Nonprescription Orlistat Nonprescription Orlistat GlaxoSmithKline Consumer Healthcare, GlaxoSmithKline Consumer Healthcare, Ltd Ltd New Drug Application (21-887) New Drug Application (21-887) Joint Nonprescription Drugs Advisory Joint Nonprescription Drugs Advisory Committee and Endocrinologic and Metabolic Committee and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Drugs Advisory Committee Meeting Bethesda, Maryland Bethesda, Maryland January 23, 2006 January 23, 2006 Julie Golden, M.D. Julie Golden, M.D. Division of Metabolic and Endocrine Products Division of Metabolic and Endocrine Products Center for Drug Evaluation and Research Center for Drug Evaluation and Research
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Nonprescription Orlistat GlaxoSmithKline Consumer Healthcare, Ltd New Drug Application (21-887) Joint Nonprescription Drugs Advisory Committee and Endocrinologic.
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Julie Golden, M.D. Julie Golden, M.D. Division of Metabolic and Endocrine ProductsDivision of Metabolic and Endocrine Products
Center for Drug Evaluation and ResearchCenter for Drug Evaluation and Research
2Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
3Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
BackgroundBackgroundBackgroundBackground
4Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Definitions: Overweight and ObesityDefinitions: Overweight and ObesityDefinitions: Overweight and ObesityDefinitions: Overweight and Obesity
• For this application:– Low overweight: BMI 25 – < 28 kg/m²– High overweight: BMI 28 – 29.9 kg/m²
5Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Orlistat LabelOrlistat LabelNonprescription vs. PrescriptionNonprescription vs. Prescription
Orlistat LabelOrlistat LabelNonprescription vs. PrescriptionNonprescription vs. Prescription
NonprescriptionGSK
PrescriptionRoche
Indication Promotion of weight loss when used along with a reduced calorie and low fat diet
Obesity management including weight loss, weight maintenance, and prevention of weight regain when used in conjunction with a reduced-calorie diet
Population “Overweight” (defined by the consumer)≥ 18 yo
Duration of use Up to 6 mos Chronic (clinical data up to 4 yrs)
Dose 60 mg; 1-2 capsules TID 120 mg TID
6Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
National Institutes of Health’s 2000 National Institutes of Health’s 2000 Practical Practical Guide: Identification, Evaluation, and Guide: Identification, Evaluation, and
Treatment of Overweight and Obesity in Treatment of Overweight and Obesity in AdultsAdults
National Institutes of Health’s 2000 National Institutes of Health’s 2000 Practical Practical Guide: Identification, Evaluation, and Guide: Identification, Evaluation, and
Treatment of Overweight and Obesity in Treatment of Overweight and Obesity in AdultsAdults
• Weight loss through diet and exercise– Obese – Overweight + comorbidities– High-risk waist circumference + comorbidities
• Pharmacotherapy– Only if lifestyle changes do not promote weight
loss after 6 months• Obese (≥ 30 kg/m²)• BMI ≥ 27 kg/m² + comorbidities
• Weight loss through diet and exercise– Obese – Overweight + comorbidities– High-risk waist circumference + comorbidities
• Pharmacotherapy– Only if lifestyle changes do not promote weight
loss after 6 months• Obese (≥ 30 kg/m²)• BMI ≥ 27 kg/m² + comorbidities
7Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
FDA’s Efficacy Criteria of FDA’s Efficacy Criteria of Prescription Weight-Loss DrugsPrescription Weight-Loss Drugs
FDA’s Efficacy Criteria of FDA’s Efficacy Criteria of Prescription Weight-Loss DrugsPrescription Weight-Loss Drugs
• Mean % weight loss (drug group) – mean % weight loss (placebo group) ≥ 5%, OR
• The proportion of subjects who reach and maintain a loss ≥ 5% of baseline body weight is statistically greater in drug group vs. placebo group
• Mean % weight loss (drug group) – mean % weight loss (placebo group) ≥ 5%, OR
• The proportion of subjects who reach and maintain a loss ≥ 5% of baseline body weight is statistically greater in drug group vs. placebo group
FDA 1996 Draft Guidance for the Clinical Evaluation of Weight-Control Drugs
8Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
• Behavioral Modification Effect– Claim: patients favorably modify their diet due to
GI side effects– Patients may also decrease drug use because of
side effects
• The incidence of GI side effects is similar across different amounts of weight loss– Consume more fat: drug effect– Consume less fat: dietary/behavioral effect
