorder.
Many of these drugs would never have reached the
market, or would have been significantly delayed,
without the 505(b)(2) pathway.
Source Woodcock 2003 Response to Citizens
Petition regarding 505(b)(2)
6Unique Set of Circumstances for Abraxane
- Active ingredient, paclitaxel, is identical
- Paclitaxel already approved as Adjuvant Rx(Taxol
175 mg/m2) - Abraxane delivers a higher dose of
paclitaxel(260 mg/m2) - Superior anti-tumor activity demonstrated in
metastatic breast cancer - Tolerability of higher Abraxane dose comparable
to lower Taxol dose - Abraxane was approved in metastatic breast cancer
under 505(b)(2) - FDA approach is to use 505(b)(2) to avoid.
studies that are not scientifically necessary
7Position of Abraxis BioScience
- Abraxis believes that an efficacy trial in the
adjuvant treatment of breast cancer is not
scientifically necessary and would
significantly delay the approval of a
Cremophor-free paclitaxel alternative - Abraxis is committed to conduct a comparative
safety trial of Abraxane vs Taxol for women with
node-positive breast cancer
8Reasons that an Efficacy Adjuvant Trial Should
not be Required for Approval of Abraxane
Abraxane is Cremophor-free Formulation of
Paclitaxel
Removing Cremophor Allows Safe Delivery of Higher
Doses of Paclitaxel
Therefore, there is no scientific basis to
hypothesize that Abraxane will be less effective
than Taxol as adjuvant therapy
In Metastatic Breast Cancer Abraxane has Greater
Anti-tumor Activitythan Taxol
Paclitaxel is Approved forAdjuvant Use (Taxol)
The Abraxane Dose of Paclitaxel is Safe and
Higher than that Already Proven Effective in the
Adjuvant Setting
9Reasons that an Efficacy Adjuvant Trial Should
not be Required for Approval of Abraxane
Abraxane is Cremophor-free Formulation of
Paclitaxel
Removing Cremophor Allows Safe Delivery of Higher
Doses of Paclitaxel
In Metastatic Breast Cancer Abraxane has Greater
Anti-tumor Activitythan Taxol
Paclitaxel is Approved forAdjuvant Use (Taxol)
The Abraxane Dose of Paclitaxel is Safe and
Higher than that Already Proven Effective in the
Adjuvant Setting
10Development of Paclitaxel FormulationsHistorical
Background
- Paclitaxel, one of the most active cytotoxic
agents - Cremophor required at high concentrations
(Taxol and generic equivalents) - In the 1990s, Abraxis developed a paclitaxel
formulation that replaced Cremophor with Albumin
(Abraxane) - Preclinical studies subsequently demonstrated
that Abraxane significantly improved the
therapeutic index of paclitaxel with - Less toxicity due to removal of Cremophor
- Higher paclitaxel dose
- Higher intra-tumoral paclitaxel concentration
- Higher efficacy in multiple tumor types
11Basis of FDA Approval of Abraxane for Metastatic
Breast Cancer
- 2001 FDA agreed that Abraxane could receive
approval in MBC (same indication as Taxol)
provided two issues were satisfied - That replacement of Cremophor with albumin did
not result in a decrease in efficacy of
paclitaxel - That the higher dose 260 mg/m2 of Abraxane could
be administered with comparable tolerability to
Taxol at175 mg/m2 - 2004 Randomized Phase 3 Trial proved superior
anti-tumor activity of Abraxane with comparable
tolerability at higherdose than Taxol - 2005 FDA granted approval for metastatic breast
cancerunder the 505(b)(2) regulatory pathway for
new formulationsof existing drugs
12Reasons that an Efficacy Adjuvant Trial Should
not be Required for Approval of Abraxane
Abraxane is Cremophor-free Formulation of
Paclitaxel
Removing Cremophor Allows Safe Delivery of Higher
Doses of Paclitaxel
Therefore, there is no scientific basis to
hypothesize that Abraxane will be less effective
than Taxol as adjuvant therapy
In Metastatic Breast Cancer Abraxane has Greater
Anti-tumor Activitythan Taxol
Paclitaxel is Approved forAdjuvant Use (Taxol)
The Abraxane Dose of Paclitaxel is Safe and
Higher than that Already Proven Effective in the
Adjuvant Setting
13Abraxane is Albumin-bound Cremophor-free
Paclitaxel
Albumin
cryo-TEM
Paclitaxel exists in the albumin particle in an
non-crystalline, amorphous state
Mean 130 nm
Concentration dependent dissociation into
individual paclitaxel-bound albumin molecules
Paclitaxel
14The Active Ingredient in Abraxane and Taxol is
Identical
Abraxane is a Cremophor-free Formulation of
Paclitaxel Received FDA Approval January,
2005 for metastatic breast cancer
Reconstituted Paclitaxel 5 mg/ml Albumin 45
mg/ml No Solvents
Supplied As Paclitaxel 6 mg/ml Cremophor 537
mg/ml Ethanol 396 mg/ml
15Abraxane was Developed to Eliminate
Cremophor-induced Hypersensitivity Reactions
- Anaphylaxis and severe hypersensitivity
reactionshave occurred in 2-4 of patients
receiving Taxol in clinical trials
- Fatal reactions have occurred in patients
despite premedication
Taxol Package Insert
Common Steroid Side Effects when Given as
Premedication
- Hyperglycemia
- Glucose intolerance in diabetics
- Mood changes
- Insomnia
16Abraxane was Developed to Eliminate
Cremophor-induced Hypersensitivity Reactions
- Anaphylaxis and severe hypersensitivity
reactionshave occurred in 2-4 of patients
receiving Taxol in clinical trials
- Fatal reactions have occurred in patients
despite premedication
Taxol Package Insert
- No premedication to prevent hypersensitivity
reactions is required prior to administration of
Abraxane
Abraxane Package Insert
17Removal of Cremophor Results in Different PK for
Taxol and Abraxane
Abraxane is Cremophor-free Formulation of
Paclitaxel
- PK linearity
- Alterations in distribution phase
18Cremophor Entraps Paclitaxel in Micelles in the
Plasma Compartment
Control plasma Plasma Taxol
CremophorMicelle
- Paclitaxel is entrapped in Cremophor micelles
- This results in non-linear paclitaxel PK for Taxol
Sparreboom A et al. Cancer Research,
19995914541457. van Tellingen O et al
British Journal of Cancer, 1999 81330-35.
