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Issue dated - 03rd October 2002

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Ups and downs in drug development

Drug manufacturers must provide scientifically accurate information, written in non-technical language, for doctors and patients, says Dr Krishan Maggon

Among the responses received to my earlier articles, one of the key points made was that all ragaglitazar related events were part of a normal drug development process. The ups and down are part of all new drug development cycles just as in human lives. Very few drugs on the starting blocks make it to the market. The Indian discovered drugs must show superior safety and efficacy profile in comparison to existing drugs as well as drugs in development. There are few if any absolutes in terms of safety of drugs. Aspirin the best known and most used is well tolerated by many but poses a risk to some.

Health and regulatory authorities like the FDA/EMEA, in each instance, weigh the potential benefits of drugs against the risks that they carry. For that reason, the safety and effectiveness of drugs is a relative thing and not a matter of absolute truths. Of course, even FDA approval is no guarantee of safety and effectiveness. Eight new drugs approved since the mid-1990s have subsequently been withdrawn from the market for safety reasons. Seven of these deadly drugs were covered by David Willman in LA Times articles.

Nonetheless, the FDA’s review ensures an objective scientific evaluation of the relative safety of proposed products and the health claims. The FDA does not approve drugs generally; it approves them for specific indications. This Glitazone article attempted to provide a balanced information, written in non-technical language, for doctors and patients.

Disseminating critical information

Doctors are likely to prescribe these drugs inappropriately because they have not been provided any of this critical information. That could seriously jeopardize patient health. The frequency of adverse drug reaction in the FDA/EMEA approved prescribing information is based on patients treated for 3-6 months only. The rate increases when data is collected for patients treated with one year, with even higher incidences expected over longer durations of use.

Physicians are not qualified to choose drugs for their patients without the help of experts (FDA/EMEA) in weeding out ineffective drugs and leaving only drugs whose efficacy has been proven in the market. The Indian pharmaceutical market or regulatory authorities have failed to weed out worthless or dangerous drugs, misleadingly promoted for unsubstantiated uses. Markets do fail, particularly those that are characterized by imperfect information, such as the pharmaceutical marketplace in India.

There is an urgent need for drug manufacturers to provide scientifically accurate information, written in non-technical language, for doctors and patients with each new and refill prescription for all prescription drugs, in the form of Medication Guides approved by the Drug Controller of India. The standard bioassay protocols currently enlisted to evaluate cancer-causing chemicals in animal model systems, incorporate two basic assumptions:

  • A chemical that causes cancer in rats and mice has a high probability of causing cancer in humans (interspecies extrapolation);
  • Chemicals that cause cancer when administered at high doses will also cause cancer when administered at low doses (dose extrapolation).

Carcinogenic tests

The default assumption is that positive effects in animal cancer studies indicate that the agent under study can have carcinogenic potential in humans. Thus, if no adequate human data are present, positive effects in animal cancer studies are a basis for assessing the carcinogenic hazard to humans. This assumption is a public health conservative policy, and it is both appropriate and necessary given that we do not test for carcinogenicity in humans. The assumption is supported by the fact that nearly all of the agents known to cause cancer in humans are carcinogenic in animals in tests with adequate protocols.

Moreover, almost one-third of human carcinogens were identified subsequent to animal testing. Further support is provided by research on the molecular biology of cancer processes, which has shown that the mechanisms of control of cell growth and differentiation are remarkably homologous among species and highly conserved in evolution. Cohen thrust the issue of risk assessment into the limelight with a 1990 paper (S M Cohen, et al, Science, 249:1007,1990).

In the case of saccharin, which causes bladder tumours in male rats when administered at high doses, the tumours are linked to the presence of a protein in urine (au-globulin) to which saccharin binds. The tumours occur as a regenerative effect following erosion of the superficial bladder epithelial cells. The erosion is attributed to a precipitate in the urine generated when saccharin binds to the protein.