• Behavioral Modification Effect– Claim: patients favorably modify their diet due to
GI side effects– Patients may also decrease drug use because of
side effects
• The incidence of GI side effects is similar across different amounts of weight loss– Consume more fat: drug effect– Consume less fat: dietary/behavioral effect
9Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
EfficacyEfficacyEfficacyEfficacy
10Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
11Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Regular counseling by dietician; food records returned monthly
No counseling; self-instructional; videos; food records returned every 2 mos
Self-instructional; dietary review; food records returned monthly
12Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
13Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
% of Subjects by BMI Group% of Subjects by BMI Group% of Subjects by BMI Group% of Subjects by BMI Group
< 28 kg/m² 28 - < 30 kg/m² ≥ 30 kg/m²
BM14149N = 729
2.5% 13.2% 84.4%
NM14161N = 642
0% 7.2% 92.8%
NM17247N = 391
89.3% 10.7% 0%
14Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Categorical Weight Loss Results – LOCFCategorical Weight Loss Results – LOCFCategorical Weight Loss Results – LOCFCategorical Weight Loss Results – LOCFPercent of Subjects Achieving At Least 5%
Weight Loss
0102030405060708090
100
Pooled studies BMI 28-43
(6 mos)
Pooled studies BMI 28-43
(4 mos)
Study NM17247 BMI 25-28
(4 mos)
%Placebo
Orlistat 60
Orlistat 120* **
*
* p < 0.05 vs. placebo
15Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Weight Change from Baseline – LOCFWeight Change from Baseline – LOCFWeight Change from Baseline – LOCFWeight Change from Baseline – LOCF
16Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Placebo-Subtracted Difference in Placebo-Subtracted Difference in Weight Change from Baseline (kg) and Weight Change from Baseline (kg) and
95% CI – LOCF95% CI – LOCF
Placebo-Subtracted Difference in Placebo-Subtracted Difference in Weight Change from Baseline (kg) and Weight Change from Baseline (kg) and
17Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Weight Regain – 2 year dataWeight Regain – 2 year dataWeight Regain – 2 year dataWeight Regain – 2 year data
First year: hypocaloric diet; Second year: eucaloric diet
• Pooled studies: BM14149 and NM14161– Orlistat or placebo for 2 years
• Additional study from Rx NDA, published in JAMA 1999– Orlistat or placebo for 1 year– 2nd year:
First year: hypocaloric diet; Second year: eucaloric diet
• Pooled studies: BM14149 and NM14161– Orlistat or placebo for 2 years
• Additional study from Rx NDA, published in JAMA 1999– Orlistat or placebo for 1 year– 2nd year:
Placebo Placebo
OrlistatPlacebo
Orlistat
18Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Pooled StudiesPooled StudiesWeight Change Over 2 Years – CompletersWeight Change Over 2 Years – Completers
Pooled StudiesPooled StudiesWeight Change Over 2 Years – CompletersWeight Change Over 2 Years – Completers
0 24 52 76 104WEEK
-10
-8
-6
-4
-2
0
2
4
We
igh
t c
ha
ng
e f
rom
ba
se
line
(k
g)
0 24 52 76 104WEEK
BM14149BM14149 NM14161NM14161TRT:
120 mg tid60 mg tidPlacebo
19Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Weight Control and Risk Factor Reduction in Weight Control and Risk Factor Reduction in Obese Subjects Treated for 2 Years With Orlistat: Obese Subjects Treated for 2 Years With Orlistat:
A Randomized Controlled TrialA Randomized Controlled Trial
Weight Control and Risk Factor Reduction in Weight Control and Risk Factor Reduction in Obese Subjects Treated for 2 Years With Orlistat: Obese Subjects Treated for 2 Years With Orlistat:
A Randomized Controlled TrialA Randomized Controlled Trial
20Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Mean Body Weight Change During 2 Years of Double-Blind Treatment –– Completers
Mean Body Weight Change During 2 Years of Double-Blind Treatment –– Completers
Adapted from: Davidson, MH, et al. JAMA 1999;281:235-242
21Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Randomized Trial of Lifestyle Modification Randomized Trial of Lifestyle Modification and Pharmacotherapy for Obesityand Pharmacotherapy for Obesity
Randomized Trial of Lifestyle Modification Randomized Trial of Lifestyle Modification and Pharmacotherapy for Obesityand Pharmacotherapy for Obesity
Primary care provider + weekly group meetings w/trained psychologist
30 visits/90 min +8 visits/10-15 min
yes
Drug + Brief Therapy
Primary care provider 8 visits/10-15 min yes
Intensive Therapy
Weekly group meetings w/trained psychologist
30 visits/90 min yes
Drug Alone Primary care provider 8 visits/10-15 min no