19Paclitaxel PK for Abraxane are Linear
Abraxane
Taxol
(1) Kearns, C. M., Pharmacotherapy, 1997 (2)
Taxol Package insert (3) Mross et al, Cancer
Chemother Pharm 2000
Source Abraxane NDA
20Cremophor Alters the Distribution PhasePK of
Paclitaxel
Source Abraxane NDA and Sparreboom et al., 2005,
CCR
21Reasons that an Efficacy Adjuvant Trial Should
not be Required for Approval of Abraxane
Abraxane is Cremophor-free Formulation of
Paclitaxel
Removing Cremophor Allows Safe Delivery of Higher
Doses of Paclitaxel
Therefore, there is no scientific basis to
hypothesize that Abraxane will be less effective
than Taxol as adjuvant therapy
In Metastatic Breast Cancer Abraxane has Greater
Anti-tumor Activitythan Taxol
Paclitaxel is Approved forAdjuvant Use (Taxol)
The Abraxane Dose of Paclitaxel is Safe and
Higher than that Already Proven Effective in the
Adjuvant Setting
22Reasons that an Efficacy Adjuvant Trial Should
not be Required for Approval of Abraxane
Abraxane is Cremophor-free Formulation of
Paclitaxel
Removing Cremophor Allows Safe Delivery of Higher
Doses of Paclitaxel
Therefore, there is no scientific basis to
hypothesize that Abraxane will be less effective
than Taxol as adjuvant therapy
260 mg/m2 Q3W Phase 3 MBC
260 mg/m2 Q2W Adjuvant setting
23Abraxane can Deliver Higher Paclitaxel Dosewith
Comparable Tolerability to Taxol
CA012 Randomized Phase 3 Trial in Metastatic Breast Cancer Abraxane 260 mg/m2n 229 Taxol 175 mg/m2 n 225
Median cycles/patient 6 5
Percentage of planned dose 98 98
Mean paclitaxel dose intensity q3w 255 mg/m2 171 mg/m2
The tolerability of Abraxane was equivalent to
that of Taxol at a 50 higher DELIVERED dose.