However, a2u-globulin is specific to male rats and is not present in female rats, mice, or humans. On the basis of mechanistic considerations alone, humans are unlikely to develop bladder cancer as a consequence to exposure of saccharin, even if humans consumed levels as high as those consumed by the rat (S M Cohen, et al, Chemical Research in Toxicology, 5:742, 1992). Genotoxic agents cause cancer by interacting with DNA and affecting the rate of genetic damage. Nongenotoxic agents cause cell proliferation, increasing the risk of cancer because with each cell DNA replication cycle there is a small but nonzero risk of genetic damage (M C Poirier, Chem Res Toxicol, 5:749, 1992).

One study looks at the levels of dG-C8-ABP, the major DNA adduct produced by an aromatic amine found in cigarette smoke, 4-aminobiphenyl (4-ABP), and the concomitant bladder tumour incidences in male mice, compared with the DNA adducts measured in the bladders of human cigarette smokers and the increased risk of bladder cancer in male cigarette smokers. The comparison shows that a 50 per cent bladder tumour incidence in mice is associated with levels of dG- C8-ABP that are nearly 200 times higher than those projected for a 50 per cent bladder tumour incidence in humans.

There may be instances in which the use of an animal model would identify a hazard in animals that is not truly a hazard in humans (eg, the alpha-2u-globulin association with renal neoplasia in male rats (US EPA, 1991b). The extent to which animal studies may yield false positive indications for humans is a matter of scientific debate. To demonstrate that a response in animals is not relevant to any human situation, adequate data to assess the relevancy issue must be available. It is recognized that animal studies (and epidemiologic studies as well) have very low power to detect cancer effects. Detection of a 10 per cent tumour incidence is generally the limit of power with currently conducted animal studies.

Differences in metabolism

There are important differences between rat metabolism and mouse metabolsm, so the same mechanism may not apply. In the case of melamine, the chemical produced bladder tumour in rats linked to bladder stones. However in mice, it caused inflammation and epithelial hyperplasia of the urinary bladder in male mice and bladder stones but no tumours. In female mice only stones were observed without any carcinoma.

The default is to include benign tumours observed in animal studies in the assessment of animal tumour incidence if they have the capacity to progress to the malignancies with which they are associated. This treats the benign and malignant tumours as representative of related responses to the test agent, which is scientifically appropriate. Benign tumours that are not observed to progress to malignancy deserve attention because they are serious health problems even though they are not malignant; for instance, benign tumours may be a health risk because of their effect on the function of a target tissue such as the brain.

The trials with ragaglitazar were halted because the mouse tumor could not
be ignored and the mechanism of its formation is not known. The press
release by Novo Nordisk pointed that only one mouse developed the bladder
tumor. But the Novo release makes no mention of dose level and was it
female or male animal. The company has not released information about the
incidence of benign tumor or any precancerous cell changes. The press
release did not mention that one out of ten animalsworks out to a 10 per
cent incidence, which is the lowest power of detection of carcinogenic
studies. The standard GLP carcinogenic study, requires 50 females and 50
males mice or rats per group per dose level, however only 10 animals of each
sex are sacrificed at a predetermined time point. To this the incidence of
benign tumors if any should be added. If a smaller number of animals (20
per dose group ie 10 males and 10 females) were used,it may work out to a
even higher incidence.Millions of patients are expected to take this drug
for prolonged periods therefore the carcinogenic potential remains a risk
unless proven otherwise. An inidence of 10% will mean, 100,000 patients with potential risk of having cancers, out of 1 millions patients and is a very
significant number. Under the US legal system any patients on the new drug a confirmed carcinogen in rodents, who develops cancer is likely to sue and
win class action, product injury and liability awards which may bankrupt
any drug company. Death, liver failure, heart attacks, cardiac failure and
cancer are not acceptable side effects for any antidiabetic drugs.

Sara Brudnoy. Pushing For A Paradigm Shift In Cancer Risk Assessment. The
Scientist 7[5]:14, Mar. 08, 1993

U.S. Environmental Protection Agency, Washington, DC. Proposed Guidelines
for Carcinogen Risk Assessment. EPA/600/P-92/003C. April 1996.
http://www.epa.gov/ORD/WebPubs/carcinogen/carcin.pdf.

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