Wadden TA, et al. N Engl J Med 2005; 353:2111-20
22Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Results of Lifestyle Modification Study – LOCFResults of Lifestyle Modification Study – LOCFResults of Lifestyle Modification Study – LOCFResults of Lifestyle Modification Study – LOCF
Weight % SubjectsChange w/ 5% loss
Drug + Intensive Therapy -12.1 kg 73%Drug + Brief Therapy -7.5 kg 56%Intensive Therapy -6.7 kg 53%Drug -5.0 kg 42%
Wadden TA, et al. N Engl J Med 2005; 353:2111-20
Weight % SubjectsChange w/ 5% loss
Drug + Intensive Therapy -12.1 kg 73%Drug + Brief Therapy -7.5 kg 56%Intensive Therapy -6.7 kg 53%Drug -5.0 kg 42%
Wadden TA, et al. N Engl J Med 2005; 353:2111-20
23Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
SafetySafetySafetySafety
24Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
• Studies from original Rx NDA (pooled): BM14149, NM14161, NM14302
• New study: NM17247
• Supportive studies: BM14150, Actual Use Trial, Consumer Use Study
• Post-marketing data: FDA Adverse Event Reporting System (AERS)
• Published literature
• Review of original Rx orlistat NDA
• Studies from original Rx NDA (pooled): BM14149, NM14161, NM14302
• New study: NM17247
• Supportive studies: BM14150, Actual Use Trial, Consumer Use Study
• Post-marketing data: FDA Adverse Event Reporting System (AERS)
• Published literature
• Review of original Rx orlistat NDA
25Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Pooled Safety StudiesPooled Safety StudiesPooled Safety StudiesPooled Safety Studies
26Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Safety Issues for DiscussionSafety Issues for DiscussionSafety Issues for DiscussionSafety Issues for Discussion
• Fat-soluble vitamins
• Drug interactions
• Pancreatitis
• Fat-soluble vitamins
• Drug interactions
• Pancreatitis
27Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Study BM14149 (No MVI)Study BM14149 (No MVI)Mean Change in Vitamin Concentrations Over TimeMean Change in Vitamin Concentrations Over Time
Study BM14149 (No MVI)Study BM14149 (No MVI)Mean Change in Vitamin Concentrations Over TimeMean Change in Vitamin Concentrations Over Time
Vitamin A (retinol)
-0.05
0
0.05
0.1
0.15
0.2
0.25
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin A (retinol)
-0.05
0
0.05
0.1
0.15
0.2
0.25
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin D (25-OH vitamin D)
-5
0
5
10
15
20
Day 1 Week 24 Week 52
nm
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin D (25-OH vitamin D)
-5
0
5
10
15
20
Day 1 Week 24 Week 52
nm
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin E (alpha-tocopherol)
-2-1.5
-1-0.5
00.5
11.5
2
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin E (alpha-tocopherol)
-2-1.5
-1-0.5
00.5
11.5
2
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Beta-carotene
-0.2
-0.15
-0.1
-0.05
0
0.05
0.1
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Beta-carotene
-0.2
-0.15
-0.1
-0.05
0
0.05
0.1
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
**
**
**
* p < 0.001 vs. placebo
28Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Study NM14161 (No MVI)Study NM14161 (No MVI)Mean Change in Vitamin Concentrations Over TimeMean Change in Vitamin Concentrations Over Time
Study NM14161 (No MVI)Study NM14161 (No MVI)Mean Change in Vitamin Concentrations Over TimeMean Change in Vitamin Concentrations Over Time
Vitamin A
-0.1
0
0.1
0.2
0.3
0.4
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin A
-0.1
0
0.1
0.2
0.3
0.4
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin D
-15
-10
-5
0
5
Day 1 Week 24 Week 52
nm
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin D
-15
-10
-5
0
5
Day 1 Week 24 Week 52
nm
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin E
-1.5-1
-0.50
0.51
1.52
2.53
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin E
-1.5-1
-0.50
0.51
1.52
2.53
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Beta-carotene
-0.15
-0.1
-0.05
0
0.05
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Beta-carotene
-0.15
-0.1
-0.05
0
0.05
Day 1 Week 24 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
*
*
**
†
* p < 0.05 vs. placebo; † p < 0.10 vs. placebo
29Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Study NM14302 (+ MVI)Study NM14302 (+ MVI)Mean Change in Vitamin Concentrations Over TimeMean Change in Vitamin Concentrations Over Time
Study NM14302 (+ MVI)Study NM14302 (+ MVI)Mean Change in Vitamin Concentrations Over TimeMean Change in Vitamin Concentrations Over Time
Vitamin A
-0.05
0
0.05
0.1
0.15
0.2
0.25
Day 1 Week 20 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin A
-0.05
0
0.05
0.1
0.15
0.2
0.25