24Abraxane and Taxol have Comparable Overall
Toxicity Profiles
Abraxane 260 mg/m2 Taxol 175 mg/m2n 229 n 225
Percentage of Patients
All Cycles
After 4 Cycles
25Tolerable GI Toxicities for Abraxane and Taxol
Adverse Event Drug Percentage of Patients by Grade Percentage of Patients by Grade Percentage of Patients by Grade Percentage of Patients by Grade P-value
Adverse Event Drug 1 2 3 4 P-value
Nausea Taxol 12 8 lt1 0 0.039
Nausea Abraxane 19 7 3 0 0.039
Vomiting Taxol 4 4 1 0 0.022
Vomiting Abraxane 10 4 3 lt1 0.022
Diarrhea Taxol 11 3 1 0 0.006
Diarrhea Abraxane 17 9 lt1 0 0.006
Cochran-Mantel-Haenszel test
26Taxane and Cremophor Related Toxicities
Adverse Event Drug Percentage of Patients by Grade Percentage of Patients by Grade Percentage of Patients by Grade Percentage of Patients by Grade P-value
Adverse Event Drug 1 2 3 4 P-value
Neutropenia Taxol 10 19 32 22 lt 0.001
Neutropenia Abraxane 21 25 32 9 lt 0.001
Hypersensitivity Reactions Taxol 8 3 2 0 0.001
Hypersensitivity Reactions Abraxane 3 lt1 0 0 0.001
Peripheral Neuropathy Taxol 43 10 2 0 lt 0.001
Peripheral Neuropathy Abraxane 41 20 10 0 lt 0.001
Cochran-Mantel-Haenszel test
27Improvement from Grade 3 Sensory Neuropathy and
Resumption of Treatment with Abraxane (n 24)
1.00 0.75 0.50 0.25 0.00
10/14 patients resumed Abraxane at a lower dose
Median 22 days
Proportion not resolved
0 10 20 30 40 50 60 70 80 90 100 110 120 130
Days since grade 3 to improvement
Source Abraxane NDA. Censored (n 10 patients)
28Reasons that an Efficacy Adjuvant Trial Should
not be Required for Approval of Abraxane
Abraxane is Cremophor-free Formulation of
Paclitaxel
Removing Cremophor Allows Safe Delivery of Higher
Doses of Paclitaxel
Therefore, there is no scientific basis to
hypothesize that Abraxane will be less effective
than Taxol as adjuvant therapy
260 mg/m2 Q3W Phase 3 MBC
260 mg/m2 Q2W Adjuvant setting
29Results of a Pilot Adjuvant Trial of Dose Dense
Abraxane
- CA030 U.S. Oncology (P.I. Nicholas Robert)
- Dose Dense AC x 4 ? Abraxane x 4 (all cycles q2w)
- Abraxane dose 260 mg/m2
- 30 received AC 29 received Abraxane
- 27/29 (93) received all 4 Abraxane cycles
- Comparable to Taxol q 3 weeks
- Mean cumulative dose 962 mg/m2
- Well tolerated without unexpected toxicity
- Peripheral neuropathy prospectively monitored and
followed to resolution - 28/29 (97) patients asymptomatic 8 months
following treatment
3028/29 (97) Patients were Asymptomatic
fromPeripheral Neuropathy within 8 Months
Following Dose Dense Abraxane at 260 mg/m2
- 59 asymptomatic at end of 4 cycle RX
- 75 2 months p Rx
- 97 8 months p Rx
Proportion Asymptomatic
Grade 0 or 1 per NCI CT CAE
Months
31Ongoing Adjuvant Safety Trials
Institution P.I. Design N
US Oncology JohnPippen dd AC x 4 cycles?dd Taxol or Abraxane x 4 cyclesRandomized, with Bevacizumab N 4 of 200 (Accrual ongoing)
Dana Farber (DFCI) Harold Burstein dd AC x 4? dd Abraxane 260 mg/m2 x 4 N 39 of 50(Accrual ongoing)
MSKCC and UCSF Maura Dickler and Hope Rugo dd AC x 4 Bevacizumab ?dd Abraxane 260 mg/m2 x 4 Bevacizumab? Bevacizumab N 12 of 75(Accrual ongoing)
University of Washington Georgiana Ellis Wkly Doxorubicin oral Cy?Wkly Abraxane 100 mg/m2 x 12 /- Trastuzumab N 1 of 60(Accrual ongoing)
NSABP André Robidoux ABX 100 mg/m2 wkly x12?FEC x 4 /- Trastuzumab? surgery N 67 of 67(Accrual completed)
32Design of Proposed Comparative Safety Study using
the Approved Dosing Schedules of Abraxane and
Taxol
- Objective
- Describe safety profiles of Abraxane and Taxol in
Adjuvant Breast Cancer following AC x 4
Abraxane 260 mg/m2 IV over 30 min q 3 wk No
Standard Premedication
AC x 4 cycles
x 4 cycles
Randomization
Taxol 175 mg/m2IV over 3 hrs q 3 wk Standard
Premedication with Dexamethasone and
Anti-histamines
Final design to be agreed upon with FDA
33How Similar or Dissimilar are Taxol and Abraxane?
- The active ingredient in both formulations is
paclitaxel - Administration Differences
- Cremophor-related HSRs are eliminated with
Abraxane - No steroid premedication required with Abraxane
- Standard IV tubing with shorter infusion time
- Differences in PK due to paclitaxel sequestration
by Cremophor - The removal of Cremophor permits delivery of a
50 higher dose of paclitaxel than that of Taxol - Despite higher dose the tolerability of Abraxane
is comparable to that of Taxol - Abraxane demonstrated higher anti-tumor activity
than Taxol in metastatic breast cancer
34Reasons that an Efficacy Adjuvant Trial Should
not be Required for Approval of Abraxane
Abraxane is Cremophor-free Formulation of
Paclitaxel
Removing Cremophor Allows Safe Delivery of Higher
Doses of Paclitaxel
Therefore, there is no scientific basis to
hypothesize that Abraxane will be less effective
than Taxol as adjuvant therapy
In Metastatic Breast Cancer Abraxane has Greater
Anti-tumor Activitythan Taxol
Paclitaxel is Approved forAdjuvant Use (Taxol)
The Abraxane Dose of Paclitaxel is Safe and
Higher than that Already Proven Effective in the
Adjuvant Setting