Day 1 Week 20 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin D
-20
-15
-10
-5
0
5
Day 1 Week 20 Week 52
nm
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin D
-20
-15
-10
-5
0
5
Day 1 Week 20 Week 52
nm
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin E
-4
-3
-2
-1
0
1
2
3
Day 1 Week 20 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Vitamin E
-4
-3
-2
-1
0
1
2
3
Day 1 Week 20 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Beta-carotene
-0.4
-0.3
-0.2
-0.1
0
0.1
Day 1 Week 20 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
Beta-carotene
-0.4
-0.3
-0.2
-0.1
0
0.1
Day 1 Week 20 Week 52
um
ol/
L Placebo
Orlistat 60
Orlistat 120
*
***
†
* p < 0.05 vs. placebo; † p < 0.10 vs. placebo
*
30Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Frequency of 2 Consecutive Plasma Vitamin Frequency of 2 Consecutive Plasma Vitamin Concentrations Below the Limit of the Concentrations Below the Limit of the
Reference Range after 1 Year of TreatmentReference Range after 1 Year of Treatment
Frequency of 2 Consecutive Plasma Vitamin Frequency of 2 Consecutive Plasma Vitamin Concentrations Below the Limit of the Concentrations Below the Limit of the
Reference Range after 1 Year of TreatmentReference Range after 1 Year of Treatment
31Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Drug InteractionDrug InteractionWarfarinWarfarin
Drug InteractionDrug InteractionWarfarinWarfarin
• No significant alteration of pharmacokinetics of warfarin
• Post-marketing, literature reports of prolonged prothrombin time
• Post-marketing reports of bleeding• 7 of 14 patients on warfarin initially
failed to identify that orlistat was inappropriate for their use
• No significant alteration of pharmacokinetics of warfarin
• Post-marketing, literature reports of prolonged prothrombin time
• Post-marketing reports of bleeding• 7 of 14 patients on warfarin initially
failed to identify that orlistat was inappropriate for their use
32Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Drug InteractionDrug InteractionCyclosporineCyclosporine
Drug InteractionDrug InteractionCyclosporineCyclosporine
• Weight gain is common after organ transplantation
• Orlistat-cyclosporine interaction study demonstrated decreased cyclosporine concentrations
• Post-marketing reports of decreased cyclosporine concentrations
• 2 cases of acute organ rejection: 1 mild, 1 moderate
• 1 of 2 patients on cyclosporine initially failed to identify that orlistat was inappropriate for use
• Weight gain is common after organ transplantation
• Orlistat-cyclosporine interaction study demonstrated decreased cyclosporine concentrations
• Post-marketing reports of decreased cyclosporine concentrations
• 2 cases of acute organ rejection: 1 mild, 1 moderate
• 1 of 2 patients on cyclosporine initially failed to identify that orlistat was inappropriate for use
33Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
PancreatitisPancreatitisPancreatitisPancreatitis
• FDA AERS Data– 99 raw reports of “pancreatitis” for
orlistat (30 US reports)– 8 raw reports of “pancreatitis” for
sibutramine (1 US report)• No increase in incidence of pancreatitis
in placebo-controlled trials of orlistat in patients treated for up to 4 years
• Review of issue is ongoing
• FDA AERS Data– 99 raw reports of “pancreatitis” for
orlistat (30 US reports)– 8 raw reports of “pancreatitis” for
sibutramine (1 US report)• No increase in incidence of pancreatitis
in placebo-controlled trials of orlistat in patients treated for up to 4 years
• Review of issue is ongoing
34Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
ConclusionsConclusionsConclusionsConclusions
35Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Efficacy ConclusionsEfficacy ConclusionsDose and PopulationDose and Population
Efficacy ConclusionsEfficacy ConclusionsDose and PopulationDose and Population
• Low overweight population at 4 months, orlistat 60 mg TID (Study NM17247)– Mean weight loss 1.1 kg– Primary Rx weight loss drug
efficacy criterion (categorical weight loss) was not met
• Low overweight population at 4 months, orlistat 60 mg TID (Study NM17247)– Mean weight loss 1.1 kg– Primary Rx weight loss drug
efficacy criterion (categorical weight loss) was not met
36Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Efficacy Conclusions Efficacy Conclusions Duration and LifestyleDuration and Lifestyle
Efficacy Conclusions Efficacy Conclusions Duration and LifestyleDuration and Lifestyle
• Pooled studies, obese and high overweight population (Study NM14161 and Study BM14149)– Greater overall weight loss was seen with
intensive lifestyle intervention (BM14149)– Smaller drug treatment and dose effect
was seen with intensive lifestyle intervention (BM14149)
– More weight regained over 2 years with less intensive lifestyle intervention (NM14161)
• Pooled studies, obese and high overweight population (Study NM14161 and Study BM14149)– Greater overall weight loss was seen with
intensive lifestyle intervention (BM14149)– Smaller drug treatment and dose effect
was seen with intensive lifestyle intervention (BM14149)
– More weight regained over 2 years with less intensive lifestyle intervention (NM14161)
37Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Efficacy Conclusions Efficacy Conclusions Duration and LifestyleDuration and Lifestyle
Efficacy Conclusions Efficacy Conclusions Duration and LifestyleDuration and Lifestyle
• Weight regain after discontinuation of orlistat (JAMA paper)
• Weight-loss drug more effective with lifestyle intervention (NEJM paper)
• Weight regain after discontinuation of orlistat (JAMA paper)
• Weight-loss drug more effective with lifestyle intervention (NEJM paper)
38Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
• A higher percentage of orlistat-treated subjects had 2 consecutive plasma fat-soluble vitamin concentrations below the lower limit after 1 year of treatment than placebo-treated subjects
• Prolonged orlistat use without appropriate supplementation may lead to clinically significant fat-soluble vitamin malabsorption– Bone– Warfarin
• A higher percentage of orlistat-treated subjects had 2 consecutive plasma fat-soluble vitamin concentrations below the lower limit after 1 year of treatment than placebo-treated subjects
• Prolonged orlistat use without appropriate supplementation may lead to clinically significant fat-soluble vitamin malabsorption– Bone– Warfarin
39Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Safety ConclusionsSafety ConclusionsImportant Drug InteractionsImportant Drug Interactions
Safety ConclusionsSafety ConclusionsImportant Drug InteractionsImportant Drug Interactions
• Warfarin– Reports of prolonged PT and bleeding likely
reflect vitamin K malabsorption and vitamin K insufficiency
• Cyclosporine– Reports of subtherapeutic cyclosporine
concentrations, organ rejection (2), reflect decreased cyclosporine absorption when taken with orlistat
• Actual use trial indicates that labeled warnings may not be adequately communicated
• Warfarin– Reports of prolonged PT and bleeding likely
reflect vitamin K malabsorption and vitamin K insufficiency
• Cyclosporine– Reports of subtherapeutic cyclosporine
concentrations, organ rejection (2), reflect decreased cyclosporine absorption when taken with orlistat
• Actual use trial indicates that labeled warnings may not be adequately communicated
40Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Safety ConclusionsSafety ConclusionsPancreatitis: Unclear Association with Pancreatitis: Unclear Association with
OrlistatOrlistat
Safety ConclusionsSafety ConclusionsPancreatitis: Unclear Association with Pancreatitis: Unclear Association with
OrlistatOrlistat
• No evidence from clinical studies that orlistat increases the risk for pancreatitis
• Increased number of AERS reports of pancreatitis in users of orlistat
• Investigation ongoing
• No evidence from clinical studies that orlistat increases the risk for pancreatitis
• Increased number of AERS reports of pancreatitis in users of orlistat
• Investigation ongoing
41Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
Do you believe that the potential Do you believe that the potential benefits of nonprescription orlistat benefits of nonprescription orlistat
outweigh the risks?outweigh the risks?
Do you believe that the potential Do you believe that the potential benefits of nonprescription orlistat benefits of nonprescription orlistat
outweigh the risks?outweigh the risks?
42Joint Nonprescription Drugs and Endocrinologic and Joint Nonprescription Drugs and Endocrinologic and Metabolic Drugs Advisory Committee Meeting Metabolic Drugs Advisory Committee Meeting January 23, 2006
AcknowledgementsAcknowledgementsAcknowledgementsAcknowledgements• DMEP Clinical Review Team
– Eric Colman, M.D.– Mary Parks, M.D.
• Statistical Review Team– Joy Mele, M.S.– Todd Sahlroot, Ph.D.
• Office of Drug Safety– Joslyn Swann, Pharm.D.– Lanh Green, Pharm.D., M.P.H.– Cynthia Kornegay, Ph.D.
• Project Management– Patricia Madara
• DMEP Clinical Review Team– Eric Colman, M.D.– Mary Parks, M.D.
• Statistical Review Team– Joy Mele, M.S.– Todd Sahlroot, Ph.D.
• Office of Drug Safety– Joslyn Swann, Pharm.D.– Lanh Green, Pharm.D., M.P.H.– Cynthia Kornegay, Ph.D.